 Welcome to the Single Use Products Working Group, meeting number two, days September 24th. So to get started, just to make sure everyone knows everyone's name or who's up at the table in our room, let's just quickly go around the table and introduce ourselves to each other again into the audience. Any comment on behalf of the American? Jen Holliday with the Chittenden's Hall of Waste District. John Ledy with the Northwest's Hall of Waste District. Lauren Curl with Vermont Conservation Voters. Chris Bray from the Addison Senate District. Good morning. Jim McCullough from the Brayville Hamlet of Williston. Gwen Zach from Montelaga Cities and Towns. Kim Crossfield with the Salloway's Management. Stephanie Bowman, Duo Restaurant and Rapper. Kathy Jameson, A&R, Salloway's Program. So thank you, everyone. And I have one quick question for Mike Ferrant. Erin Segrist, who's on the panel, was traveling today. Do you know if she's going to be able to call in? She had a little bit of a problem with it. OK. I'll leave over that information. Great. When you're ready, just jump in and we'll keep going. With that, I wanted to, I don't know if anyone has any questions before we get started with it. EPR oriented agenda to get going. So great. I'm looking forward to it. Kathy, do you want to lead us all? Excellent. Good afternoon for the record. I'm Kathy Jameson. I'm a Salloway's Program Manager at the Agency of National Resources. And thank you again for having me. So this includes products working through today. What I'd like to do is just quickly read the review of the points I made last meeting. And then jump into what is EPR, which is really high level, very briefly, before explaining the Vermont EPR programs that we have already in their effectiveness. And the other charge that I was assigned today is how would an EPR system, what would we look for in Vermont to apply an EPR system to single-use packaging? So with that, last time when we talked about single-use products, they're being produced and consumed at an increasing rate. They are comprising a significant portion of our landfill capacity. About 1 third of what the monitors throw away is attributed to single-use products. Of those single-use products thrown away, only about half of them can be recycled with that current recycling system. And as many of you know, the cost of recycling has really increased quite a bit in the last year and a half. And it's at a point where we're getting a large number of complaints. And what we're concerned about is that people might not continue recycling the current amount that's being recycled, let alone have a system where we can put more materials into our recycling system. And then, fourthly, we also went over some of the negative environmental impacts that that's from single-use products. And then our charge with ACES-9, we are to review a list of seven items. Today is EPR, which is one of those items. The lens that the law gives us to look through that to kind of how I look at it is like, this is our true norm. It is how are we going to make recommendations that reduce single-use product use, reduce the impact of these products, the environment, have a system that's improved. Who's calling while we blade you into the home frame? We're weighing less of these materials and there's less impact on the environment. So that's kind of the lens. So it can't be not all single-use products can be recycled with only about half currently disposed of. Is that, does that 50% represent exclusively the ones that cannot be recycled? Or are they also, does that also include ones that can be but are not being recycled? To be clear, it's out of the 155,000 tons of single-use products that we're throwing away annually. Half of that, so about 75,000 tons, can't be recycled. And not being out of that current system. Think about all the film plastic that we have or materials that have multiple composite layers so that it's plastic, it's a metal, it's aluminum or whatever. Those materials in our current recycling system won't fit. Right. Maybe it could fit in a future recycling system. Not today. Thank you. Okay, so jumping ahead. What is EPR? So in simple terms, what extended producer responsibility is extending or making the producer, the manufacturer of these products have responsibility throughout the light chain of the product. So it's product management. And in the past or currently with some of these products once the producers, once it's sold then the manufacturer usually is done, right? And then it's up to consumers or municipalities or solid waste districts to figure out how do we have a home for this? Who's paying for it? With EPR, the manufacturer is assisting with that management when the consumer is no longer using that material. So PSI, Product Institute Institute, which you'll hear more from later today, has a more complete definition and that is it's mandatory type of product stewardship that includes that minimum, the requirement that a producer's responsibility for their product extends to the post-consumer management of that product in this packaging. There are two key related features to EPA policy. One is the shifting of the financial and management responsibility from that government oversight up-screen to the producer and away from the public sector. That's one. And two is to provide incentives so that the producer incorporates environmental considerations into the design of their products, because that's what they have control over. Consumers, municipalities have no control over the design of these products, how they're packaged and how they're sold to the consumer. We'll just step with that at the end of the slide. So why the benefits? Why do we care, right? And so we would have a system that does incentivize manufacturers to make changes that are positive to use less packaging, have that packaging be less positive, have that packaging be more environmentally friendly, perhaps better to recycle or reduce the content altogether, which would be the best benefit as I said last slide, the best benefit that we have to the environment is to reduce the material. Whenever we can reduce, we are providing a better outcome. EPR also provides convenient collection systems. And now with our Vermont EPR programs, and I'll get into that in a moment, we have collection opportunities throughout the state. It doesn't matter what district you're in or what your town does or doesn't do for solid waste management, provide that consistent convenient opportunity. And that usually ends up with increasing the recycling or recovery rate at these materials. And then thirdly is providing financial relief. Right now, especially with recycling, it is costing taxpayers and swimmies even more today for managing these materials. And let me give you an example with electronic waste. So with E-Waste, we have Vermont was the 23rd state. A lot of people think we're the first state. No, no, we were the 23rd state that came along and adopted an EPR program for electronic waste. And I think there's now 26 states that have some sort of E-Waste program. They're different, they're different models out there that approach it quite uniquely. But with all of these models out there, with all these states participating, with manufacturers having to pay for 26 different programs in 26 different states, there is not a separate line I'm going to buy, a computer or a TV. That cost of managing these materials is just included in the cost of that product. Just like other parts of the manufacturing, just like sourcing the materials to build it, just like the labor cost, just like the transportation cost is all part of buying that item. I saw Best Buy and some of the retailers do have a cost now of being to take the E-Waste product back, is that right? If they are taking it back themselves, but are they charging at the upfront regardless of where the consumer takes that product? I don't know, I was asking. I think it's that way. I think some retail stores are offering collection of the materials. It's not, sometimes it might be at no additional charge, sometimes they are charging more. With the EPR program, the cost of that product is a flat cost of that product for all the manufacturing costs and the consumer has a no additional charge collection system available to them. That's a key part of EPR. Some states have EPR on let's say a product. So Vermont does not at the moment, let's say, and we are Vermonters paying an embedded cost for that product that the manufacturer's class distributor has included because they have to do it at another state. That's a great question. Since I'm not privy to how manufacturers calculate that cost and would that cost be incrementally higher if the other 24 states that don't have e-waste programs had e-waste programs, would that be a higher cost? I don't know, but I think the answer to your question, the simple answer is, yeah, we're all paying for it. So we may as well have a program that helps us manage the materials. Thank you. Okay, so who's involved? This is a shared responsibility model. So yeah, the manufacturers and producers are involved, but so are others. Retailers are generally involved because they can only sell products that are participating in the program. And that is determined. Usually the agency has a web-based list of those producers that are participating. The agency has been really, at least in Vermont, clear and communicating to retailers when a participant drops out by issuing stop-sale letters. And we have not had to do that often, just even having that in our toolbox is helpful in making sure that we continue to have participation. Consumers have responsibility that when they're done with using a product that they take it responsibly to the appropriate collection location and have it managed. And government, you know, with our Vermont programs in our, as we recite, implementing the program. And our Swimmies have been, our solid waste management entities, your districts, alliances, and independent towns have been really providing key, convenient collections throughout this day and making sure that these products are appropriately managed. We hope while we place you within your own brand. Don't forget to connect it. Okay, go ahead, John, I'll get it. This here, um... She's gonna try it and she's been trying to have it. Thank you. All right, about that. So, moving on. So, we have some key EPR programs in this day and month. And like I said before, we have one-on-use electronics. We have mercury-added products. That's the thermostats and the light bulbs. We call them lamps. The picture, enough, the lower middle picture, that's a switch in an automobile. Prior to 2003, automobiles had mercury-containing switches. They're no longer used in the production of automobiles, but we had a program to collect those primarily at our selfish yards. We also have a program for architectural paint that's based on latex and oil-based paints. And also on primary batteries, which the stewardship organization expanded to also collect rechargeables as well as cell phones. Like I said before, this is giving into our effectiveness that the swimmings and others help provide cleanant collection throughout the state. And so, you'll see here, under each one of these programs, that Vermont has obtained by having a really good collection network, by having excellent outreach on our programs, letting consumers know about the programs, and having it at no additional cost that we get high participation. So those are the three key factors in making sure any program, whether it's EPA or not, successful. So with e-waste, we had a dramatic increase in our electronics collection with the startup of the program, highest collection nationally, same with mercury lamps. And with the mercury lamps, thermostats and auto switches, it's really important to see, demonstrate how much mercury that we're removing from the environment by having these collection programs. Same with electronics, there are certainly heavy metals, PCBs and other components that are important to remove, as well as to recover the valuable materials that can then be used to manufacture or produce new products. Primary batteries also had a dramatic increase, you know, 2300%. Another way of thinking of that is, it's 23 times greater than it was prior to the program starting up. And then kind of a tag along is our rechargeable battery collection, which was occurring voluntarily up until then, had a dramatic increase as well. Paint, we have the highest recovery of used paint or unused paint among all the state programs. And if you want to see graphs of these, here are three examples of how we had an increase in the collection rate of our program. So with used electronics, you know, 2009 and 10, that's kind of like the base. Most Whimmy's offered collection of used electronics, some of them charged for it. I noticed that there were some consumers who felt like they paid a lot already for their electronics. So when it was needing to be recycled, they really kind of didn't like having to pay more to recycle something that they paid a lot for to begin with. My husband was among those. With these programs, though, we can unclutter our homes of these non-functionary, unused, no longer used products. And our collection rate increased by three full for electronics. And you see it decreasing a little bit now? That's because the heavier cathode ray tubes, the old TVs and computer monitors, we're getting through a majority of those. I don't say all of them, but we're starting to see a decrease there, just like other states that started either before or at the time we did, they're starting to see a decrease in the weight. This is all by weight, of course, in the PAN's collective. With PAN, it's the gallons collected. So we were collecting about 60,000 gallons. We have a huge network. Hopefully you're all aware of the network that our Whimmy's provide of the household has those waste events or their permanent facilities where you can periodically clean after house of paint and other household hazardous waste and have them properly managed. So even with that good network throughout the state, we still had nearly a double doubling of the amount of paint collected with an EPR program. Now, I think, again, there was a little bit of, I won't say hoarding, but keeping a latex paint that maybe wasn't as conveniently available for collection. So that, there was a big slugger that at the beginning of the program and now we're seeing that paper off a little bit, but still dramatically more than when prior to the program. And then I think one of the biggest changes we saw, maybe the color scheme isn't so great here, but there's a real sliver, a really tiny sliver of, I think that's good enough. But folks, I didn't mean to do that. A real tiny sliver of arcane at the bottom, that's the amount of primary batteries. How do I go back to where I was? So let me check in. Erin. Hi. Hi, you are on speakerphone room 10. Welcome to the meeting, which is in progress. Yeah, great. Thank you so much. Definitely. Hi Erin, this is Kathy James and I'm providing a presentation on ETR programs in Vermont. So. Sorry to be late. Thank you for allowing me to call in. So with battery collection, now primary batteries are the non-rechargeable batteries. Most people think of them as alkaline batteries. And so we have dramatic increase where we're not collecting much at all prior to the program and now we're collecting, it was over 60,000 pounds the first year and then up to about 80,000 pounds the second year. And then with rechargeable batteries, we had an increase in the amount that's likely far in how much we collected a rechargeable battery. So again, we're showing that, this is a good example of volunteer programs. Call the Recycle had a volunteer program of collecting rechargeable batteries for decades. Yet when we have an EPR program that's well advertised, that people are aware of, then we have increased in collection rate. So it's, and then likewise with electronics and paint, when we have the EPR program, we definitely have an increase in how we're collecting compared to voluntary programs. Kathy, I have a quick question about how these materials move around. So last time we were talking about the single sort stream and then there's also like, depending on where you are, some places are sorting materials, recyclables like glass by color or tin cans or the rest. How are these materials being collected? Are any of these batteries, for instance, coming out of, or paint coming out of the single sort stream or is that by then? I don't know if they, somebody handles it. We would not encourage anybody to put a battery or a paint or an electronics in your blue bin because that goes to the mirb and that would only cause problems with the mirb, right? So first of all, please don't put it in your blue bin. When you have these products, please go to a convenient separate collection. So these things all get collected separately. So you could, you know, go to the website, go to your Swimmy's webpage and they have an A to Z guide. Every Swimmy has an A to Z guide. You type in the item you're trying to find a home for and it will tell you the nearest location. Great, thank you. I'm just thinking a little head could, if we move on to plastic packaging of which there is a lot more volume, what's the way that these materials will be collected and flow for we'll get there later? Right. So again, those graphs demonstrated that we have an increase in the amount of materials collected. EPL programs also save money when you think about how we're currently painting and maybe it's shifting that cost to the actual consumer of the product so that it's a true cost of planning. But with E-Ways, for example, if you look at, we haven't closed out this year yet so we don't have data for this year. But the seven and a half years prior to 2019, we collected over 32 million pounds. A little bit of a question on that. As you just mentioned, maybe you'll get this. In terms of, it says it saves the taxpayers money over $10 million. Is that money that's for term of the taxpayer or is that just put somewhere else? I'll explain in a moment. Okay. So, we've collected over 32 million pounds in the seven and a half years of the period. And if you now remember, there was a charge that most families charged for E-Ways prior to the implementation of the CPF program. Sometimes it was $10 a computer or $20 a TV depending on how big it was. Okay. What we did for looking at what's the savings here is we took that 32 million and just looking at only the collection and recycling costs of those materials. And that saves the taxpayer and swing over $10 million. Now, that $10 million might have been embedded into the cost of those materials, which, you know, that might be a more acceptable way of managing the true cost of that product. So the cost of managing that product when the consumer's done with it is in that price already, it's already accounted for so that there isn't an additional charge like a ticker shop charge at the end of the life of the product. Does that help? Yeah, but you're saying it saves the sub-ways districts money. And that's not going back to the taxpayer, though, right? Thank you. The solid waste system isn't saying, you weren't known, you know, with packaging they wouldn't say, well, giving you back, you know, a portion of your property tax if that funds solid waste collection. So some of these might have been subsidizing the cost of managing that material prior to the UPI program. So we don't have a good clear breakdown of how much was being paid by this taxpayer and how much was being paid by this money. Collectively, it's $10 million. That's not being paid at the end of the life of these and of just the Vermont consumer electronics. Okay, but packaging, we don't have that fee now, so that it's built in somewhere else and it's not gonna be the same savings. Well, we haven't talked about packaging yet. I'm just talking about the tax waste. Trying to make comparisons, right? Yeah. And a clarification on savings to taxpayers. If the swimming saves money, the taxpayer saves money. Thank you. Which I think is important for us to. Right, because the swimming only has so much money to manage materials. And so if it's gonna cost more, that money has to come from somewhere and they get their money through the members that taxpayers in the industry. So it's ultimately for monitors. Any label you put on it. Managing electronics in Vermont prior to this program cost for monitors money. And now the manufacturers are paying for it and likely so is probably on the cost. It's a cost of that product. Just like making this screen costs X amount of money. Well, managing this material when it's done costs Y amount of money. And all of those things are factored in the cost of that product. So manufacturers as like a consortium or something like that pay in fee or the, how does the state of Vermont get money? Thank you, great segue. There are different models. So with our battery model, for instance, it is a stewardship organization that really takes care of all of that. And all the stewardship organization does with the state is submit a plan to the statement how they're gonna do it. We verify that the plan needs the minimum requirements that are in the law. And then the stewardship organization called Recycle interacts with all the battery manufacturers and has those battery manufacturers pay the stewardship organization for the collection of the batteries and then that recycling of the batteries. And pay for the outage of the program. That's one model. The e-waste model was a little bit different. In 2010, when we approached the e-waste manufacturers to have a similar system for the e-waste program, the manufacturers were quite adamant that they did not want to work together in implementing a program. And so the state was directed by the law to basically be the implementer of the program. So the state bills the manufacturers based on their market share. They're a national market share created for Vermont population by the weight of the materials they sell into the market for their cost of the program. And we have a contract for the collection and the recycling of the electronics. And so we, the state or the implementer of the electronics program. I will say that that is a lot of work to put on the state agency. And our preference would be not to be basically playing the role of a stewardship organization. Moving. First, is there another state sometime? Do you know what exact week? Well, some states required each manufacturer to submit their own plan. That became problematic in those states. And that, you know, you think about it. We have about 75 to 80 major manufacturers in our electronic waste program that we're connected with. That's a lot of different plans to keep track of. Those states basically had a target, each manufacturer had a target amount of pounds to collect, but they weren't necessarily required to collect throughout the state throughout the year. So if you're in Minnesota, for instance, you might just set up in St. Paul, the Twin Cities, collect the pounds and be done. That's great in St. Paul, but it's not great for the rest of the state. So with our program, New York is that way too. Right, and some of those states are considering modifying their state law because they're realizing that not all of their state is being served consistently. And the legislature at the time of the e-waste law, this was, you know, they were very adamant that all Vermonters would have access to this program. So they said, we need a model where all Vermonters, it's not gonna rely on what district you're in or what city you're in. And so that's why we have the model that we have for the convenience. And so it was basically modeled after Oregon and Washington as very similar models to Vermont for e-waste. Moving on. So that's about information on our Vermont programs. And so the other charge, Senator Brady made, was how would this work for single use products? It's gonna be complicated to think about it because, you know, like I said with electronics, you know, we're dealing with maybe 75, we need factors, batteries, it's about the same, you know, pain, I think it might be up to about 100. You know, when you start thinking about packaging printed materials, there's a lot more players involved, right? So you get, that gets complicated. But the elements are the same. And so for this exercise, what we did was we said, okay, we looked at like our battery law. What are the basic elements? And then we know about some of the discussions going on in the country looking at EPR for packaging. So what are the considerations that this group should have and looking at EPR for packaging? And so we didn't say one way or the other how these considerations should go. We're just listing them. And so for ease, I mean, for the next six slides in PowerPoint, it's this list, but to make it a little bit easier on folks, we might want to refer to it later. That's up to the chair. But they're all on this one single-page sheet because when I was first talked to the legislature, everything should be on one sheet, right? Uh, well, that comes out so cool. Okay. So if I may. Please. So with any EPR program, it's really important to, with anything you do, right? What are you talking about? Okay, so what are the products that will be covered? We call those the covered products. So with electronics, it was computers, monitors, because back in the day, monitors were separate from your computer. TVs, CRTs, printers, and peripherals. Well, peripherals was, it was covered to come back in, but we didn't capture all the manufacturers peripherals because there were a lot more manufacturers of things that can plug in, like mice and whatnot, but they didn't weigh a lot. They didn't, you know, so, yeah, we kept those separate. But what are you covering for products? And then, then you have to define producers and brands, many of our EPR programs have broad definitions of those. And then, real important is who can bring the material back in. And so with single-use products, I'm assuming for the working group that the Act 69 definition of single-use products is what we're supposed to be looking at right now, for products. So as far as covered entities, this group would want to consider would a program for this cover residents and businesses. And the one thing with our collection system in the state, and every state's a little bit different in how they manage solid waste, but my understanding, and we have an expert here, but we can't easily tease out the amount of material that's collected by residences and businesses, some small businesses on the same route as residents for collection. Is that correct? Yeah, so that's a consideration for this group. Another consideration is the collection system that we have. And it's real important to consider that it be at no additional charge to the customers to get participation, just like our other EPR programs. And so with single-use products, or some states are looking at just packaging or just loop-in items, but in any event, when you're looking at this, how do you deal with the existing infrastructure? And maybe I should have added in there existing collars as well, because those are businesses. So how do you balance the manufacturers or the producers wanting complete control for the system because they're frankly paying for a good portion of it versus how do we not strand investments that we already have and deal with the businesses that we currently have for solid waste management in Vermont? So that's a real balancing thing and that's something that this group would have to consider as far as collection. That's a quick question. So when you say at no additional cost to consumers, I think some people think that you're saying it's free. So it's not a separate paid transaction to recycle that, but the cost of that recycling may be already built into the price of the good that you purchased. Right, so my father taught me that nothing is really free, that somebody somewhere is paying for it. And so, and then him has taught me that running trucks over the ground, over the road, to collect things costs money. So there is a cost to collecting recyclables. You know, that costs money to operate. You have staff, you have equipment, you have O&M. So having a recycling system is costly. So how do you pay for that? And so what people are looking out in EPI program, you know, there's provinces in Canada, there's a 50% payment, there's 80% payment, it's 100% payment, what portion of the payment of that system of providing those services should be for aid for buy them in and back those. And so that would be a question for the group. Maybe it's a question for later. I mean, obviously living in a state that has deposits and just having gone through the deposit system. I know it's a different incentive, but are we missing an opportunity to educate the consumer about the need to manage this material differently with banning potentially some sort of feed that the consumer sees? So I just thought that I'd throw out there. I don't know if you thought about that in these other programs, on whether or not there would be a reason to have the ability for a fee or the deposit system or something on those lines. Being responsible for the oversight of Fadoville, I would caution us in not being another separate recycling collection system. It's right now in Vermont, we have two collection systems. We've got our Fadoville material and we have our BluVin system, okay? To have it yet third or fourth or fifth would be very costly to Vermonters. The Fadoville is very, very, very successful, but it costs more per ton to recycle those materials than our BluVin system. So that said, there are other models out there. Like you said, like a fee on packaging, that fee goes into a pool and then somehow that pool gets divvied up. That is a separate model for sure. But I would just caution about Fadoville types. I mean, it can still be a stewardship, but the extended presupposibility is just a different approach into the same goal, right? I mean. So my understanding is that item number five on our list of things to do is looking at, maybe it's four, four or five. One of them is to look at different methods. Today I was just charged with walking through Ethiopia. You're right, that's a model that some people are looking at right now. Oh, I was just gonna, when we were talking about the costs, just echo the point that Kathy made about when we're divorcing the costs from the manufacturer, that incentive to re-look at how you're developing the product in the first place. If you're offloading that cost to taxpayers or other people are paying it and not the producer, then you're losing that opportunity to incentivize. So, you have to be a one-to-one cost if you're producing it. Right. Okay, so I'm gonna try to speed this up a little bit. So our recent education, we talked about that how it's really important for any program. Stewardship organization, that's a nonprofit group usually that works on behalf of all of the manufacturers. They develop the plan, they collect materials, they're in charge of recycling, but maybe contact that out. So, with any EPI program you should consider, do you just require one stewardship organization? Do we do allow multiple options? Do you let manufacturers do go in alone? You know, our E-Waste Law allows for a manufacturer opt-out plan. So that's on the table for sure. The plan is really key in the law as far as what is required by the manufacturers through their stewardship organization and how they manage materials, what kind of performance goals should they have, and what happens, how do they implement the program to meet the performance goal. And moving on, the producers. This is getting after the payment part that we were talking about earlier. And so, generally, if you want a fee that helps incentivize the making less packaging, less toxic, easier to manage, more recyclable, the fee itself has to be such that it is different for each kind of category. So there's a term being used in the EPI world called modulating fees. And basically it means different fees based on different categories. You might get a bonus or less fee that you have to pay into, if it's more recyclable, or for flight of the material, and you might pay more, though, if it's not recyclable, if it has to be landfill, et cetera. So there's a whole concept out there on modulating fees. Sorry, I have a question about modulating fees. Has that been done in the United States or Canada anywhere? Well, the United States does not yet have a state that has an EPI program for packaging, right? Yeah, yeah, but for e-waste or anything else, has it been modulated fees for easily? France has one. For the E-waste. Yeah, France has adopted modulating fees, and they have data that shows that it has actually improved the recyclability and the recycle content of these materials being sold in the marketplace. So modulating fees can be effective in something that the group might want to consider. How we've talked about embedded fees, that's where the fee is incorporated in the cost rather than a separate line item. Our e-waste law allows national sales data to be used to per-rate based on our state population in order to ease, make it an easy way to calculate what the market share might be. And then most of our programs have an assumption for small producers based on either a number of products produced or perhaps under sales. And then another key component is the responsibility of the stewardship organization. So remember, this is the group that's implementing the program on behalf of the manufacturers. And so lots of considerations here for the group. So one is, in the state of Maine is looking at this right now with their, and I'll get to what Maine's doing in a moment, but how do you have the stewardship organization pay or reimburse for the cost of collection of these materials? And so does the stewardship organization take responsibility for all the recycling? So then they just have to pay for it. Or if we have the existing system in place, is there a reimbursement of a portion of the cost? And so that's a consideration for any program. State of Maine's also looking at a consideration of the payment of the portion of the waste stream that is disposed because as Representative McCullough pointed out, not all of this material goes through our recycle stream and still can't go through our recycle stream. So what happens to that? What's the compensation that taxpayers get for that portion that still has to be disposed? Then the change in our marketplace because what we've seen in some places, not in the United States, but in Canada and elsewhere, where the stewardship organization works with manufacturers to help develop additional or better recycling markets because what's recyclable is really, it's dependent on the market. And if there's a better market out there, then maybe we can collect more different materials that can then be recycled and used for input manufacturing new products. So that list at the beginning that I pulled directly from Act 69A through E, one consideration is having the stewardship organization report annually on how well they're achieving those items. And then other items that we have, other components and the law that we've had is the producer is predicted from selling a product in the state if they're not participating. That's a key portion that to incentivize the producer to participate. And we use that as a tool to gain compliance with the law with our other programs. With EPR programs for packaging, it's important to have performance goals and those goals are probably gonna be different for each kind of material type. So glass would be different from paper, would be different from plastic, whatever we're collecting. And there needs to be some sort of consequence that the goal is to incentivize continued performance in collecting these materials. All of our programs require annual reporting to the state on how much they're collecting, where it went, having an audit by third party is important and what their plans are for the upcoming year. To allow manufacturers to work together with this stewardship organization, you'll see an anti-trust condition in our laws. And that's because the manufacturers didn't want to be pursued for anti-trust issues if they're working together on implementing this program. So that's that issue or that's why that component's included. There are fees that are associated with this. One is paid to A&R for our oversight and then the law usually defines what A&R's oversight is. Generally it includes we review and approve if it's acceptable to plan. We do annual reviews of their reports, their performance goals, we have enforcement and that can be making sure that the producers who are supposed to be are participating, are participating, et cetera. With data being submitted to the state, we have to make sure that any confidential distance information is kept confidential. And of course we have to have a schedule for implementing the program. So there are other states, I'm not sure how I'm doing on time. Roughly five more minutes. Okay, so you can hear from others about how there's a multiple of EPR programs throughout the United States for all kinds of programs or products. Right now there are several states that are looking at, similar to how we're looking at EPR for either plastic packaging or all packaging or single use packaging. I think the states to watch right now are Maine, Washington and California. And real quick, they already had EPR framework legislation that requires their DEP report annually to the state. And as part of that in the legislature with their discussion with Maine DEP, the legislature passed a resolve requiring their DEP to come back for this 2020 session with proposed legislation for EPR law for packaging. So Maine's DEP is working on that right now. And the resolve required that the proposal has to include a stewardship organization that the producer fees are basically modulated, that the producer fees pay for 80% of the cost of recycling in a portion of the disposal of the non-recyclable material and that it funds education and outreach. So stay tuned, we are in touch with Maine and so we're looking forward to hearing from them when they have a public document. They did have a model, conceptual model that they released a couple weeks ago. It's not proposed legislation. Washington State had slightly different legislation. They're taking a little bit longer point of view but their goal is by 2022 to have better management in place for plastic packaging. So they're requiring the state to hire a third party consultant to evaluate plastic packaging and report back in about a year from now. And that report has to show how they're going to achieve 100% for, let me back up, that plastic packaging has to be 100% either recyclable, reusable or compostable by January 2025. And that that packaging also has to have 20% post-consumer recycled content. They also need to try to reduce, we said that's the best bet, that it's when you reduce it and identify costs. So they're another state for what? Is the post-consumer recycled content requirement a way of trying to drive the marketplace and create other uses for the material? Right, and it helps provide an incentive to collect it if you have to incorporate it into manufacturing the products. California has a lot of activity going on. So they had both an assembly and senate bill with the same bill. It was, they called it the circular economy bill. It required their state to adopt rules so that all packaging or single-use products would be recyclable or compostable for 2030, allowing a little bit more time than Washington. However, we'd also mandate a 75% reduction in waste if it basically was being disposed from these single-use products. That bill has not passed. My understanding is that they just finished year one of a two-year biennium. So I think that that bill is still alive and can come back into discussion in January. Meanwhile though, they did, they just passed two separate bills. And one is that for businesses that are required to recycle or compost and they need to provide the same services to their customers. So for instance, if you're a restaurant and you compost and recycle, that's what I'm talking about here. Maybe a mini-maric or something that has recycling of materials in the back end. They have to make sure that there's a trash can that does the recycling of the finer. But more importantly, more importantly is the post-consumer part of this. And they passed a separate bill or this is just their bottle bill plastic. 10% recycled content by 2021 and 50% by 2030. But that's just my understanding of the bottle bill plastic containers. So that's kind of the state of the state and what's happening at a very high level. And I think that kind of sets the table for some other presentations, which might be a good one. Similar to the auto emissions California program that have been multiple states in one who've adopted the California standard. Is it too early for states to have considered or have any adopted the California standard, if you will, on bill 792? Oh, I'll just close it up. Is that the bottle content? You know, I think they're a real driver in manufacturing of materials. Maybe someone from the marketplace can tell us if that's gonna drive a couple of all of that states. It's the first bill in the country to pass and just passed a week ago. Oh, oh yeah, yeah, two, yeah, right. That's literally it, right? Thank you. Quick question. So thank you for putting this together for all of us. When you think about, me and Vermont and even Washington having this kind of a conversation, how do you think about the possibilities to move forward when we're not California? So we're not 40 million people. So are you imagining that there's ways that states are gonna be able to make steps independently or as groups of states, or what are you thinking might happen? For instance, New England and Vermont. You know, that's a great question. Wouldn't it be ideal if everyone could pass the same law? The challenge with that is our solid basis since we're not the same. You know, for instance, like Massachusetts, my understanding is curbside collection of both trash and recyclables for residents is pretty much done by the municipality. Like, municipality contracts that out. But we don't have all that subscription service that Vermont has and what I mean by that is that, you know, Vermont, you genuinely call a private holoruck to come to your home and pick it up. So you have various hollers. You know, I think it's probably easier to implement in a state where the municipality has one contractor providing that service. We have multiple businesses providing services and our municipalities. For most of them, our municipalities. And that I think is gonna be a different challenge for us to think about. You know, Maine, we've been having discussions with them because they're leading the charge. One of the ones leading the charge. And my understanding is that municipalities and they are required ultimately for trash and recycle management. So they all have transportation. So there's municipally owned facilities. So that's why when you look at Maine, Long, you look at their conceptual model it's municipal reimbursement because municipalities have a real cost here. You know, yes, we do have some municipal transfer stations in Vermont, but we also have privately owned ones. And so we have a different variety of players touching, managing these materials. And I think we should be conscious of that when considering any of these models. Any questions for Kathy before we go on? Thank you. Thank you. I just have one more reason to raise Senator McCullough, the task force. I'm Scott Cassell, I'm the CEO and founder of the Product Stewardship Institute coming up from Boston, beautiful drive up here. Today's theme of the leaves change. I just want to start by kind of answering your last question and then I'll back up. In terms of models, that's really the way to think about our organization is that we've developed models for extended producer responsibility across the country. And in terms of packaging, and let me just say, it's great to come after such a great presentation on EPR, usually the one kicking it off and breaking the ice on things. So thank you for your presentation Kathy. So what we do is we try to find the commonalities among the different states. We work with 47 states and lots of hundreds of local governments on this and I'll get into that more. But what we try to do is to develop models because that's really what industry wants. It's more fair to them, it's less expensive and governments share with each other but they don't always know the best practices. So that's where we're coming from. So I'm gonna also, I know that you're just getting these slides, we have up here the behind me so I'm gonna keep going back and forth so you can follow me. Since I'm not known in Vermont, I thought I put together who I am, I've been working in the waste field for 35 years. I founded the product stewardship institute with many, many people 20 years ago. Been working on packaging EPR for about 15 years right now. I was on and pointed to the Connecticut legislative packaging task force which I think is similar to what you're doing here and went through that process two years ago. I'm also the president of the Global Product Stewardship Council, we share information globally. And for seven years I was the waste policy director in Massachusetts, liaison with the governor's office and all of our departments on waste, hazardous and solid waste issues. I come from this from a dispute resolution perspective matching the technical with facilitation and mediation and that's how we've developed these EPR models. So the ones that you have here in Vermont, our organization developed with Jan Holiday, with John Letty, with Kathy Jamison and others here. We bring together the experts and all over the country to develop these different models. So our organization, we're based in Boston, we have 47 state members, hundreds of local government members, we also have 120 different partners, mostly businesses but also university representatives, universities, organizations including environmental groups and non-U.S. governments. So particularly those in Canada and Europe that work on product stewardship. We have an advisory council, business and academic, global product stewardship council as I mentioned before and then we've also helped to start to found or co-found a number of product stewardship councils including the one here in Vermont that Jan Holiday is the chair of and John Letty is also an active member in. So we work very closely with those in Vermont. I think every solid waste district is a member of our organization and works on the Vermont product stewardship council. Here's just another diagram to amplify what Kathy had mentioned about product stewardship. That term is one that we defined a number of years ago with a couple of other organizations to get on the same page. Product stewardship is the big circle here meaning it can be voluntary or it can be mandatory. So if you follow the upper end it could be producer responsibility like the thermostat recycling corporation all over the country here, it's mandatory but it's voluntary in other parts of the country. Batteries is mandatory here, rechargeable batteries it's voluntary all over the country. Industry voluntarily taking responsibility that is part of product stewardship. It can also be government regulatory programs acting on their own if government say limits the mercury in a product like it did in the Northeast and here in Vermont on mercury thermostats or thermometers or other things it's taking action. So those are all under the product stewardship umbrella but EPR extended producer responsibility is really a mandated end of life aspect in what we think of as take backs. So it's take back the product and as Kathy said we're extending the producer's responsibility from the typical in the manufacturing plant where you're responsible for air emissions, water, land worker safety extending that all the way to the end of life management of the product. So they're responsible for it even in the back end. And the idea is if they're responsible they own that product and problem if you will for material then they're gonna think about what they put into that product upstream. So they're not gonna put materials in that are toxic or costly in the back end because they'll have to deal with it and they'll make that calculation. So it's a connection that's very important. So just as a big picture trends from 2000 to 2019 118 products by EPR laws have passed in the United States. You can see here Vermont is red in color and has eight of these laws. They're second only to California with nine, Maine has seven and there are 118 laws passed on 14 different products in 33 states. So it's fairly expensive across the country. These are some of the products here starting with mattresses, lamps, paint, medical sharps, batteries, thermostats, electronics and pharmaceuticals, five state and 20 degree local pharmaceuticals. As as Kathy mentioned, zero on packaging so far. So that's an important thing. Good question on the experience around these other products that already have been regulated for a while. Often people, discussion of finance always comes up pretty quickly and people say, will this cost me more or will this cost me less in the end than not building in the cost of front fringes? So can you say something about the economic experience that you see in terms of when there's EPR? Overall costs, however divided. This isn't too dizzying, what I'll do is go right into the end. This is like the saber slide. But as you'll see, there's two types of financing systems for extended producer responsibility. What we're talking about for packaging, the most part is on the left side and you have here the electronics and the thermostats and batteries that are cost internalization model. I'll talk more about that. And in that way you don't see any increase in costs if there is, it's spread over, if that financing system gives more flexibility of the manufacturer. Basically it says you have these responsibilities, you have to figure out the cost and the responsibilities could mean to recycle a certain amount of that material you put into the waste stream or you put onto the market, you have to take that back, you have to figure out the system, you have to educate them. Consumers, you have to have the administration, all that, you figure out how to do that. You can add cost if you need to to all the products in your region, in your country, whatever, or you could reduce your cost somehow. We don't care as a government, it's up to you to figure that out. The three models, the eco-fee model on the right-hand side here, there's only three of those. It's paint, you have that here and mattresses and carpet. There's three laws of mattresses and one on carpet and those are the eco-fee model. Like paint, it's, what's it now? It's not 75 cents, it went up to 90? 99. 99 cents, 99 cents a gallon on the paint case. So the consumer there pays more. I'd say the missing discussion on cost here so far and it's hard to calculate, of course, is the externalities of the environment, right? We're trying to incorporate those externalities and there's a cost to preventing those externalities from happening. There's also a benefit that's hard to calculate but it's in jobs and economic development and material use. We just came back from Colorado last week and we announced the creation of the International Paint Recycling Association which Chittenden County is a member, one of the two government members. And these are businesses that have formed and expanded over the United States because there's a supply of paint that's being created by these EPR programs. They're creating jobs, there's economic value and so it's not only creating the market, as you mentioned, for the material but it's creating some positive financial benefits. So there's financial costs that are covered but there's financial benefits and then there's the externalities not created. And those are tough to calculate but I just wanted to put that into the mix. Thank you. You heard me ask the question earlier in the afternoon. This is regarding, again, your last slide, the internalized costs of products, that's one way EPR is done. Are Vermonters or other state residents paying an internalized cost for a product that they do not have in their state an EPR on but manufacturers have embedded it in their list? There's no, I don't know how we can figure that out but there's no evidence that I've seen that it might be happening but I think it's more, it's broader than that over the United States, let's say it would be imperceptible. Like it's not happening on a state-by-state or even a regional basis. No. I think that would be something that the producers can address better than I could and in Canada where we've worked across the state with those from packaging, one of the representatives from Unilever who is supportive of it and works in the EPR for packaging systems has said that there's not that change. Now it could be because the market in Canada is smaller and the United States markets bigger but it has not been brought up as a major concern that one state or one region is paying more for this and as a matter of fact, I don't wanna get too much into it but the pharmaceutical take back the pharmaceutical industry sued brought a case to the US Supreme Court on that basis saying that it was a commerce clause that California's law was putting externalities and raising costs in other places and they don't get the service and so the Supreme Court said they're not gonna hear that case that went back to the Ninth Circuit and they let that EPR program stand. So that's as far as that argument has gone as far as I know but there may be others that know more than I on this issue. Thank you. So why is EPR growing in the US and globally? The ground has been plowed. We've been doing it for 20 years and this is the wider view of lots of people in the United States but globally it's been for a long time, over 35 years. I mean we've been coordinated this concept from Europe and Canada and coordinated it from Europe as well. So it works. There's sustainable funding for programs. There's savings for governments as Kathy was saying. There's financial benefit. Some of it is direct. If you spend, if you're spending on paint, a million dollars on paint but you really need to spend five million and then the program comes in and there's five million of benefits so it's one million of direct financial savings and five million of benefits. I mean that's kind of getting to Andy's question here. Education and infrastructure, there's more convenience for consumers, increased recovery, you see it for all different products and even for packaging. There's more jobs. We had calculated 200 jobs for the paint program alone and that was about three years ago. So there are actual jobs here being created. Improved efficiency and then better products. Not on every single product but and not in every instance but there are design influences. More for packaging than say electronics, less for paint than some other different product. So this isn't just a statement. This is really a fact. EPR is the centerpiece for the circular economy when it comes to Europe. Europe is mandated. They have, they come out in front and they've mandated EPR as the centerpiece for the circular economy. They could buy the law. The 28 member nations, they have that as their directive and so that's the way we look at it here in the United States and globally here's, you can see the same slope as I showed you in the United States it's happening globally. This is five years old. It's from the OECD organization for Economic Cooperation and Development. We work closely with and you can see that the number of EPR programs has really risen worldwide. We're about a third of those. Caution here is that they have a different definition than we do but it's very similar and overlapping in many ways. The next slide shows you that packaging is the second most prevalent program in the world. Or maybe tied with tires, if you will the tires are more fees and packaging is really true EPR. We don't consider advanced disposal fees as EPR in our definition but they do globally. So electronics number one but packaging is number two. And this is the, this is pretty, maybe startling but in 2000 you can see that's part to the left. It's just some countries in Europe had EPR for packaging. And this is the light blue. And on the right hand side you see EPR for packaging in 2019. And this is all throughout Canada, all throughout Europe. And there are, there's Soviet Union, Russia has this. And then in the yellow are those in implementation, China and India. And you have the dark blue is also EPR in implementation at the country level. You have Brazil and I was just in Chile recently and that's in implementation too. This is all over the world. Israel has the program, many, many countries. We do not in the United States, zero. We're one of only few OECD nations that do not have EPR for packaging. It's, we're kind of following the trajectory of what we do when climate change. But we're gonna change that, right? All right, so the next slide is a, is a, this slide just showing where the US fits. This is from a producer organization in Europe. The red is the US fitting it in or between Latvia and Romania, I think. And other, this is just packaging. It does not have printed paper to it, but taken out. Just showing you that we're, we're not doing well compared to others. I'm just gonna pause here and move into a different direction unless there's questions. So, oh yes, Lauren. Just seeing this, you know, exponential curve of the growth of EPR policies and then we're simultaneously seeing these like massive increase in plastics and packaging. Just, could you speak a little to, is it like these haven't had time to go into effect to drive down those global trends or are we not doing the right things or just, just kind of that disconnect. Yeah, that's a good question. I think it's that a lot of the plastics is coming from nations that don't have systems in place, EPR systems or bands or fees. I mean, what you've put in place here are what other country like India as well. You know, I was over there a couple of years ago and they're struggling with putting these programs in place. They have a big informal sector. They're, a lot of plastics coming from there and into the gyres into the oceans. So yes, I think that's it. We're in the beginning of that. And so EPR is one of the solutions. It's not the only solution. Sometimes you wanna ban things in which we've done here in Vermont, certain items. So there's various approaches and it just has not caught up to the problem yet. So I have here a dialogue process and this is really what we do at the heart of the organization. We do a lot of research. We bring the experts that I call the brain trust together. We have the government brain trust and those in the industry to solve the problems. And you need to have all these different problems. That's my training in mediation is that they can't be directed. And so we've developed this process where you go through what's the problem. Everyone needs to agree on it. If you don't agree on the problem, you can't go to what's the goals that you're trying to achieve. If you don't figure out the goals, you can't figure out then what's the barriers to achieving those goals. And then you can't start to talk about solutions. If you rush to the solutions without figuring out the other things, you're putting the cart before the horse. And so this is the process that we've used for over 20 different products for the United States and has worked in various ways here for the different product categories. So starting with the problem, this is a slide I've used for probably at least 10 years or more, and I'll use it again. It's good recycling or reuse, is that the recycling is stagnant. It has been for about a decade. It just ticks up a little bit. We're at a straight line here in terms of recycling in the United States. I'm not talking just Vermont. You are a leader in so many ways, so I want to hesitate. I don't know where you are with the average. I know you're hurting on the packaging like everyone else. It's fragmented. So for packaging, each city, county, jurisdiction is collecting a different set of materials and they're educated on different ways. And there's a potpourri, if you will, a fragmented system. It's underfunded. We all know that government is stretching so many matters. It's based upon an annual appropriation. It's not reliable. It's underfunded. We've worked quite a bit in Connecticut. They have calculated $30 million for their recycling. That's the cost. I just heard yesterday, you're talking to Maine. It's about half that amount, maybe 15, 17 million in name. We don't have a number for Vermont, but you can see it's big dollars and those are costs that taxpayers and governments pay. And of course, there's difficult markets and if there's a problem, it all falls back on government. So this is where, you know, this is, I think why you're here, it's who pays. And I think around the country that governments are finally saying, why are we paying for this? Why are we paying no matter what happens? The markets go out in China, our costs go up, everything gets passed on to us. We have no control over the system. We have to pay it or stop our recycling program. It's, you know, and it's coming to a crisis right now. So crises are good for these kinds of things and this is an opportunity to really change the system, to make the fundamental changes that we've all been talking about here in 15 years, that Europe's already put them in place for 35 years. Those programs, many of them in Europe, are in place for EPR for packaging for 30, 35 years. That is crazy, but that's the case. So we have an opportunity. There's no incentive for, oh, answer, yes. One question that we saw in the European race was 80%. They include waste energy in their calculation of energy, that's correct. I asked that question in the answer I got from Joachim Koden who runs that expert as metal and that does not count as recycling and no recovery. Yeah, because I was curious myself, the answer is no. So there's no incentive really for manufacturers to change their product design or reduce the impact unless it lowers the cost for them. I mean, that's what manufacturers should be doing. They should be lowering the cost and, you know, lighter weight electronics, as Kathy was saying, the electronics are getting lighter and that's all a good thing in the manufacturer. That's why the driver there for electronics is more about the lightweighting. But there's less incentive if it's not for that. You're not gonna do it because it's more cost on government. So this is where I put a question mark. What are Vermont's goals for recycling and reform? And this is where, you know, as a mediator in a consensus builder, I can tell you what we're hearing from other states and jurisdictions. So take that in that vein, it's not me saying what it should be or what it is, but some of it is in the definition of EPR. Our definition of EPR, this is for the group or Vermont, this working group or the legislature to figure out A&R to figure out. But one goal needs to shift the costs from taxpayer-funded government programs to the producers and consumers, either fully or partially. Reducing ways to increase reuse of recycling is probably the no-brainer, we all want that. Maximizing material value, so for reduced contamination, there's things to do to reduce contamination. Some of those would be stipulations, requirements on governments, we'll pay you this much if it's clean, but we'll only pay you this much if it doesn't have that quality. So you actually have a lever in there, but material value, creating recycling jobs, and then giving incentives for the manufacturers, pro and con incentives for them to make more sustainable products. So what are the objectives? So cost internalization could be one, rather than eco-fee, for example. Producers paying the cost to recycle what they put on the market. A cohesive system that melds with your laws and regulations, I think that's also one, most states want, cohesiveness. And then there's this differential fees or eco-modulated fees, which Kathy brought up, to create an incentive for the use of material that costs less to recycle, has less impact on the environment. And so I wanna go into that a little bit more. I do have some slides here that I got from others around the country. So this is really the leading edge, if you will. And thank you again, Kathy, for laying that out on the groundwork link. So the eco-modulated fees, they're set by week. It's one basic way. So if you have a unit of measurement on, weight is the unit of measurement. So if you have less material to make your product, then more material, if it's less material, it'll be charged less, because it's less weight. It also can be set by the type of material that would reflect environmental costs. So for example, recycled content. So if you have low recycled content, you're not creating that market pull, then you'll charge more. Or another way to say it is if it's high recycled content, you get a bonus and you'll be charged less. And these systems are being revised in Europe and Canada to reflect now the true cost of managing materials and to incentivize eco-design choices. And this is saying, this is one of the most rapidly developing areas globally. And your question was, is it happening here in the US on other products? It's starting to be discussed for them, but I think that the leading, the concept is leading on packaging. There's most experience in that and that's coming globally. So I have a couple of examples here. One is the British Columbia program. And if you see this slide, I circled the red. So within the category of plastics, PET containers, for example, would be, and I put the glasses on here, 53 cents per kilogram. But the same weight for plastic laminates, because laminates is less desirable, would be double that, okay? So the cost for the plastic laminates would be more. Now it's not telling the producers you can do this or you can't do that. There's not banning laminates. It's saying, if you wanna use laminates, it's such a problem that we're gonna charge you twice as much, okay? So that's what the producers have come up with in British Columbia. This is from the producers themselves and I'll explain that. Kathy mentioned the stewardship organization. That's where all the figuring out of the costs and how to assign these costs comes about. But the producers basically assigned themselves these costs. Now in France, this program here, it's run by a stewardship organization called CIPEO and they currently only have one EPR fee for all plastics, but beginning in 2020. There will be seven categories for plastic packaging to reflect the level of development of recycling facilities there. And this is where life cycle analysis, if I can say, it can be changed by putting in infrastructure and changing the calculation of the benefits by putting in, say for example, infrastructure. So here, just look at the top line model in a biode in a clear PET versus the packaging containing the PVC. You can see that there's an incentive for the clear PET and a disincentive for the PVC containing plastic. On that model from France, does it also include, is that life cycle analysis include public health externalities where plastics can reach toxic chemicals or toxic chemicals can be involved in their manufacture and stuff like that? So, do they get into that side? They will, let me just say they will. I don't know particularly if France does that. If they're just moving, if they have one fee now and they're moving to this, it looks like they're not there yet. But say the Canadian programs, they're run by an organization that coordinates all the stewardship organization and they put out a study to look at where we can push the envelope on life cycle, looking at the toxics or other impacts. And as we know, life cycle analysis is very complicated, very costly. And to get further than it depends, we need to, which is, I've had my experience with life cycle analysis, it's important to think that way. How we can bring it down to this, we need to do that, and that is even beyond what I see as the cutting edge now, but it is, people are thinking about that and that is where we need to get to. So here's the Netherlands. And so starting January 1, 2019, a lower rate will apply to plastic goods that can be sorted and recycled with a positive market value. So you can see the various rates. These are also called differential fees because there's different fees. Non-recyclable plastics is higher than an easily recyclable plastic. And then they even define what's recyclable. Of course, that needs to be defined and made from the type of plastic that is collected, has a market value and or supported by a leading humanity program, et cetera, et cetera. So there are specifications here. This is the goalpost. It's having it clear to the producers like how to play the game. It's clear to them and let them compete into this game, but the game is getting more sophisticated and these eco-modulated fees are more sophisticated. And I'm not going to go over this slide. Yes. Yeah, just one question. So the British Columbia, the fees are set by the PRO, France, and the Netherlands except by the government or who sets those up? No, those are set by the PROs. Yeah, yeah. No, there's different ways to do this. And it gets down to the level of prescriptiveness that a government wants and we see this all over the United States, someone, everything in the legislation themselves because they've won it all spelled out and their experience with the producers or with others because if it's not in the legislation then the producer's going to argue about it and there could be a lawsuit where there's uncertainty involved so they want everything in the legislation. There's others that say, okay, we'll let the producers propose that to us and in this case, the us would be the government oversight agency, let's say A and R and it would shift the responsibility to the administrative agency. And so they would get a proposal from the producers, let's say, that would say, okay, here's what we propose for our modulated fees and then the legislation would say you have to have modulated fees and there might be some stipulations in it but it would allow the industry and the flexibility to propose that to A and R and they would review it and either prove it, disprove it, ask for more of it so it gives them the authority. So those are two of the elements that we see but the producers are very much involved in that because it's their programs and the one that's doing the good stuff and having environmentally preferable materials in their product, they want to get the advantage. They want all their R and D to pay off as it should. Can I have a quick question on how those, the proceeds of their government or entities collecting those fees, do the producers typically have any kind of influence over how those dollars are expended? For instance, might they be drawn to using a particular kind of material if government invested in infrastructure that would create a higher level of recyclability of that material? So that it would be a more optimized system or do they just pay in more and where the money goes, who knows? I would say that we're just about to start a discussion with the Flexible Packaging Association. And it's one of their questions that they'd like to bring to the table, which is whether the EPR system and they would like to see the EPR system, the funds that are created, have some amount of funding go into R and D for flexible packaging, flexible package recycling. And so that we'll put on the table to the governments and they'll see. Now I think R and D in the pain program is happening in the three states that have surpluses on the pain fee. And the fee is different than cost internalization. Here, I know you've had a deficit and hopefully it's more along the line. That's why the fee is raised. But in three states, there's a, and it's pretty good, such a great job here in collecting the pain, I think it's why that they didn't get it right, the pain here. But you have three states where they used funding from those states for spending $100,000 in each of the states for R and D into non-pain that is recyclable but is not good enough to go into recycled paint. For example, you could use that to make adhesives or soft rock, they call them, or some kind of other recycled paint products. So that is a precedent for using some funding from that pod for R and D that would then create more markets and solve an overarching problem. So here's the last example of the eco-modulated fees and I know I spent a lot of time on it but I think this is an important concept. I'm not gonna go over this but you can look at it another time. Germany, Sweden and Italy are also moving in this direction as well to put in place eco-modulated fees. Europe does not mandate it happen exactly the same way the member states have jurisdiction to implement it but they do say and it is mandated that they all have to have modulated fees. So back to the questions. Here's some things to consider if you wanna have as one of the objectives and the use of existing recycling and solid waste infrastructure. You want all municipalities to collect the same materials and have consistent messaging, same messaging or like paint care has the same messaging all across the country. Safe money is the benefit to that. You wanna have full producer payments into the system. Usually if there's full producer payments the producers want more control. That's kind of the tug here in the negotiations. Always have government oversight. The concept of a multi-stakeholder advisory committee is here. There's a big question of governance. So these producer responsibility organizations are just producers but you could have in that group the legislatures could say well we're gonna have a member of ANR, we're gonna have a local government representative, environmental group representative on the board to have that voice right in there or it could be multi-stakeholder advisory to that producer responsibility organization. So governance is a very big issue globally and you see here the carpet program is getting a lot of the carpet manufacturers and the stewardship organization they have developed is not working well and there's people that wanna take that control completely away from the producers. So if they don't do a good job then they're on the hook and they'll be behind the ape also there's an incentive for the producers to do a good job but how does government ensure that that happens, what oversight? And there's a number of different models for that to consider. Can I ask a quick question just so I can make sure I understand the term full producer payment in a system. So they're paying into every step of the entire system but are they covering, does that also imply they're paying 100% of the costs for all that? That would be 100% but it would be globally so it wouldn't be just paying on collection and paying on processing like separate. They would figure out what's the cost of the system that government's telling me I need to produce. I need to reach 60% recycling of this material by this date. What's the cost going to be in the infrastructure and education and administration for doing that and also paying government oversight. Let's not forget that, that's part of the program, government oversight before. So all that together comes into a cost and that's what the producer responsibility organization figures out. How to apportion that to their different producers that pay into that fund. So we're gonna go down here just the different paths. Briefly, this is a main fork in the road that we've seen here for our members is you. And these are becoming archetypal programs. Do you want either the British Columbia model because British Columbia, Canada or do you want the Quebec model? And there could be a hybrid somewhere in here. So I'm just laying these out as options. What people mean by British Columbia is that the brand owners are responsible for financing and managing the recycling and municipalities from the PRO are given some options. They say, look, you can turn your recycling system over to us, we'll pick it up. And that's it, we'll take that over. You don't want to buy new trucks, maybe you never did it before. Look, we'll take it over. You could also be under contract. You as a municipality could be under contract to us, the PRO, to recycle. Now what they do is they put a number on the table and they say, we've calculated what the optimal cost should be. We're going to pay you X. And that municipality will make that decision if they want X. They negotiate a little bit, but they seal the deal and they'll say, OK, I'll have a contract with the PRO. A third could be the municipality says, look, we love our system, we market our materials, we're doing great. You guys do what you want, we'll continue. And you can do that as well. So there's options. The Quebec system, the producers are responsible for financing recycling, but the municipalities actually are responsible for managing the recycling and they get reimbursed by the brand owners. So this is where there could be more of the patchwork, if you will, if it's developed that way. So let's say each of the municipalities has different systems. They like it. They like where they're going. Some of them have their own public mirf. They know where they're going on a private mirf. They want to keep that system, but they want to get reimbursed for it. So this is more of a reimbursement model. Less disruptive for the existing situation might not be optimal for some of the other things, depending upon what you want, but less disruptive. And then there's the hybrid somewhere in. I don't want to answer this question, so let's go back and have 100% because they're made back to financing under the program. Yes, it's moved from 50% over the years to 100% producer finance. And when did that change happen? Very recently, a year or two ago, it's pretty recent. Yeah, because I remember 50%. Yeah, it went from 50% to 75% and then to 100%. But the control, they didn't get more control over the system. And then there's the hybrid. I know how much time do I have just to do a check in there? I'll give you about another five or 10 minutes. OK. So I'll just kind of breeze through and please stop me if you have some questions or comments. But there's something in between those goal posts. That was really my point, is that there's two archetypal programs and something in between. This next diagram on cost internalization here is very simplistic, but just shows you that the producer pays into the system into the stewardship organization. Or there's that diagonal line down. The producer can do it themselves. You usually find it more cost effective to join a stewardship organization. And then in this case, it's more like the British Columbia model, where it's industry run. They figure out the costs. And they hire someone to collect, someone to process, someone to educate, and they have their vendors. If this was the Quebec system, the industry run program, that would say government run programs, municipal run programs. And there would be a reimbursement to the municipalities for their costs. So again, idealized program. The arrow is going down to the retailer and the consumer. It may or may not happen. This is the cost thing. For an eco-fee, it has to be handed down from the producer. It's legislatively, the assessment has to be handed down. The producer doesn't have to. It's just incorporated into the product. Is there any impact on effectiveness, whether or not? I mean, part of it. Sometimes we have discussions about when you see a fee, it gives the customer a little mental check-in. Oh, there's a fee relief. So it may modify behavior in a different way. Is there one type of program tend to be more effective than the other? I think we could have a week-long conference on this. We still have no conclusion, but with lots of interesting discussion. I don't think we've come to that yet. I think governments prefer cross-internalization because they want industry to do it and to set up the broad umbrella of it. I know industry would rather have some fee that that's consumer-funded. It's not industry-funded, so that's part of the negotiations that take place on any different product. So to step back, again, we work on over 20 different products. And there's a recipe for this. It's not that for every product, like packaging, we have to reinvent the wheel. We're going to use the same elements and same process that we have for paint, thermostats, lamps, electronics. A lot of the other systems, it's just modified. So we have to say that. So the key elements of EPR programs have the legislation, which levels the playing field, producers being responsible for financing and often managing programs. You have that stewardship organization that brings efficiency, and frankly governments would rather have one stewardship organization rather than 300 plans from all the different producers. It's better for everybody. The performance goals you need to figure out whether the program's working and how to define that with convenience standards and performance goals and then government oversight. So those are some of the main ones. But there's 20 of them that we have for every single element. And we've developed a model for all these different elements for packaging. So that's what we've developed it. We're going through it with each of the states. And it goes through, but what are the scope of products do you want? Do you want just those insulting to the residential area? Do you want commercial? Do you want institutional? And there's variations. So we've gone through and we've come up with what our brain trust of government officials all over the country have said is kind of the sweet spot. And then there's other things to consider. And so we're going through that with various states right now. So there's a recipe here. And we've used this for developing other models. The next slide is just showing that these systems are complementary. One does not have to take over another. EPR is the centerpiece. It's by no means the only thing. There's other things around it like the volatile pay as you throw programs, recycle content standards, bag bans, fees, even voluntary programs. They all have a role in a way to manage packaging here in Vermont and the United States. One thing on the bottle bills, it is the third rail, if you will, in many discussions. And I think it's important to have it in this discussion. That many states are saying, well, we have our bottle bill. We like our bottle bill. So we're going to look at the EPR system and define what they call covered materials. What's covered under the EPR program, we're not going to have the bottle bill materials included in that, meaning the bottle bill can be separate, complementary to the EPR program. Now, the complication, I don't want to go into it too much. It's like, well, if you have that, then there's going to be some of the bottle bill materials get into the EPR system. And so there needs to be a flow of funds back and forth. And there's calculations in British Columbia does it one way, Kim knows it all the stuff well. British Columbia does it one way. Quebec does it another way. This is all negotiated out. There's a way to make it fair there, but the systems coexist. And they coexist all over the world. And just in context in Quebec, the total proportion of bottle bill material that comes at the recycling sorting centers is very small. It's 1.4%. So it's an important guess, but let's put it into context. Another thing to point out is that there's various roles. We call this producer responsibility. I think in one way, we called it that because producers had not taken or had been given or required to take responsibility. So it's been the focus on them. I didn't call our organization the Producer Responsibility Institute. It's the Product Stewardship Institute. It's broader because there's roles everyone has. The state government has oversight. You have recycling policies, sometimes funding. You have local governments with mandates, education. You have the consumer that can do pay if you throw or has to really bring the products. So everyone has that responsibility. These systems, these roles are articulated well or should be in a U.P.S. system. So I'm near the end here. And so governments are considering various things. Some are just looking at the status quo. And I think we always have to think about that. Voluntary could lead to dropping programs, dropping materials from the program, or more government investment. More government says, oh, I've got to pay more. No one likes it, but they don't want to disappoint their residents. So they're going to find the emergency funding and stick it in to keep the recycling program. Some are doing that. But California's, Kathy, covered all packaging, recyclable or compostable by 2030. That was in the bill. Come back again, 75% reduction of single-use packaging by 2030. Washington went the route this past year of the study bill, which they're now starting to implement, which Kathy mentioned. She mentioned Resolve here in Maine in 2019. And they're looking to pass a bill in 2020. So they're going through that. So those are some things. We are working with a lot of other states. And for years, we've brought all these states together to, again, that brain trust of state and local government. These are all our members, many board members. She mentioned Kathy, Jan, board members of our organization. Doesn't mean that we agree on everything. We work on things together. But we have members and board members from all these different states. So that we could share information and try to get to some models that the industry might want to consider as well. So you can't come to the industry with some ideas if there's 12 different voices or 50 different voices talking. That's why we started our organization to have the coordinated voice and the discussion. It helps the industry as well as it does the government agency. So there's activity in all these different states, particularly in the top four or five, Oregon, New York, we're very active in the end of Massachusetts, less so as well. But there's other states considering this, of course. We're working on federal legislation. Senator Udall and Representative Lowenthal staff have asked us to help them in crafting a federal bill, which we've been doing. And so that's a comprehensive proposal that has EPR as the centerpiece. We didn't put all these elements in. They came with some ideas, a national bottle bill, bagged in and fee, single-use plastics. We're doing this as much to protect our members in the states because some of them say, hey, we don't want to lose that bottle bill money, as it is to try to get something that's reasonable that would be reflected at the state level too. So there's consistency in a federal approach and a state approach as well. Last, I did, I don't know if we got out, but I have a chapter in this book. I make no money off this at all, but it might be useful. This is Tom Zaki's book. He's from Pericycle. There's a section here. It's like six pages. On the future of packaging, it's EPR and packaging. And there's a link there if you want to get it. And that's it. Thank you very much. I'm feeling I can't have any questions for myself. Just got a question on your last slide. You went to earlier about the constant utilization but the ECO fee. How many of those does the industry manage the program versus reimbursement in terms of that in terms of Columbia and backtrack model? So where there's EPR programs, so let's see. That would be industry programs. Pesticides is one that actually should, pesticide containers is the industry. Those are industry, those are all industry run programs on the left-hand side here. And the right-hand side. The right-hand side is also industry run programs. Yes. Pesticide fees, as you know here, is government run, but has a fee on the pesticide. So industry funded partially. I agree. Well, thank you very much once again. It was very helpful. Thank you very much for having me here. I think we might have more questions. Yeah, if you have any questions, I'll make one. So back, back to work again. Yeah, here we go. So can you keep educating us on EPR? Certainly, I've tried everything about going third. It's a lot of it's been said. So this is how we were capping and stuff. Talked about but also John Eddie and the person. Just to reiterate, the municipalities are required by state statute to ensure that solid waste is being properly and there's jurisdiction. And many of them have joined together as solid waste management entities or swindlers. And there's a few yellow spots on the map that are independent towns that are going not bad upon and satisfy the solid waste implementation plan requirements. And part of that, those requirements are to ensure that there are collection systems available for waste that is banned from land disposal. And mandatory recyclables are a subset of the single-use products that has been defined for this working group. So I'll be talking about how EPR might impact these municipalities. So just to review the collection system that we have in place, it's for a single-use product or mandatory recyclables are done two primary ways. One is by curbside collection and the other is a drop-off collection. Curbside collection is generally speaking a contract between the individual, the business, or the resident with the holler. And drop-off collection is where municipalities will provide a drop-off spot for mandatory recyclables. But it's also done by the private sector. So remember that Act 148 requires any transfer stations that collect trash to also collect mandatory recyclables. So those transfer stations, whether it's private sector or municipally run, must collect those recyclables. And up till recently, was not able to charge for the recyclables that were collected. And that has changed. So there are a few municipalities that do provide collection for the entire town that they're oversee to their tech space. And those are listed here. But that's an anomaly. And Vermont is different in that a lot of states in the United States are like these municipalities. They collect the money in taxes, and they ensure that trash and recycling is picked up at the court. So Vermont's kind of different in this respect. Once those recyclables are collected, they generally go to two of the largest mercs, the single-stream mercs in the state, the only single-stream mercs in the state, one's owned by CSWD, one's owned by Casella. But some of those source-separated drop-off sites, whether they're privately operated or publicly operated, market their own materials. So the Northeast Kingdom, for example, markets their materials that they collect because they're source-separated by the users coming in. They're separating all the recyclables out. And it's a commodity for the Northeast Kingdom's market from that point. But generally speaking, a good portion of the materials goes to the two single-stream mercs. Two fees of those mercs are currently $65 a ton at CSWD and over $100 a ton, I believe, in Rotland at Casella's Merc. So if you're looking at EPR options for single-use products and how that might impact these collection systems, and Scott had some slides for the different systems in Canada, and this is pretty much the British Columbia system, what it might look like in Vermont. So one option would be that we would contract with a stewardship organization to compensate for the collection and the processing of the recyclables. Or we might give up that control and allow the producer responsibility organization to act on behalf and collect those materials under a separate contract, maybe with a separate entity. Or we would just continue to collect the material on our own outside of the stewardship program. But that's really depending on how the legislation is written and whether there is that options available. I would say given our system and how they're different entities that are managing these systems, both the private and the public sector, you would want that flexibility. Are all three of those currently in play in Vermont for the consistent EPR programs we already have? Yes, I would say what I'm trying to think. So paint, for example, the solid waste framing entities have the option of they don't have to collect the paint, but they can collect the paint. And if they do, they can get reimbursed from the producer responsibility organization, Pain Care. I can't, and there are retailers that collect also on behalf of the producer responsibility, so I think it would reflect this model. More on that, how specifically on the paint, I understand that the paint in our area gets turned into new paint, if you will. And how does that cost net it out when they're reimbursed by the manufacturer? Yeah, so that's a great question. And one that I really want to touch on when we talk about costs. So this is a little bit of a contentious issue with the paint program and the entities that collect the paint, the solid waste management districts, and not so much the retailers, because they want to do it, they want to protect, to drive traffic to restore it. But paint care and the law doesn't require paint care to pay for collection costs. So in the paint model, what happens in general is the solid waste planning entity will do a collection event or collect paint at their programs. And they will get the disposal or the recycling, transportation disposal for paint taken care of by paint care. In the situation where CSWD takes the paint and we remanufacture it, paint care pays us to do that. They actually pay us to process that paint. So we are getting our full costs covered or most of our costs covered to do that for them. Thank you. So there's a third, there's another way that recyclables are collected and by municipalities and that's the public space recycling that were required to provide if municipalities provide a trash container in a public space like a downtown or a park. They're also required to provide a recycling container next to that recycling, next to the trash container. So in an EPR system, I would expect because this is mandated by law that wherever there's trash collection and recycling collection, I would expect that the law would require the stewardship organization to also pay for these other collection systems. What do you mean that there would be a third collection that would support paying for the collection system in public spaces? But it wouldn't be an additional system and an additional receptacle. Correct. It's just the trash container next to the trash container that was recycling, I would anticipate would be part of the EPR program. I think that's another way that municipalities are collecting recyclables and it's a fairly significant cost for municipalities that provide that container in their public spaces to manage it. So another area that solid waste planning entities and municipalities have to meet the requirements that the solid waste implementation plan is through education about recycling. And so we're required to educate school businesses, residents, year-round multi-media campaigns and that is at a significant cost. With an EPR system, EPR programs typically have education requirements built into those laws and the result is a more uniform education that would be provided statewide that would potentially be easier for the consumer to handle less confusion and possibly more participation in programs less recycling contamination. So just as an aside, CSO needs to be graduated just under a million dollars this past fiscal year for our outreach and communications department. So it's pretty significant. We don't just print ads and produce brochures or in the schools or in businesses or real hands-on helping our community recycle. So these are the potential impacts that I came up with for municipalities if there were an EPR system implemented in the month for packaging. There's a lot of potential outcomes and it really depends on how the legislation is written. But definitely municipalities would see a decrease or possibly an elimination of costs for collection. So as I said, we're required to have collection for recycling at drop off sites for trash and that is something that a lot of municipalities cover through the trash fees. So this would offset those costs for municipalities if there was a high convenience standard and recovery requirements, there would potentially be additional curbside collection, additional drop off infrastructure. There'd be, as I said, statewide education. Curbside collection would likely be consolidated and more efficient than subscription service. The downside of that is the individual wouldn't be able to choose their color necessarily. So that would be something to consider. And there would potentially be more collection opportunities for materials that aren't collected in the traditional recycling system like copy pods or film, that would be another material that the producers would potentially be trying to capture elsewhere. There is the risk of the standard public investment within the EPR system, particularly where the marks are involved. So we would want some kind of insurance through the legislation that that would be utilized in the system and not become stranded. Could you elaborate on that? Yeah, so in some of our EPR laws, we require utilization of the existing infrastructure. But if that existing infrastructure wants to participate, so to speak. So, for example, with the paint EPR program, there was the requirement was in the law that said if a municipality wants to collect paint, you must allow them into the producer program, right? So if we're running household hazardous waste events and we capture paint, then we're allowed to participate in the EPR program and the producers have to pay for that paint. So with the MRF, I can see it as being a requirement to utilize the existing infrastructure, the MRFs. If the MRFs, I can and want to accept that material. And it would be obviously a business we deal with the mark and in negotiation on costs and what would be paid. Yeah, for the standard infrastructure utilization question, would you see performance requirements? Obviously, the infrastructure is created. We want it to be efficient to meet performance requirements except for materials, those types of things. Would you see that as part of it? As long as it is funded, yeah. I mean, if you got to put in a whole new piece of equipment to capture laminated pouches or something like that, that would be something that MRFs could stand up and be able to do on their own, necessarily. I just wanted to see if that's been done, because obviously paints, you take it to process it, but with packaging, there are much different materials and there would need to be performance benchmarks for them or be mandated to use certain infrastructure. So I want to talk briefly about the goals of an EPR system for single use packaging. And again, Scott did go through some of these, some of mine are redundant, some we have that I didn't have. But these are kind of, the first two are kind of the pillars behind EPR programs, right? They generally get financial ready for municipalities and they aim to recover more material. Those are generally the primary goals and I think that could be accomplished through EPR for packaging. Another goal of EPR is to encourage producers to minimize packaging and design it for the public and recyclability to talk about the modulating of these. And there's a fourth goal that's just being talked about, just the conversations are just starting between public officials and producers about overall environmental impacts and looking at packaging in that light and looking at the entire life cycle of the production and the use of packaging and not just the end of life management. So when you're looking for, looking at the circular economy or design for end of life, that's really a subset of the whole impact of a package, packaging and products, right? So there's mining of the material to the packaging, there's manufacturing, there's the user that are getting into the producer to use the package and then it gets to the consumer somehow and there's greenhouse gas emissions and other environmental impacts all along the way through that whole life cycle analysis and when you get to the consumer and then when you get it to the consumer, the consumer's interaction with packaging is really just what do I do with this? And on one hand, the consumer thinks if I can't recycle it, then this is a bad package, if I can recycle it, it's good or it's good for the environment. And that's not necessarily true because some packaging that you can recycle might have a greater environmental impact than the packaging that you can't recycle if you look at the whole life cycle analysis and that's something that I think this group should just be considering when we're thinking about policy for packaging because what we don't want to do is just encourage packaging to be used that's just recyclable because that's not necessarily the best thing for the environment. And I'll give you an example. Here you have three different ways you can purchase a container, right? One's in a steel can, one's in a plastic container, one's in a plastic flexible pouch. And when you look at the life cycle of those three types of packaging, the energy consumption and CO2 emissions or the steel can and the plastic container are higher than the flexible pouch, which is not favorable. However, the flexible pouch is not recyclable. So in the end, if you're really looking at the best choice from an environmental perspective, it's probably the flexible pouch versus the other two containers. You know, that one's not recyclable. And in an ideal world, you'd get the flexible pouch and that'd be recyclable too. And I think that's what we're all aiming for. And I know Representative McCuller, you have Vermont Coffee Company and that's probably better than all three because it's a paper bag with just a plastic bag inside of it, but this is just to demonstrate that example I think it does it well when you start to think about all the packaging that's being introduced now versus what was out there 10 years. There's laminates and pouches and all kinds of materials that aren't recyclables. But if you think about, you know, whether how it's protecting the product or the whole life cycle of that package versus just what do you do with it in the end, you might find that a lot of those are applicable from an environmental standpoint. And I think that's really important to look at. Here's another scenario that's just a little bit different than looking at the life cycle of the package itself, but it's more about protecting the product. So this is one that irks so many people, including myself, it's like, why do I have to have a plastic piece of plastic on my cucumber when I buy it? And the reason why is that it really extends the shelf life of that cucumber pretty significantly. And when you look at the greenhouse gas emissions of this product, most of the environmental impact has occurred in agriculture, in growing it and getting it to the grocery store. The thin piece of plastic has a very low environmental impact and you don't want to waste what's been put into this product in terms of energy. So that's why you have the piece of plastic. By the way, there's a edible coating that's being developed that would potentially someday replace this plastic that I have on my cucumber. And you're not supposed to eat that. No. Yeah. So again, I'm thinking about policy. These are the different packaging attributes to encourage in an EPR system. Recycle content is generally a very positive attribute to require reusable, obviously recyclable recyclable and recoverable is oftentimes preferable. But sometimes when you're looking at the overall greenhouse gas emissions and recyclable, it's not the better choice. And biobased and compostable, that has a whole another whole other issues involved with that as well from lack of collection infrastructure and other issues that we could delve into as well. So in summary, I think EPR single use products legislation in order for it to be successful legislation should have a high level of convenience and access for recycling. It shouldn't need a good deal of statewide education. All collection costs should be covered. You don't want to get stuck in where we are with the paint program. I think it's a great program, but there's a lot of collections programs that have a difficult time covering all the costs of collection and paint. I think there should be municipal choice and participation as well as the private sector should also be able to choose whether or not they want to participate in the program. There should be a requirement that existing infrastructure is utilized and again, we should really look at those modulating fees and overall environmental impact to encourage design for the environment and not just design for recyclability because that's really missing a mark. Any questions for Jane? Jane, municipal choice. You are promoting a municipal choice. Could you talk about that some more? Is that like this municipality shouldn't be required to have EPR or are you talking about the multi-layered system whether or not, such as the Quebec family? So what I'm talking about is that if you look at, say, the drop off site collection programs and some of them are municipal-aeron, some are private sector runs those programs, some of them are getting material coming in from consumers that are sourced separately and so they end up with a bit of aluminum and they might want to market that on their own and they might market all of their materials on them and that's worked for them. They're covering their costs, maybe they're covering their costs and then some, I think in today's market it's probably stretched to say they're covering their costs but I think that if they want to continue to do that then they should be able to do that and not participate in the stewardship program. So the stewards will not pay them, contract them, reimburse them for their collection, they just keep going on their own. And the same for the private sector and there's a lot of transfer stations running by the private sector that might want to continue to do that. But that's not to say that the product won't be managed. Right. How? Yeah, again, just to remind you of the statue we have to use this material, right? So there has to be, if we want to collect trash we have to put recyclables and it can't go to the landfill. Thank you. Thank you. Good afternoon. Good afternoon. Thank you, Mr. Chairman and members of the working group. Not the committee, I guess, right? For the record, my name is Paul Burns. I'm the executive director of the Vermont Public Interest Research Group, or VEPIRD. And my organization has a long history of working on solid waste matters. We were founded in 1972 and have spent a great deal of that time working to find ways to reduce waste, to encourage reuse and recycling as well. And we've supported many of the programs that have already been talked about here, some of the legislation that has been addressed, including the law that actually gave rise to this working group. So it's a pleasure to be here before you today on this topic. Now let me see, how do I get from Jen and Paul Burns, I appreciate the technology assist. That's not a problem, you are, right? And then we'll just use that. Great, thank you. Jen noted, coming at this stage, you've heard a lot of details. I wanted to note that as a follow-up to the passage of the legislation, which as you know, was the strongest legislation in the country dealing with single use plastics passed earlier this year. VEPIRD and our outreach staff went door to door throughout the state talking about continued issues related to single use plastic and single use products marked more broadly. Our canvassers went door to door and they went to every single community in Vermont. We are certainly the only organization that has the capacity to reach out, have direct face-to-face conversations with people at their homes and every community in the state. And this summer the topic was on single use plastics and single use products. I'm not gonna talk too much about some of the details there, you're familiar, I think, with the Pacific Garage Patch, equal to 64 Vermont's in size. And more, that's kind of hard for people to get their heads around. It is massive and it is a problem that is growing. This graphic here is one that again, many of you have heard about if you saw the National Geographic Magazine issue devoted to plastics from June of 2018, you may have seen a similar graphic there. This is where we got the data from the same raw material and research. But half what this graphic shows and half of all plastic ever produced was made in the last 15 years. What that means is that as bad as the problem is today of single use plastic pollution out there, it is getting way worse every single year, almost every single day. There's that much more plastic being created. And so there's no kind of end in sight where we would see that leveling off anytime soon. There's more and more products being made of plastic, more and more packaging being made as well with plastic. And about half of that total plastic is packaging material. So again, we're seeing this as an increasing problem. Not too much of the plastic has been, is being recycled now over since plastic was created. Only about 9% of the plastic has been recycled. Certain programs do better for sure. So when we talk about our campaign to address this problem, we invited people across the state to sign on to a petition. What would you like to see done about this? These were the conversations we were having. And this is the petition that we invited people to support. And I wanna just note that we were pretty successful with that petition. I will leave you one copy of this. Sorry, Mike, I'm not gonna ask you to make a copy of all this. This is more than 20,000 signatures from Vermonters, from communities across the state who supported the language of this petition that you see up on the screen. It's not terribly specific. This is more an indication that I think, broadly speaking, Vermonters recognizes as an ongoing problem and they want to see your continued focus on it. So again, mostly to say thanks. Thanks for being here. I'm pleased that this working group itself is part of the legislation. And you'll see a lot of support in the communities around the state for what you're doing. You've already made some progress here. So congratulations, you can check off pretty much the first item there because when we started going door to door, that had not yet been passed or signed into law. So well done. There is more to do. And I would say that from VPIRB's perspective, what the focus of the working group is on, there are a number of different aspects of this. And we see, for instance, the need to ban other items just as the law that you passed, to ban certain items that I think we can be phasing out other things, whether it's plastic balloons or the release of plastic balloons with helium glitters. Maybe it's just a personal thing for me, but I think a little bit of plastic that we use for no particular purpose. Some are a couple of Vermonters who don't appreciate the work I do, I guess, and send me envelopes filled with glitter. Or maybe it's just a fair way of suggesting we should get rid of this stuff. I guess maybe that would be a more positive way of thinking about it. But there are problems with a lot of things. Your committees both talked a little bit about plastic utensils and things of that sort as well. So there are all sorts of ways that we can be involved in going further here. Today's focus of your working group is on EPR, so that's where I want to focus in as well. I'm not going to go into the definition again. I'll just note that there is this excellent report. Scott Cassell mentioned the OECD, the Organization for Economic Cooperation and Development. And they, I've given you a link or given Michael a link to this. If you're interested, this is just an eight page report. It kind of summarizes some of the information that Scott Cassell already noted, that where about small consumer electronics equipment accounts for about one third of all of the EPR programs worldwide, and now I think the status, it's about 400 of what they consider to be genuine EPR programs worldwide, a third of those are small electronics. But the packaging does come in at about second place or tied with tires, if you consider tires as part of the EPR program. So that's about 17 or 18% of all of the EPR programs deal with packaging. So there are examples out there. And so this is an excellent little report and you'll have got at least the connection to that. So I wanted to kind of focus in on one aspect of this because the EPR programs are being considered and passed and adopted in an environment where citizens are putting more and more pressure, honestly, on companies that are creating this material, this packaging materials for large extent. People are seeing it, it's something that we find this is not a partisan issue, across the political spectrum, people are seeing that after each trip to the store, they come home with a lot of stuff that is of no value to them and they've got to find a way to get rid of it. And so it had a useful life of minutes and now it's gonna be around for 500 years or more. But consider Coca-Cola. Coca-Cola, of course, they own Dasani, they own all sorts of beverages, it's not just literally Coca-Cola in their bottles that they put out, and I don't have the statistic here in front of me, but it's many, many millions or billions of containers filled with Coke or water. Sometimes people say that they're a plastic packaging company that puts water in things, they're not a water, they don't make the water. So there's a lot of pressure being put on them. Coca-Cola in that environment has started to say, well, we're gonna do something about this voluntarily. In Australia, they have said, they have committed to making that 70%, they say that 70% of their bottles will be made from 100% recycled PET by 2019. And that's what this article talks about. From earlier this year, this is the press release the top item there, talks about that pretty bold fledging commitment regarding what Coke's gonna do in Australia. In the US and in Europe, Coca-Cola has committed to 50% recycled content by 2030. Again, this article was from 2018. I don't know that that's changed. I think as far as I know, that's still an accurate figure so that they are not gonna go as far but Coke is still committed to making some progress here. So that's a good thing. The problem is that Coke can't possibly meet these pledges or commitments because we don't have enough recycled content right now. Recycled PET plastic. So Plastics News, for instance, had this article from earlier this year, 2019, the big plans for recycled content, meaning that we need more PET and therefore they argued that we need more bottle bills or that's what the result will be. So if we want to achieve the kind of environmental gains major brands have been talking about for plastic bottles like Coca-Cola, in the US it will need a perculean effort and more than double its recycling rate for PET bottles. The other highlighted piece there is that demand for so many more recycled bottles to feed Coke and others will threaten to overwhelm our recycling systems and lead to much more pressure for national deposit laws. This is from Plastics News, this is not some left wing viral publication, although I think they know they're speaking the truth here, NAPCOR, which is the National Association of Plastics Recyclers has also said that we will need more recycled PET to meet the demands that are out there. So that's kind of the state of the situation today is that there isn't enough of the recycled material. They need more recycled content in order to meet these demands and as consumers press for higher and higher amounts of recycled content in the containers, as legislators consider requirements for more recycled content, they're gonna need to get it from some place and that's where we would argue the bottle bill comes in and Coca-Cola, at least in Europe and elsewhere seems to agree, Coca-Cola here says that the bottle return scheme, they don't mean scheme in a negative sense if you're familiar with the way British use the term scheme, I think they really mean system, but there you go, their system is a once in a generation opportunity, that's what the Coca-Cola representatives say in Europe. I will say that that has not been Coke's position here in the United States of America or in North America at least, they have a separate decision-making body and they have not been as receptive to an expanded bottle bill in this country, so that's worth noting. We believe, though, that the bottle bill program is one that is appropriate for your consideration today as a kind of EPR. There are a lot of reasons why we should be thinking about modernizing the bottle bill that was also created in 1972. Number one, it's a great follow-up to the plastics legislation that you passed earlier this year, all of those water bottles and other plastic containers that attend beverages many of those are getting out into our environment today and Vermont could consider a ban on plastic water bottles. That could be another area of consideration for this working group, but my expectation is that you will not, within the next year, ban all plastic water bottles in the state. There are some communities and municipalities around the country that have decided to ban certain of those water bottles. You might say that we don't really need it for the eight ounce water bottles. That's a policy question. But as long as we are generating plastic water bottles and selling these plastic water bottles, VPR's position is that we should do all we can to prevent them from getting out into the environment. That is, we should recycle, collect them and recycle as many of those as we can. And if you recycle them in a clean way and there's much less contamination through the bottle redemption program, then that plastic that you gather from a bottle bill program can be turned into new plastic bottles. So that Coke has some hope of achieving and meeting its pledge that it put out there for recycled content in the US and more broadly. So that's kind of the goal for the plastics piece. The second reason is it's a way of dealing with some of the harder to recycle items like glass. We've seen glass in the news lately. Glass doesn't always find its way to highest level recycling and being turned into other glass products. And so it's appropriate to think of ways to increase the odds that glass can be recycled either into new glass bottles or into fiberglass or things like that. That's higher level recycling. We would prefer that than even downcycling, which is using it in road construction material or the like. But certainly glass that comes to the bottle bill program is also less contaminated and has a higher value and is more likely to be turned into a glass bottle again. So another reason to support it. And then finally, just after 47 years, there are other reasons why we should consider updating or modernizing the bottle bill. One example of that is that the deposit is still a nickel. It was a nickel in 1972. It's a nickel today. If it had kept pace with inflation, it would be worth, Mr. Chairman, you may know what I think it's more than 30 cents today. 32. 32 cents today that if it kept pace with inflation. So there are a lot of reasons why you should consider it. Is the bottle bill EPR? I don't want to get too hung up on definitions here, but it's a consumer product system that has spurred green design. It has established a take back model and it's increased recycling. It's paid for by the producers of the packaging material. So at Beeper, we absolutely think that the bottle bill is an example of extended producer responsibility. Thomas Lindquist, who is a Swedish professor of environmental economics, coined the term extended producer responsibility more than two decades ago. He classifies the deposit return system as EPR, devoted an entire chapter in his doctoral thesis to it, as a matter of fact. The OECD considers it EPR, the National Recycling Coalition, the National Container Recycling Institute, and we all consider the bottle bill programs to be EPR. So I think it fits in today's conversation. If you were to add, for instance, modernize the bottle bill in Vermont by extending it to cover water bottles, wine bottles, and sports drinks, you would dramatically increase the number of containers that could be recycled under that system in this state. So for instance, just with the water bottles alone, that's about 175 million containers, 175 million additional containers each year in Vermont, 175 million. Under the current bottle program, there are about 326 million containers covered by the program as it exists today. If you added sports drinks, you would get another 8.3 million containers. If you added wine, which is mostly glass bottles, you'd get almost 18 million more. So that's more than 200 million additional containers that would come under the system if you modernize the bottle bill by expanding its scope. If you increase the deposit, we would think that you would do that for all containers to at least a dime, but you might consider a modulated fee system or you might consider Vermont's current system to already be modulated because liquor bottles are at 15 cents today. I presume that's because they are bigger bottles, but I'm actually not sort of the rationale for that, but so it's at least a two-tiered system. You might consider that a modulated system. It might make sense to continue that path if we were to add wine bottles to the system, for instance, so that the wine bottles would be 15 cents. So that's something to consider there. We believe that the bottle bill can also work well, work effectively with curbside recycling programs. That is the way it exists in a number of other states and a number of other provinces and other areas around the country and around the world. In this small way, I guess I take a little issue with what Catherine Davidson said, where she mentioned that we've got two separate programs or parallel programs, one for bottle bill, one for everything else. But the fact is we've got multiple systems right now for all of the other programs that we have that are EPR programs. Each one of those has its own different means of collecting back the material, whether it's for light bulbs or thermostats or what have you. So I think we've got multiple today and I think they each work really well, including the bottle bill. The challenges right now are mostly with our recycling program and the curbside single stream recycling, which ends up when you throw a lot of these materials in together, you necessarily have a higher degree of contamination. Glass and paper and these systems together can be kind of moral enemies and that means that all of it is worth a little bit less. I'm not presenting the answer to that particular problem to you today, but it is something that should be considered is whether the existing single stream recycling program is one that can allow us to be as successful as we really want to be at making sure that those items that people beautifully put into their blue bins are actually being recycled and turned into products again. But as for whether recycling, curbside recycling, the bottle bill can work well together. I will submit for your consideration to give you again a link to this overall report done by Unomia looking at the Ontario system. Ontario has, as far as I know, North America's oldest curbside recycling program and they are now considering expanding their bottle bill program to include non-alcoholic items and this is a rather in-depth report and analysis that looks at how these two would work together and concludes that the two programs would work very effectively together and that is an issue that we would have to grapple with here. What would be the impact on the solid waste districts, for instance, if you were to take the PET plastic bottles out of the system and recycle them through the bottle bill program whether you took the glass out and so forth and they're obviously pros and cons. But I'll just read two sentences from their executive summary. They note that there are more than 10,000 tons of plastic end up in the Great Lakes every year breaking down into microscopic pieces. You're familiar with the health risks and other problems there. It's estimated that beverage containers account for approximately 40% of litter by volume and according to a 2016 Toronto litter bot at PET beverage bottles alone accounted for 15.4% by weight of all the large recyclable litter surveyed by the city. It's just an indication that plastic bottles are a not an insignificant problem when we're certainly talking about waste and litter and the problem of single use products. So I encourage you to consider carefully this question of whether we can expand upon, build upon the successful program that we've already had in place for 47 years so that it is even more successful at collecting more items, perhaps 40% more containers and turning them into new recycled products. And indeed, if we have any hope of achieving a circular economy, which we've also talked some about, you need to find ways of getting material back into that circular system and the bottle bill because it has cleaner material can be used, and this is the plastics industry folks saying, can be used much more readily than other kinds of plastics who curbside programs to make a new PET bottle for instance. So that's why we encourage you to consider updating and modernizing the bottle bill. That's one of the items, one of the to-do items for this working group. We are supportive of some of the other testimony that you've heard looking at other kinds of plastic packaging, perhaps modulated feeds. I would note that Ontario, you will see this in this report, that is one of those places where they charge manufacturers of the material to pay for the curbside recycling programs. I think it's 50% on its way to 100% if I remember it correctly. So with more of that information in the report. Since the liquor is distributed through state stores, is there data that shows the percentage of bottles that are returned liquor specifically because that's at the 15th and 7th bottle? Our estimates working with Container Recycling Institute are really kind of the national experts on this, is that about 84% of the liquor bottles are recycled. Our brought back for redemption I should say, if they're brought back for redemption, nearly universally you're seeing those containers being recycled into something else. For the non-licker bottles of beer and soda, I go by the figure that was contained in the 2013 DEC report, which is about a 75% redemption rate. DEC has national research. In Vermont. Yeah, in that same report, had a 74 to 75% return rate for liquor as well. I can help people with that. The data that we have for liquor is more recent than that for going off the sales data this year. I should be happy to talk about this somewhere. No, this is Vermont. Let's be happy to talk about it. What are the questions for? Paul, I've heard that the redemption centers are pretty challenged with the current system that we have with sortation of all the different brands that are in the condo system, like there's over a hundred sorts for those redemption centers. How would you see, do you get a sense of where the redemption centers are at with an expansion proposal and how do you see that being able to be supported by the infrastructure that we have? One, I cannot speak, wouldn't suggest that I'm speaking on behalf of all the redemption centers out there. In fact, there are a number of them and then they might have their own opinions about this. So it's worth looking at, and there is no one association that does a terrific job of trying to figure out what the position of the redemption center is. So all of that by context. We've certainly been working with several redemption center owners as we talk about some of these next steps. They are supportive. They think that we could move forward with this kind of a modernization or expansion to the scope of the program effectively. We know that a number of states have gone beyond what Vermont currently has in their systems and they seem to be working reasonably well. Just around us, for instance, New York and Connecticut added water bottles. It was probably almost 10 years ago now when they decided to have the state begin collecting the unclaimed deposits. And Maine has more materials than that. So I think they have examples of where it has been done. I think we could provide you with testimony from redemption center owners here if the committee would be interested in hearing from them. Which again, is not necessarily saying that's the way all of the field, but it would probably be useful to hear from someone about how they might grapple with any kind of expansion like that. But the other thing is, we have a bit of an antiquated system with the way of how they deal with it and trying to separate each one out. It's really from a recycling perspective. You just wanna separate them out so that the material, the color, the glass is the same so that it can be more easily recycled, but it's an accounting process really that requires the separating things out. And it may be, we believe that technology exists that could allow for more of the co-mingling and Tamara is the reverse vending machine owner, for instance, that my understanding is they may have some technology that could assist so that what the system we have now may be improved upon to so that there would be less of that separation, less of that kind of separating burden placed on the redemption center owners. We'd be very interested in looking at that, too. Any other questions? Well, I have, as you're well aware, supported significant expansion on the bottom of the years. I am becoming more and more concerned, especially, I guess, in today's, in today's atmosphere of recycling about the harm, the economic harm to the solid waste districts is to take off a significant amount of the E.T. out of their system. So are you aware of that being a problem in other states or countries and how that's been spoken to or is being considered to be spoken to? This analysis for Ontario I was looking at exactly that question, for instance. Where, how would the finances be affected if you were to take away from the municipal systems, effectively the aluminum, those things of value, aluminum and, to a lesser extent, P.E.T., but also taking more glass, which is a financial logistical hurdle for those same municipalities or municipal systems? So there are some pros and cons there, but then you also look at other financial advantages that come from recycling more and perhaps reducing curbside pickup programs or so forth. I mean, if you can do enough to get more materials into a bottle bill redemption program, there are other cost advantages. That's what this analysis is fine. So I'd be happy to try to pull some of that out for you, but I think if you, we've given Mike the link to the full report. Again, it was 150 pages or so. I wasn't gonna have copies for everybody in the interest of trees, but we could pull out some of those specific citations and analysis that might be helpful to you. I think the other thing to consider is that if you were to expand the program and if you were to raise the deposit to a dime, you would be increasing the amount of unclaimed deposit monies that will be coming to the state. There's a question about what happens to that money then. Right now, it is, it goes to, we'll begin going to clean water programs in two weeks, I guess, it takes effect on October 1st. Or in the state, we'll get its first revenue in January of next year. But it might be appropriate to look at using some of that revenue to the extent that there is a financial disadvantage to any of those municipal or regional recycling systems there. Let's look at how we can make that work. I think that's a conversation that we should be having. But there really is no question if you're looking at it from a resource perspective that more material will be collected for recycling. It will be a higher quality material. It will be turned into higher quality recycle items later if you do it through the bottle bill as opposed to the current system of curbside recycling where fewer of the containers ever get put into the blue bins and fewer still are of a quality that can be used for recycling. You know, a bunch of, some of that material is going to a landfill. Some of it is just not of a quality that can be used in the same way that a bottle bill material can. Just building on that point, what we've been hearing from the earlier presenters today, I would hope we could be looking at how are we getting the producers to be paying for the system so that we're not hamstrung in what are the challenging finances that our municipalities and solid waste management entities are in, let's be shifting that burden so that we can be looking at what's the highest and best way to recycle as much as possible, not recycle less through the blue bin system because we have to kind of prop up that I would hope we'd be looking at more of a bigger picture approach to the finances. Thank you very much. Thank you very much. Good afternoon. Good afternoon. Thank you for coming in. Thank you for the invitation. Good afternoon, Chairman Bray and Representative McCullough, members of the work here. My name is Sarah Thane Pierce. I'm the director of government relations for the Association of Home Appliance Manufacturers. I don't know if I feel like I'm taking a hard right turn or if I'm just thrusting us out of this whole discussion on EPR but we're gonna talk a little more practically about how my industry uses packaging and plastics and so have some things that I wanna share with you today and I'm really excited to let you know that this is Hadoca Press' brand new information from my industry, Vermont. This working group is the first in the country to get this information. So we're gonna look at a lot of pictures today, talk about what and how my members are using packaging and in the next month or two, I hope to, if I can't appear again, supplement this presentation because we're still doing some ongoing research and having more discussions with our members. So we'll have more to come as well. So AAM represents companies that are household names, all the trusted brands like local GE appliances and carry animals like Green Mountain but carry Dr. Pepper who is here and makes Vermont their home. These are brands that bring us home comfort, they bring us efficiencies and make our lives in general easier and if anyone has purchased an appliance recently whether it's a portable appliance or a floor care appliance or a major appliance, all of our appliances are capable today of connecting to the internet and so these products are getting a little more complicated. They can make coffee at the perfect temperature for you before you even wake in the morning to letting you know that your mouth is running low and asking if you want to have it reordered for you. So we're getting quite sophisticated in the production of these products which really brings us to the subject of this working group of plastics and packaging and how that plays a role in making sure that when US consumers place an order for an appliance whether it's a major portable or a floor care product that you're getting once you've ordered and that you get what you pay for and packaging plays a huge role in that and make sure it gets to your home safe, securely and in the condition, proper working order that you expect it to be. So when I think of a brand new kitchen I come to mind something along the lines of this maybe this isn't the case for everybody but when you choose to make that decision it's a big decision to order new appliances for your home, right? And we do go through an exhausting research process and we agonize over it. We consult our coworkers, our friends, our families perhaps we go to many retail establishments to try to choose just the perfect products for us. And finally we select those products we make those purchases, we select a delivery date and we've even gotten our four hour window for delivery right and so we're sitting there waiting maybe we're ordering some washers and dryers but we're waiting and we're waiting and we're waiting and then something like this happens where we have a refrigerator that's delivered to us and this might be an older version of my presentation but hello Aero but you can see down here in this bottom right hand corner there's a nice big giant scratch across that refrigerator. Quite disappointing as you can imagine and as any consumer you would likely make that quick snap decision to send that appliance right back with very little thought about what's gonna happen to that appliance next because there's perhaps an assumption that this appliance is gonna go back onto a retail floor or it's going to do something other than what is potentially likely that this will go to scrap and that's a brand by brand decision but think about that in the context of not how this product was packaged to get into your home but what that environmental footprint will do with that one snap decision which is given very little thought and I would not think that any of us might do anything otherwise but it's something that's a reality that happens and so when we're talking about packaging and what we're looking at packaging is that what we want to do with our packaging is making sure from the moment this product leaves the production line that it's to contents that prevent the situation and the scenario from happening and so anything that we do it goes from your manufacturing line it goes to at least two to three warehouses it will get packed with light products it will get packed with unlike products and everything that is put around this product is to prevent a situation like this packaging is meant to absorb shock it's meant to stabilize when appliances get stacked we have ranges and refrigerators that get stacked and warehouses four to six high and so there's a stabilization element that goes into it and really assuring that we avoid any situation like this and so how we look at our packaging and before I jump into anything is this is what our current materials composition looks like for our major which would be on the left side of your screen and our portables and floor care and as you can see we are already using quite a bit of cardboard paper wood we do use EPS we do use some plastics and film plastics which I've heard mentioned a few times today very important uses for those single use products on some of our larger appliances like a refrigerator dishwashers for example here are some of the packaging materials that you're going to see that we're currently using you saw those reflected in the pie chart we have our wood pallets we have different types of cardboard as you see those little divots I guess in those cardboard it's actually called a flute and it's a fluting system to determine shock and how to best preserve a package based on its weight and so depending on how large that flute is is how much protection you'll get in shock absorption you'll get as your packaging with cardboard and of course we have the expanded polyestering there on the right hand side so those are all of our major uses for packaging that go into our products here is how we use those products that you just saw to secure appliances and so you see it's a very minimal and it was just about 6% as I showed you on that pie chart the use of EPS and other plastics into our major appliances and I'll talk about small appliances portables and floor care in a few more slides but here you're going to see that we're using these long now the name is escaping me right now but you're going to see your poles on the sides that's going to bring you structural integrity again for stacking not just in warehouses but when you get into rail and truck and then you're going to have your EPS on the corners and you're going to have your EPS also underneath those appliances and what happens with EPS and why it's so important is it's basically one of the only uses that we've found in our manufacturers have found to properly absorb shock and not shock just once and so if it's a drop, if it's a bump along a rail, a railway or a roadway it will repeatedly absorb shock and our members have done quite a bit of research to try to find and determine if there are other products that they can replace with the EPS and there are no options that will continually and repeatedly absorb shock so here's just a little bit of a look at some other plastics that we use straight versus stretch and again this is just related to really how the plastic is being used in conjunction with the cardboard or the EPS but one interesting issue for consideration is as our members, not all the brands are moving into this more of a shrink wrap situation where they're just using EPS around the corners is that there is a higher damage rate that goes along with that and so our members are also actively considering different ways to protect those products and going back to a more traditional packaging scheme as you see here on the left hand side which is more full cardboard to fully protect that box because again as I had mentioned before that environmental impact is much much greater if you're having a major appliance return to a store which then as I said most likely could go to scrap and again here's just another look at this so we have these corner posts here you see on the left hand side and now we're getting into some shots and views of how a warehousing situation is set up and the next slides we're gonna look at what stacking will look like but a lot of these pictures are just depicting how we're getting into a situation where we're determining how we're gonna place these products into warehouse and really that's gonna be the first warehouse which is the brand warehouse which is really distinguished from a major distribution center and then onto a retail warehouse and studying where you're gonna be packing these products with unlike products where that really increases the risk for damage and again having that ability to absorb that shock is incredibly important and so this is what it looks like maybe not quite as daunting as when you see this in person but you're gonna see ranges and refrigerators stacked four to six high in any warehouse one thing that you have to keep in mind warehouses don't have a whole lot of temperature or climate control and as we're developing packaging strategies one of the things that we do test to is extreme weather conditions and so we can easily imagine here in Vermont and I'm from Minnesota so we can imagine those negative 20 weather conditions in the winter but we also test to how these products will withstand high heat up to 150 degrees because there are situations where you're gonna have these products in their packaging sitting in those variant temperature conditions and again we want the integrity of those packages to hold up and withstand so that those products are arriving to the consumer's home the way they expect it to and so one of the interesting statistics that we have learned just recently is that as the percentage of humidity increases and it's just by 1% percentage point of humidity you're losing an inch of stability in a cardboard box and so when you think about that and you look at this what is that 255 range stack high think about 90% humidity and how the potential for the tip inch comes in and that's something that our members are testing to because safety obviously is a concern in warehouses and in every other aspect of our production. Moving as I have mentioned several times we use clam trucks and other types of trucks to pick up these products and either load them onto rail cars or onto semis again the design of the package will be taken into consideration how it's going to be moved from one place to another. And here's some technical challenges in the packaging design so we've talked about the extreme heat and humidity stacking movement and transportation so abrasion damages is one thing that I alluded to as we talked about the single use of plastic film think about your stainless steel refrigerator or dishwasher for example TVs we don't represent televisions but this is an application for TVs as well as you get that single sheet of film that's put over the front of your refrigerator that's to protect from scratches and abrasions like we saw earlier in that picture our members are unable to identify any other source that's going to prevent any scratches from taking place during installation during transportation and so that's really important issue to take into consideration as well is that all of our packaging is in place for a purpose and it has a purpose and so it's to prevent again scratches and damage shipping and transportation especially for small appliances is very interesting one of the more interesting issues as we've been examining these issues consumer facing versus e-commerce and you have a number of different e-commerce channels whether you're ordering from Amazon or Alibaba or you're ordering direct from the actual manufacturer a lot of my members will sell direct to consumer then you have your brick and mortar packaging and they all are different streams and a lot of retailers will have different requirements for those small packages versus e-commerce but our members are working to design across all of those spectrums and for example if you are sending something into a retail store we have to test for a potential of five to seven touches and that really needs five to seven drops and so we have to put our products into boxes that are going to withstand at least five to seven drops if it's put into a brick and mortar retail so if you recall that picture I showed you in the beginning of the flutes with the cardboard those flutes are part of what absorbs that shock as well as EPS and so consumers one thing that we also know is they do not like a lot of assembly when they're small appliances are arriving to their homes and EPS plays a role in that because EPS can hold the integrity of that appliance in place as it's moving through that system on the e-commerce side I should just mention very quickly we test for 15 to 17 drops and so it's very interesting when you're in one of these testing facilities they actually have drop machines and they actually have sequences as required by the retailer or by the e-commerce side of how a manufacturer should test the drops to make sure that that product remains intact and is still able to get into that consumer's home on damage and so I didn't originally think it would be that interesting but it's actually quite fascinating to see all the effort that goes into making sure that the integrity of these products is maintained through this process so consumer assembly went over and then just as I said there's a wide variety of standards and we're trying to again make sure that we get them all the way through that process the other aspect that is a new trend that we're seeing is a lot of these e-commerce sites are trying to get rid of that exterior box so think in your mind the last Amazon delivery that you got you had an Amazon box and you opened your box and then you had your packaging which had all of the marketing materials and whatnot and then your product was inside of that box and so there was a push by some of these e-commerce platforms to do away with that exterior box and so then think about issues like having that box left on your front stoop and any passerby can see the contents of your delivery and we've all seen all the news reports of especially at Christmas time and the holidays of those disappearing even in the Amazon box without your front porch so these are issues that we're wrestling with packaging and so just things that we're trying to keep in mind so and this just goes into and kind of tries to bring together everything that we've just talked about is the problems and the challenges with our delivery channels and so we're large products, core products, small appliances and parts are all different categories. You have your examples up there with the large products talks a lot about refrigerators, core products, laundry range, refrigerator dishwasher, small appliances, our countertop microwaves, garbage exposers and then any replacement parts and so we all have bigger each category has different issues and so our biggest concern with those large products is the last 50 feet. It's gonna be on a contracted delivery truck usually if you live in a house I live in a condo so it's a little bit different but if you live in a house they're gonna take the box and all the packaging off outside the home get that refrigerator into the house and install and so the big concern again is that last 50 feet and so we're talking about those protective films to prevent from scrapes and scratches and bumps becomes very important. The core products mechanically assisted damage and so we're talking about moving products and packing products against unlike products and any time that package is touched and moved potentially dropped there's an opportunity for something to break inside the contents of that package and so we're continually trying to work against that and small packages very same issue we talked about the drop tests and all the research and effort that goes into making sure those maintain their integrity and of course parts are easily shipped through UPS, FedEx, USPS so dropping is gonna be our biggest issue and problem right there so and just moving on so we have done a bit of research about alternatives and we're not gonna be shy about telling you a lot of these alternatives are very expensive a lot of these alternatives are not available in a great enough variety I don't wanna say variety but great enough quantity that's the right word that it's an easy switch but there are some alternatives EPS is a major challenger there's not product out there that can continually and repeatedly absorb shock and drops and everything that our members are using EPS and their products for again it's a very small percentage of what we're putting into our packaging yet very critical the second page just kind of goes into some other issues one that usually gets a nice little chuckle is the mushroom packaging which is actually a thing but it's again very cost prohibitive and doesn't stand up in weather conditions so this would not be a use for anywhere south of where I live in Virginia I would suppose so just moving on some issues that we're identifying and trying to get our arms around with plastic recycling policy across the board and I think Kathy talked about it and others have talked about it is that there's not a broad recycling infrastructure in America probably shouldn't be because every jurisdiction is different but the lack of an infrastructure makes identifying the best solution very difficult because it's definitely gonna be a case by case issue but something that we're identifying is something that really should be addressed perhaps before some of these larger bigger policy issues because we need to have something in place that can actually handle and manage that whole process lack of industry control over recyclable materials once our products leave our warehouse in every case our manufacturers have lost the ability to control that product because the consumer has made that purchase and it's very difficult for us from that kind of a supply chain perspective to control what happens to that product after the fact a lack of market for recycled plastics we've talked a lot about that already today failure to distinguish between IC&I and residential recycling and so IC&I is just business to business and how did those products get handled and our members again are doing quite a bit there as well and this is I think something that's common we look at this access to recycling programs perhaps a place to start because of one of our biggest concerns here is EPR costs a lot and it's a major cost and we aren't convinced that it is the solution and we're here at the table because we want to work with you to identify areas where we can work together to really improve the situation and as I had mentioned we're working hard with a pretty large group of our members to continue to identify areas that we can do even better but our members are working at this issue every single day and we just, we were at a company about a month ago who has a goal by 2020 at least on their major manufacturing facilities to be at zero waste and so we have lots of anecdotes and things like that that we're hearing from our producers and our attempt is to bring all of that information together to share it back so that we just believe that all of that will help you identify the best policy solutions here so I think that's my last slide so I can answer any questions that we have. Thank you. Any questions from the panel? Bad Lauren. Just, I was just curious you described a lot of kind of unique challenges just curious what like percentage is on the fly is it the waste stream of the packaging and maybe caffeinated those Oh gosh I don't actually don't know I'll have to see if we have that data but I don't think we have that data it's a lot of, it's recycled and as I had mentioned again particularly where majors are concerned if it's contracted the contractor is the one who's recycling the cardboard, the pallets any of the plastic material and then again if it's a portable or floor care that's gonna be something that the consumer does and so it's that data I mean I'll go back and check and see if we have any data like that but I mean I think it's probably shifted we've had it so. I mean just looking at your last slide on EPR I mean you're saying it's very costly it's costly to you the producer I mean we're already paying to deal with this stuff so we're paying for it it's shifting the cost onto the manufacturer or more accurately reflecting the cost of what were the full system yeah but I think the reality though is that and again and I don't wanna say this because it sounds hard and fast but the general response is I know you probably well know and not surprised that I'll say this but that's gonna get passed on to consumers and so the consumers are gonna pay one way or the other and so our interest is how do we do better like from our full value chain and so that's really what we're looking at rather than having a program like this I mean I think there are challenges with this and you know we have an office up in Canada and we're you know we wrestle with EPR issues in Canada all the time so it's just you know we wanna try to work with folks to identify the policies that make sense for everybody who's at the table. Just one point of question to the slide in terms of the administrative cost that's something that is new it would be on top of just the waste collection cost so yeah consumers are already paying and there's already a portion of solid waste that we have to manage but creating a new quasi-governmental PR organization comes with additional administrative costs registration fees, staffing, those types of things which one could argue is a role of the government a role of the state government you know that's something perhaps just to consider what's the most efficient way to collect more and recycle more because that's the goal what's the most efficient way to get there I think is what I'd look forward to next one. I'd be interested in any data Sure, for that brownie. You can send that along there for me please. This one, that's my one. You're getting, if you can grab my 421 I'll stick to the same, no less time but I just want to make sure we don't go over because we'll need 10 minutes to wrap up for the stage. Well actually I was going to say Mr. Chairman I wanted to congratulate you at the rest of the week when I'm sucking up to you but I have never, I don't know what time I was in that legislative agenda that actually stuck to the schedule as well as the stuff has to do with it. So for the record, Williams School of Associated Industries of Vermont, I appreciate the opportunity to provide some initial comments really kind of questions to ask. Certainly this is something that's going to be an ongoing conversation, I look forward to continue to participate. But UPR is a very broad policy approach it means a lot of different things to different people there's a million different ways to go about it and really how effective it is, how appropriate it is can vary widely across products and industries across jurisdictions to the size of the jurisdiction and also getting to the actual program details so addressing the specific pros and cons of how one could or should or not apply the UPR to the charge of the working group. In some ways it depends a lot on the more specifics that might, as this discussion continues to evolve and when we get more detail on the feedback. Can I ask you just a quick question for sort of like a baseline? Since we have a group DPR programs already do you have concerns about those? I mean, before we talk about extending our position what is your, does the EIV have a position on the effectiveness, appropriateness of the current EPR program? There are definitely strengths and weaknesses relative across them, I would want to detail the conversation about that, I want to go back and look at it, but I think for example we were supported by the PAINT program that me wasn't perfect but I have positive attributes. I know that there are concerns, it's been a long time since I've worked on it myself directly, but I know that there are concerns with the E-Waste program and you can go through the different examples and relative strengths and weaknesses. But, and frankly a lot of those programs are obviously very much more focused and more discreet in terms of the kind of products that they are addressing and the more discreet you make in EPR program, the more variable that some of the pros and cons can be. So the issues I'm sure raising today are actually more focused on so broad EPR approaches particularly regarding packaging, that tends to be a fairly broad topic to try to take on and I want to try to sort of go walk through the, I mean the context of the five charges that this working group has been given to look at specifically. So the first is obviously the goal of reducing the use of single-use products. So some of the issues to look at there and you actually got an introduction to that with the previous witness is that you know the working group should work to understand how single-use products, particularly packaging, how they use and design is really driven by quality, health and safety, efficiency, presentation and availability for consumers and how those sort of performance requirements are significant drivers in terms of what you actually have for the use and design of packaging. And those sort of restraints or requirements limit the ability for an EPR program to have much change on those considerations of those constraints particularly in the context of a Vermont EPR program. That being said, manufacturers are motivated to minimize costs including materials regardless of whether there's an EPR cost on the packaging. There are also sustainability goals that companies have in marketing consumer appeal motivations that are driving design issues and amount of packaging issues that are unrelated to whether or not there's an EPR context. So it would be helpful if the working group to work to understand how industry already has and continues to work to reduce unnecessary packaging or increased recyclability of products based on those much larger market contexts and sort of the practical technology and materials opportunities that again, were not necessarily meaning to be changed by a Vermont EPR program. I think it was worth noting here though, you know, my understanding, you can certainly hear from witnesses who are more expert in the fields, my understanding that the evidence has not suggested that the existing EPR programs for packaging in Europe or in Canada have had themselves much of an impact on packaging design and other issues like that. That's not surprising given the fact that it's went over but folks have raised today the idea of having modulated charges and certainly you understand the logic of how a modulated charge could be intended or designed to try to have an effect on manufacturers' decisions like that. I think this simply raises the question to look at how well designed is the modulated price when these are going to provide the sort of positive feedback that would be hoped to have a change like that. For example, if it's simply modulated based on weight, is that going to have a sort of a hand-fist approach that doesn't really necessarily motivate the kind of changes in designer or other issues that you might be looking at? And then frankly, is Vermont a large enough market that no matter how perfectly modulated the gene you might have, is that really going to have a meaningful impact on the costs under consideration for companies to really motivate that change, especially relative to the larger market modulations that are already driving in that direction? Those, I think, are going to be something to be asking about and be realistic about. Two of the other goals of the working group obviously I want is to reduce the environmental impact on single-use products and also to prevent contamination of natural resources by discarding single-use products. So there's some considerations there. It's also similar to the diversion goal as well. So with regard to, there's different ways to look at what the environmental impact or contamination, one is the material composition packaging itself or the product, and I think it'd be helpful for the working group to understand how sort of the material issues, whether it's toxicity or other aspects, how those are driven by existing health and environmental regulations within the performance constraints that I've worked and discussed, and how those are the real drivers of those characteristics and not necessarily EPR itself. And again, I understand that there's not much evidence that EPR has had an impact on those kind of questions historically and the limitations of Vermont having a different impact even with the modulate charge structure would be, that may not be the realest time's rotation. The other aspect of these goals is whether or not these materials actually end up being recycled or if they end up going into environmental. I think there are two main drivers that the groups should really look at that may or may not really be something that can be affected by EPR per se. First is, clearly, is there a market for recycled material? So is there actually some place for it to go other than the landfill? And there are a lot of factors involved in terms of whether that market exists, how can we try to grow or improve that market? I guess the question for the group is, how would EPR change that availability of a market for the products? And is that really the tool that gets you toward for that different goal or not? And the second, and this is really one of the critical things, ultimately whether a product is recycled and recycled properly or ends up in a landfill comes down to decisions by the consumer. What are they going to do with that package? What are they going to do with that product? And a lot of this obviously driven by awareness, education, and incentives for the consumer to do the right thing. And is EPR necessary? Or is EPR necessarily the most effective way to drive those factors? And I think that's the question we really take a serious look at, because I'm not sure it's immediately clear that it is. One thing I would note, and this often comes up with EPR proposals, is one of the other factors for individual consumer decisions is convenience. Obviously the more convenient you can make it to do the right thing with the product, the more you're going to have a positive impact. And certainly, if you look at some of the more narrow-focused EPR programs that I've looked at, especially looking at hard-to-hand or very difficult products or in-community products. When you have an EPR, a new EPR program that has come in and introduced convenience where previously there wasn't, you haven't seen the positive impact. That's not surprising when you would expect that. But it's the convenience that's driving that. And you don't have to have EPR that will more convenient system. State programs and services, local programs and services, competition group hallmarks, there's all sorts of things that can lead to more convenience being provided to consumers that would then have a positive impact on recycling that don't require EPR to make those things happen. So it's just, and I think it's not clear to me that convenience is the most, is such a huge and critical issue in this particular area since we're talking about some fairly basic recyclables where, whether it's, you know, iPhone 48's requirements for options for consumers or just to deny the state of the infrastructure. I'm not sure, it's not clear to me that convenience is a really big serious problem. Certainly one that can't be further improved through any number of reasons beyond EPR. So, another goal is to improve statewide management of single-use products. I don't know if the community has discussed what that means in terms of, is this like a smooth operation or some other aspect of what good management means. So I guess the questions would be for the group is in the context of EPR, is creating sort of two basic approaches you could take. One, industry is required to create a whole brand new collection system, a whole new infrastructure system either on top of or to replace the existing lineup. You know, from a good management perspective is that really a good idea. And then the other way is basically to have the industry pay for the existing system and simply changing who pays for the system. How is that going to improve the management of EPR, say? Again, that would be a question to the community for either because it's not in the clear to me how that's going to be. And then finally, divert single-use products from the disposal in landfills. This is really somewhat overlaps from the other things that we've talked about in terms of making the drive to make packaging and other products more recyclable. There are big market forces that are pushing that to the extent that it can be done. It's not clear that EPR will change those forces. And ultimately, it really does come down to how can you best educate and motivate consumers to make the right decisions. And there are certainly industry programs particularly regarding education that can help with that. And it could be good to hear from industry groups as to what they're doing in those lines and what the support and participation or cooperation is available for Vermont. But those aren't necessarily EPR programs per se. So really just to boil down, I think there's a lot of progress toward the goals that have been given to this working group that the industry is already pursuing for bigger reasons than EPR. And there are a lot of goals that really come down to individual consumer decisions which driving those is something that is really not, does not fit well, I think, into our exclusively, certainly, into the EPR approach. So I'll just do that. One last thing, because there's been a lot of talk about today about the cost shift and trying to relieve these values of solid districts and what districts are some of the costs that they're facing. Yeah, I think there's a lot of questions about that, especially with regard to whether that's really saving for moderate money, whether it really helps the consumers or whether it's simply just moving things around. There's a lot of factors to look into. I think it's highly variable as to which manufacturers, to the extent that they would or could pass those costs, either in a whole or in part, on the consumers. I think to suggest that it's not gonna happen, it's pretty unrealistic. And to the extent that that does happen, there's all sorts of things to think about. If you're imposing a cost per service up at the beginning of the markup chain, and that gets back into the underlying initial cost and as that product works its way through distribution and retail, and you get the markups that you normally get, is that cost gonna be inflated along with everything else down the line? And then that costs more at the end of the consumer and then it would have, if it had started there, there's additional administrative costs. I think Mr. Happner brought up that issue. If you're looking at NPR approach as more or less sort of, we'll just pay for what the current system does or when check approach, what does that do to accountability and incentives to be cost-effective and the services that you're provided if you're basically going to be paid to do regardless? I think Mr. Chairman, you brought the concept of if you have a tangible connection between the consumer and something that they have paid, they have paid for the service, how does that affect their incentive to actually make use of that service? I think actually that's a very important connection that I think that's a real factor that should be kept in mind. And again, this is sort of discussed a little bit earlier today too, realistically, if you offset the cost that's being driven from an existing tax or existing fee, is that tax a fee really going to be reduced commensurably, I think it's a political reality that doesn't always happen? So, shifting those costs is not necessarily a good solution for consumers. It's very understandable why some folks would like the idea of that cost, especially if it's an expensive program, of those costs being changed a little bit so that they're more hidden from consumers that doesn't necessarily mean that's the right thing to do. And frankly, if you look through the statute, the charge for this working group and the things you're supposed to be looking at, shifting that cost out of existing providers is not listed as a role or a priority for the group. And so I think it would be unfortunate that became the primary driver of the discussion here. Just some things to think about. Yeah, so just to make sure I understand your last point, there's in terms of the charge which we were reviewing earlier today. So what part of the charge, I'm not quite sure about what part of the charge, and this is a point that you think may be ought to be part of our charge to put the shifting costs and missing them. I mean that explicitly tried to shift the cost off of existing providers and obviously manufacturers. That's not a direction given to the community. I mean to the working group. I think people may try to argue how it may factor into some of the other charges and we can have that debate in the discussion. It's not on the space of a goal but it's given to the working group. Any questions for Mr. Driscoll? Third question? Okay, all right. Thank you very much. One of the other charges I thought was to come up with a list of items that are supposed to be considered for inclusion under this. So it's kind of hard to think about what kind of extended permissive responsibility program you put in place without understanding what materials we're talking about. And I'd like to hear from some of the distributors on some of the challenges that they may have. Some of these extended permissive responsibility laws. I know the bottle bill was brought up today. I don't think that's really a charge of this group. Decide whether or not we expand that or not. But I'd like to hear from some of the distributors on some of the challenges they could face. And Sarah, when you say distributors, what kind of distributors are we talking about? So, fully, Claire, in the room here, also, you know, there's thousands and thousands of manufacturers of these products. But if you're talking about getting them to one state that has a program, how do those products get distributed and separated and entered into this type of program? And then I think we also need to consider what markets are in place, depending upon what items we choose, what markets are in place and available to recycle these materials. Because I think there have been some unintended consequences with the electronic waste producer responsibility law that you can read across the country about warehouses, actual warehouses with abandoned CRTs, that manufacturers paid into a program to recycle, but now are left abandoned in no form. So I think we need to consider unintended consequences as well. Okay, thank you. I said at the last meeting, and I'll reiterate it again, just asking solid waste entities and municipal entities, other interest groups that are working and insistently have now, whether there's any kind of low-hanging for your improvements in the system as it is that can sort of help. What's not working or what is working, especially when we're talking about the costs, regardless of where they're born, I'm trying to get the most bang for your buck for any changes we make in the system. So. I'm lining up with Kim on identifying products can also mean types of packaging, as well as classic restaurant ware, for instance. But I'm sort of, could be a product, could mean, could be a sort of a broad thing, but it can also mean specific things. And I do think we need to have a better understanding of the specific, and then to then understand how we're going to deal with it. And which products may actually be best managed through ERP and which may be best managed through BAM. Thank you. Go ahead. Yeah, I think echoing a lot of what I've heard already, it sounds like it's the next meeting that's going to be hearing from more stakeholders and experts. It seems like soon we need to be looking at what are some of the policy proposals, like BAMs and other things. We started hearing about EPR, but maybe we're putting the charge out to all of us the meeting after to come in with some more specific proposals that are looking at product categories and what we might do about them so we can start making it more tangible to react to and get input on. And then that might kind of opposite, which further expertise would be helpful to hear from someone from one of the other states who are working on similar bills and that kind of thing. So that would be my recommendation or idea. The other thing I wanted to raise was at some point, it might be helpful to build in some opportunity for public input as well. Is there anything else? Excuse me. It was good to hear that there'll be some testimony lined up around health impacts and the other items that you mentioned, Senator Bray. Yeah. And looking at single use products and lining up with that comment as well. You know, looking at what products we want to include in any system, we have the division between BANs and other management systems. And maybe somewhere in there, as we talked today about like modulating fees, what criteria would we use as a group or suggest for further investigation for ranking those materials because, as Kim mentioned, CRT glass, which was maybe a byproduct of a former PPR system, was collected because it was a hazardous material and something that we didn't want in landfills. We were trying to force other management from and so identifying those, you know, the highest need materials for greater management would be useful. Okay. So I would like to find out more about the work that Maine's doing and see if that aligns with any of the goals that's tasked with this group. Because I think that could be, that could cut to chase a little bit. Could you say that again, because I didn't know. Oh, sorry. So I would like to find out more about what Maine is doing with their PPR work, the build that they're working on at the state level. Because I think that might, and to see how that aligns with some of the tasks that this group is tasked to do. In that same vein, I would like to find out a little bit more about the Canadian programs and advancement of the modulating fees, potentially, and how implementation of those programs work with the existing system that was already in place, because that's what we're looking at here as well, to just see how that transition happened. And I would like to know more about the Vermont Holler's perspective on that and how PPR would potentially be transitioned into what they're doing and what their perspective is. Specifically, probably Kasella or Meyers, like the Vermont Holler's. Indy. So, one, in terms of getting an idea of what costs whatever program we create is trying to cover up for 30 million, I think that was in Connecticut or Massachusetts, 15 to 17 million in Maine. I know their numbers, just a rough estimate. So, if we've got any ideas on whatever program or outcome we have, what type of cost we're trying to reimburse or cover, what's the scope of that universe, perhaps. I would support an investigation of the markets to understand what changes happen in the markets and what markets either aren't there or would need to be there to help make the system function better regardless of whatever we recommend. And then, in terms of what I mean free and sort of programs other than EPR, I would encourage some outreach and I can help provide some contact with the Recycling Partnership and improving current systems and the program that they have, which is a voluntary industry sort of program that's been working around the country. So, I encourage understanding what work they are doing so that we can understand that and see if there are efficiencies that aren't in the system right now. Great. Okay. So, plenty of things to work on, but I'd say kind of the thread was being more product specific. I narrow it down from all the universe of things we might focus on. And so, I don't want to put the, you know, the two of you are sitting side by side on the spot for people running programs at the speed level. You know, I think part of what we can do is be thinking about, again, if it's the end of the low hanging group and also I don't know if you, because of your day to day operations, seeing materials coming through and you say, this is the most problematic material or maybe the other side of the coin is, here's the material that represents the biggest opportunity for financially positive stream to deal with like a financial opportunity or something. We can look at identifying from really like an operational level where you see some opportunities. And I would think, can you must have some feedback on that, especially on like the market side? Yeah. And casting. So I would ask people, I'll follow up with you between now and next meeting because we're really, we're over by five minutes. I apologize. But so we already, we'll have some practitioners in next meeting already, so we can hear from some people who are executing on this kind of thing and learn from them. We're identifying products more that we narrowing our universe a little bit, identifying products more narrowly, looking more into recyclables, marketplaces and the loading for food piece. Seems like some useful thing more than enough to keep us busy for the next, next meeting and beyond. And if you can give Michael and like the recycling partnership information and two meetings out, we're connecting with Jeff. Can you remind the group who he is and who he's done evaluations of different programs around the country for the national Ways and Persons Association. Great. All right. Anything, so thank you everyone. Any parting comments anyone have something you want to add? Yes. One thing that didn't come up that I was just thinking back to Scott's great presentation that you talked about, clarity of goals and what are you trying to accomplish. So just thinking it could be worth time before we're crafting a system of like, do we have a shared understanding of what we're trying to accomplish and therefore what are the best tools to get there? Even if we might not agree on what those tools are, do we get to a, like, do we have there, you've got the charge of the, from the statute, but like grounding ourselves in what we're trying to accomplish. Yeah, I think that was, yes, thank you. I was thinking about that and forgot to write it down. So, right, you're trying to solve a problem but are identified the problem pretty clearly and agreed what the problem definition is first. Okay, so thank you everyone.