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Plastic Packaging Management Study Stakeholder Consultation Process Prepared for the Washington State Department of Ecology

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Plastic Packaging Management Study Stakeholder Consultation Process Prepared for the Washington State Department of Ecology Plastic Packaging Management Study Stakeholder Consultation Process Prepared for the Washington State Department of Ecology September 25, 2020 Table of Contents Table of Contents ..................................................................................................................................................... 2 Authors ........................................................................................................................................................................ 3 Executive Summary .................................................................................................................................................. 4 Stakeholder Consultation Process Summary.................................................................................................... 7 Appendix A. Study Timeline ..............................................................................................................................A-1 Appendix B. Stakeholder Organizations Contacted ................................................................................... B-1 Appendix C. Stakeholder Communications .................................................................................................. C-1 Appendix D. Policy & Technology Options for Managing Plastic Packaging Survey Summary ......................................................................................................................................................... D-1 Appendix E. Policy & Technology Options for Managing Plastic Packaging Survey Instrument ....................................................................................................................................................... E-1 Appendix F. Policy and Technology Options Survey Raw Responses .................................................. F-1 Appendix G. Draft Recommendations Feedback Form ............................................................................ G-1 Appendix H. Comments Received on Draft Recommendations............................................................ H-1 Appendix I. Other Public Comments Received ............................................................................................. I-1 Appendix J. Comments Received via Study Email ....................................................................................... J-1 Table of Contents | 2 Authors This report was authored by Cascadia Consulting Group and Full Circle Environmental with support from Eunomia Research & Consulting and MORE Recycling. We have taken due care in the preparation of this report to ensure that all facts and analysis presented are as accurate as possible within the scope of the Study. However, no guarantee is provided with respect to the information presented, and Cascadia Consulting Group, Full Circle Environmental, Eunomia Research & Consulting, and MORE Recycling are not responsible for decisions or actions taken based on the content of this report. Authors | 3 Executive Summary In 2019, the Washington Legislature passed the Plastic Packaging Evaluation and Assessment law (Chapter 70A.520 RCW), which directed the Washington State Department of Ecology (Ecology) to hire an independent third-party consultant team to study how plastic packaging is managed in Washington and assess various policy options to meet the goals of reducing plastic packaging waste. The law directed the assessment to include industry initiative or plastic packaging product stewardship, or both. The law also directed the consultant team to include consultation with packaging and packaged goods producers, providers of solid waste management services, and other stakeholders. The goals of the consultation process were to: • Identify key stakeholders • Consult with stakeholders on research and findings • Gather data and information • Keep stakeholders informed • Provide stakeholders with opportunities to share data and feedback in the development of options to increase recovery and reduce plastic packaging in the waste stream, and in the development of final recommendations. The consultant team contacted, received input from, or otherwise engaged the following stakeholder sectors: • Industry (packaging producers, • Litter and marine debris clean-up packaged consumer goods programs Local government solid companies, brand owners) waste or recycling personnel • Solid waste management services and • Academia collection companies • Ecology management and staff • Recycling facilities • Other State agencies • Plastics recyclers • Members of the public and other • Nonprofit environmental groups and interested parties community-based organizations The consultant team established several channels to communicate with stakeholders and solicit input, including: • Webpage where all Study documents and deliverables were published • Opt-in listserv for all Study-related updates and notifications • Data requests and interviews during research phases of the Study • Survey on policy and technology options for managing plastic packaging waste Executive Summary | 4 • Public comment opportunities via website, monitored Study email, and voicemail box • Feedback form designed to gather targeted input on draft recommendations Stakeholder sentiments regarding proposed recommendations are summarized below and provide general trends and attitudes toward potential policies and funding mechanisms. However, it is important to emphasize that because the Study recommendations constitute high-level policy options for legislative consideration and are not fully developed policies or bills, these stakeholder positions constitute general feelings and could change for each stakeholder depending on the specifics of future proposed legislation. • Government and nonprofit stakeholders who provided input indicated strong support for an extended producer responsibility (EPR) policy framework for all packaging (recommendation 1). Several packaging and packaged goods industry stakeholders indicated they could support an EPR policy with specific design considerations. Several other industry stakeholders, as well as waste and recycling service providers, were strongly opposed to an EPR system. • Support was lower for a deposit return system (DRS) for beverage containers (recommendation 2). Similar to EPR, government and nonprofit stakeholders tended to favor it and think that it should be incorporated into an EPR system, while waste and recycling service providers uniformly opposed it. Industry support was mixed, though two key stakeholders representing the beverage industry indicated they could support a DRS in Washington and outlined specific ideas around policy and program design. • Support for recycled content requirements for plastic packaging, beverage containers, and trash bags (recommendations 3, 5, and 6) was generally much higher and encompassed all sectors, though there were concerns around adequately addressing toxics in recycled content, wanting exemptions for certain packaging (e.g., health and medical products), incorporating lifecycle considerations, and allowing time and flexibility to address supply constraints. • With a few exceptions, stakeholders generally supported, could support, or took no position on a standard for customer opt-in for foodservice packaging and accessories (recommendation 8), supporting development and adoption of reusable packaging systems (recommendation 10), and strengthening data collection on final destinations of materials sent for reprocessing (recommendation 9). • Packaging and packaged goods industry stakeholders did not generally support producer registry and packaging reporting (recommendation 4), though other stakeholder groups did. (Relatedly, a number of stakeholders critiqued the overall Plastic Packaging Management Study for not having sufficient data, underscoring the need for expanded data access.) • Support was very mixed on banning problematic and unnecessary plastic packaging (recommendation 7), with local government and nonprofit stakeholders, as well as Executive Summary | 5 some waste and recycling service providers, indicating support, especially for packaging containing toxics. Industry was generally opposed to bans, and was concerned by the lack of definition of “problematic and unnecessary.” In general, government, nonprofit and other advocacy groups, and members of the public tended to favor all recommendations and expressed desires for recommended policies to go further by broadening their scope or speeding their timeline. Waste and recycling service providers tended to support recommendations that would benefit their business and oppose those that they perceived as threatening their business model. Packaging and packaged goods industry stakeholders generally tended to oppose recommendations that would increase regulation of businesses, citing expected high costs associated with many policies and potential regulation and the potential for unintended consequences. However, several industry stakeholders indicated some level of support for (or lack of opposition to) two key policies, EPR and DRS, to which they have been heavily opposed in the past. Several stakeholders expressed concerns about expected costs of many of the recommendations, noting that adding costs and other regulatory burdens to any sectors— especially in the current context of the COVID-19 pandemic—would be unwise. Executive Summary | 6 Stakeholder Consultation Process Summary Background To implement Chapter 70A.520 RCW, the Washington State Department of Ecology
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