Good afternoon, everybody. Welcome to meeting number four of the Single Use Product Working Group. And we have a busy and ambitious agenda today.  That said, we have a brisk schedule and so I'll ask people to, although it's, we have limited time for everyone. I think when we both move right along, we usually hear everything we need to hear and we can always ask all questions. So apologies for the tight schedule. Let's get started and are you, Mr. Button? I am. Okay, good afternoon. Thank you for coming in. Thank you. Thank you for the opportunity to testify. My name is Todd Bell, I'm the general manager of Feral Distribute Incorporation representing the Vermont Wholesale Peverage Association whose members include a number of Vermont beer, wine wholesalers. Vermont's beer and wine wholesalers are family-owned local companies employing thousands of Vermonters. Our companies have significant capital investments in Vermont, including large warehouses, fleets and trucks that deliver a wide variety of beer and wine brands to over 1200 licensed bars, restaurants and stores across the state. We are not the multinational out-of-state company as we are sometimes portrayed. We have been operating the bottle deposit system in Vermont for nearly 45 years in our responsible stewards of our products in the environment. At the onset I want to be clear that Vermont beer and wine distributors is not here to just say no. We are open to discussing alternatives to the bottle bill for those products that we sell that are not already covered, such as wine bottles. Alternatives should apply to all glass, not just beverages. A&R has been hosting a series of bottle bill stakeholder meetings and there is near-denominous agreement by the stakeholders that operate the bottle bill that there are serious problems including the number of sorts retailers are required to perform. Space constraints are also a problem for redemption centers, fraud in the system and ensuring nontraditional entrants to the market comply with current regulations. Vermont must address the following serious operational flaws of the existing bottle bill for making any changes such as expansion to new product types. I would like to address two issues that go largely unnoticed by the public and the legislative community in regard to the bottle bill. One has been around a long time and the other is relatively new problem that will increase exponentially over time. First, the issue that has been around the longest is fraud. Deposits require a costly system of oversight and auditing retailers and redemption centers to ensure that not only deposit containers purchased in Vermont are being redeemed and are route out fraud in the system. In my 30 years I have witnessed countless cases of fraud in the system. Recently one of my employees visiting a redemption center near the New Hampshire border kept on film a large truck and trailer loaded with bags of empties. Do you have pictures in your packet to this effect? This vehicle with New Hampshire plates left the empties without being paid and the empties were in standard redemption center bags that the distributors pay for and supply. This was reported to A&R and A&R did act on this. This suggests the way it was carried out that it was an organized effort. A few years ago, the Vermont Co-Mingling Group paid to investigate a situation in Brattleboro where a U-Haul truck with neatly wrapped palates of empties were being returned on a regular basis. This is large-scale fraud but the greatest cost comes in the form of everyday returns that are fraudulent. People returning bottles, they never paid to deposit them. Increasing the scope of the bottle bill while the current system cannot protect or not business is already negatively impacted by the bottle bill's regulatory shortcomings is unjust. I just like to pause a minute to, I didn't include the pictures but here's a picture of palates of blue bins from Cheshire in New Hampshire, the town of Cheshire that was coming over to Vermont on a regular basis. So they're actively sorting and bringing them over and then palatize product as well. So this is fairly large-scale. Second, the newer issue but one that will grow exponentially there are many non-traditional entrants into Vermont's retail beverage marketplace including hundreds of out-of-state wineries and internet retailers that ship wine to Vermonters. The same is true for other non-carbonated beverages. As a result, it would be extremely difficult to enforce any requirement that these non-traditional entrants in Vermont's market include on their labels the Vermont deposit insignia or initiate deposit when they sell the wine, pick up the empty wine bottles from Vermont's 1200 retailers and pay refunds and handling fees in Vermont. Local Vermont wine distributors will be left paying these expenses while out-of-state businesses enjoy the ill-gotten profits. There are already more glass containers redeemed through the redemption system than are sold by Vermont registered deposit initiators in Vermont's coming-in system. I'd like to just repeat that because it's the most important point to making this whole testimony. There are already more glass containers redeemed through the redemption system than are sold by Vermont registered deposit initiators in Vermont's coming-in system. This demonstrates that Vermont is already experiencing fraudulent redemption as glass beverage bottles are purchased out of state and make your way to Vermont. There are other reasons that make expanding the current bottle bill system less advantageous than tackling recycling for single-use products as a whole. Vermont's bottle deposit system is inefficient and costly because the same containers must be counted numerous times so consumers and retailers are reimbursed for their deposits and handling fees each touch of the container adds cost to the system. Imposing a deposit and a three and a half cent handling fee on each wine bottle will increase the price of the wine to the Vermont consumer and other product more attractive to purchase either online or in a neighboring state. The Agency in Natural Resources commissioned a report by DSM Environmental Services, titled Systems Analysis of the Impact of Act 148 on Solid Waste Management in Vermont. That was dated October 21, 2013. That report found that in 2013 the existing bottle bill cost all parties including distributors, consumers, redemption centers and the state over $11 million to operate per year. This is an extremely costly system to operate. We believe the state should consider alternatives that would better use our resources to focus on a haul price rather than just beverage containers. And in doing so, we'll get a better environmental bank to live up. The 2018 Waste Composition Report provides data about 8,000 tons of glass which makes up 1.9% of the total 422,000 tons of all mixed municipal solid waste including both residential, commercial and industrial disposed in Vermont in one year. The data from this report also demonstrates the glass from wine bottles and other non-carbonated glass beverage bottles comprised less than half of the glass disposed of at Vermont's Merce. Even if Vermont had an expanded bottle bill Merce would still have processed 3,300 tons of glass from other products and sources. You have heard at your meeting from the representative of the Chittin' Solid Waste District that they are in the process of upgrading the technology of Merce and Wilson. Given that imposing a bottle bill on wine will still lead a significant amount of glass to be processed through Merce. A more comprehensive solution that will address all glass and not just beverage container glasses needed. Per the data from the 2018 Waste Composition Study expanded bottle bill glass which includes wine bottles and non-carbonated glass beverages such as juice accounts for 0.6% of municipal solid waste by weight in Vermont. Recover rates for non-deposit glass are already very high in Vermont.  Imposing deposits on wine bottles will also lead to a greater carbon footprint due to increased transportation that exists within that system. Wine bottles currently go from table to blue bin where they are transported to a mark. The deposits would require extra transportation by the consumer to the retailer and then again for the wholesaler to pick it up at the retailers. Glass is heavy and very expensive to transport. Imposing a deposit and a handle of the unwind will cause wine sales to decrease in retail stores along all of Vermont's borders thereby reducing tax revenue generated by wine sales in Vermont. New York and Massachusetts do not pose the bottle deposit on wine. New Hampshire does not have a bottle bill and imposes no sales tax on wine or beer given that statement even greater edge. Increasing the bottle deposit from five to 10 cents on all beverages subject to the bottle bill will significantly increase the price for Monarch paper beer and soda at the cash register. A total of $2.40 per case just for deposits. This would send more of our Monarchs along the border to New Hampshire without a bottle bill in New York and Massachusetts with a buy sent deposit. Once they purchased products in the bordering state they often returned those empty beverage containers in Vermont and get reimbursed for deposits they didn't pay. Buying a case of beer in New Hampshire would come along with the added bonus of being able to return the empty in Vermont and get $2.40. This sets in motion a scenario whereby Vermont businesses lose sales. The state loses tax revenues and distributors pay for containers they never sold. This is not good business for governance. Why beer and not wine? I've heard this question came up at your last meeting and historically the bottle bill was enacted as a litter control measure in the 1970s. Wine bottles were not a large part of Vermont's litter problem then and they certainly are not now. I hope my testimony today about fraud and all the non-traditional entrance to the wine market in Vermont helps you better understand the current challenges with imposing a bottle bill on wine bottles. We already have over redemption in glass in the Vermont Co-Mingling program. Some recommendations. We recommend the ANR Bottle Bill Stakeholder Group or the ANR Bottle Bill Stakeholder Group is considering asking for legislation to acquire more manufacturers to Co-Mingling to ensure they are participating in the system and to reduce the number of sorts of retailers. Please consider this and other ways to address the significant operational issues with the existing bottle bill before changes are proposed to bring additional containers into the system. BWBA members will welcome the opportunity to work with the state and other stakeholders and alternatives to the bottle bill that will address not just beverage containers but all bottles. We believe a more comprehensive solution will increase recycle rates, generate funds for necessary investments in technology that are solid waste facilities, have a greater environmental benefit, be good for the Vermont economy and be less costly for Vermonters. We urge you to direct interested stakeholders to work out the details of this proposal. Initiators of bottle deposits must begin remitting unclaimed deposits to the state with the first quarterly payment due this January 2020. These funds are currently earmarked for water quality. As this is revenue that is generated by the bottle deposit law, we urge you to propose that part or all of the unclaimed deposits be redirected to build up Vermont's recycling infrastructure and address other needs in Vermont's solid waste system to increase recycling rates in Vermont. Let me finish by saying that the BWBA members that I represent fully understanding and embrace our responsibility in improving the current system of material recovery and processing. Thank you for considering my testimony. Welcome to questions. Thank you. On recommendation number three, that was actually part of the recommendation of the committee, two fellow legislators, but by the time the bill came out, that money had been kept in an environmental effort but shifted to the other, just by way of explanations. Any questions from the committee? Mr. Butler? Can you explain what it would mean logistically to put five cents on a wine bottle as far as the distributor is concerned? Sure. Currently, and I can speak a little bit more specific about our business, we handle roughly five to six million bottles of wine a year and we're a, what we call a bottle state, meaning we sell each bottle of wine individually. You don't have to worry about the case. That product comes into our warehouse. We would then have to hire a crew of people to open five to six million bottles of wine, pull it, stick it, drop it back in the box. I saw this practice in place in Maine a number of years ago and I went up this to visit with Pine State and they had a crew of, I believe, seven people doing it at the time. One concern with that right now, it's quite honest that we have not had a full staff for our operational part of the business for well over three years at any one point in time. We usually, we average about five to six empty positions every day right now. So I don't think staffing that is gonna be easy at all. Plus the job itself is completely tedious. There will be no middle to small suppliers in the wine industry that will have any interest in helping us with that or changing their labeling. So we'll end up having to do it. You might get a couple of the large suppliers to do that like a Gallo or something like that, but in one way or shape or form it's gonna be just a tremendous undertaking of labor. I heard, I read through some of the notes from the previous meetings. I think there was a figure out there that suggested there's 18 million bottles of wine in Vermont. I don't really understand where that number would come from because we know what our market share is and we know what we do. And I think the more realistic number for Vermont's gonna be between 10 and a half and 12 million bottles a year. But I'm sure you all know people. I certainly know people, including my wife that loves to stop in New Hampshire on the way up through and buy a case of wine because it's a great deal. And I just think we're gonna, we're gonna exasperate the problem with our own small businesses in the state. The other thing that's really important is when we first started having these discussions about the bottom bill with Kathy's group it became apparent that a lot of people don't understand the extent at which containers come into the state of Vermont differently now than they ever did. When I first started 30 years ago there was maybe five wholesalers, that was it. And you control 95 to 99% of the containers. Now you got everything from small craft beverage manufacturers who don't quite understand the law and their bottles and cans come into mix. We have third party distribution centers out of state that sell to the likes of a dollar general. And they don't really know what those laws are but those come into the state. There's online sales for beer clubs and wine clubs. I know recently the gentleman from Coca-Cola he gave a data point in New Hampshire where they shipped four to five pallets a week to an Amazon distribution center. So I think that it's foolish to think that that's gonna slow down. I think it's gonna increase. We certainly in running our business fully expect that our piece of the pie is gonna continue to get smaller. We sure don't wanna be saddled with any expenses associated with that business that weren't born from us. Questions? Yeah, questions. So spirit syndrome, are they all stickered by the state to start their system? Yes, stickered by the state, that's my belief. I don't think that has changed. I do know that they have difficulty with maintaining the stickers. We actually did a, we did our own little survey recently and found that, I don't know what the percentage is but there's a fair percentage that those stickers did not last all the way through the system. Are there other states with that deposit, line bottles that you're aware of and are those jurisdictions, is it working any better someplace else? Maine is the one I'd be most familiar with. They have a very different co-mingling system up there and their entire system is built differently than Vermont. So I can't really speak to the specific efficiencies that they're experiencing. I do however know that the stickering of the bottles is just a huge problem for them. In fact, for a while they just stopped doing it because they couldn't staff it. And just, I wanna make sure I understand the logistics. So one, if there were wine bottles in Vermont or stickers, you were talking about, well, people traveling through New Hampshire might wanna pick up the case. But what I'm missing is, how would they be redeemable? Sure, so we've learned from the explosion of the craft brew in the studio tonight, for example, that it really doesn't matter what's on the bottle. We audit, the wholesalers run the Vermont co-mingling system and we pay to have a gentleman that audits that system and he goes out to the redemption centers and does his best to try to quell that problem. But at the end of the day, you're still working with probably a high school kid in the back of a beverage redemption center who is just throwing them in and you're not catching it all. In our meetings with A&R we discuss a lot about the technology that is out there and available to try to fix that. But that technology is extremely expensive and you only see it really deployed in massive systems. I mean, at the end of the day, Vermont is still only a 600,000 resident state. So, to answer your question, I don't think the sticker's the end, though. I mean, sure, you can still try to stop it, but invariably much of it is gonna go into a bin. Any other questions from the committee? Can you tell us the process of, you were talking about the environmental footprint of bringing it to point A and to point B, but when you pick up your bottles that you distribute, will you tell me the process? Sure, so I'll give you an answer of the way it used to be and kind of the way we do it today. So back when I first started, we didn't have co-mingling or third party collection systems. So we as the whole center collected every single account in the state of Vermont, all of their empties. Those would be brought back to our facilities. We processed them and ultimately back then, we also marketed that material to recycling companies, or companies that would use the material. Very labor intensive, a lot of travel. Lots of redemption centers and small stores were much more engaged in the redemption process back then. As years went on, we developed a co-mingling system and part of that was because the number of items had started to grow so quickly that we just needed a new way of getting everything into one box because the redemption centers couldn't handle the sorts. So we developed what was called the co-mingling system whereby a group of distributors, not all but a group, participate in this. It's all in, all of our material goes into that. That's picked up by a third party company called Tomra. So they're out picking that up from redemption centers. The wholesalers still go out and pick up the small stores and on-premise accounts, okay? So you have two parallel systems. You have Tomra picking up the bulk of it at the larger redemption centers and you have the independent wholesalers still picking it up at all the little mom and pop groceries and all of the on-premise accounts. Those products come back to our warehouse. They get handled, cross docked and then Tomra comes in and picks it up from us and then trucks it out of state. So you really have multiple things going on with many trucks on the road. More than you used to have. It's from a carbon footprint standpoint. It's not very advantageous. As opposed to consumer finishes the product, puts it in a recycle bin to pick up once and it goes right to a facility for processing. So it's much more streamlined that way. Great. Thank you very much for your... Thank you. So you're gonna read the presentation. Alan B. Hi, Alan. This is Mike Perot from the Single Use Products Working Group. Hey, Mike, how are you? Good. Hi, Mike. This is the chair of Chris Beret and you're on speakerphone in a room with 50 or 60 people. We have your PowerPoint up on the screen and the floor is yours. Just wanna note that for the content of my desk we're an organization that's been around 25 years now. We started in 1994. During that time we've recycled 20 billion containers weighing over 1.6 million metric times. So we've had that for a long time. In terms of my presentation overview, next slide. Just wanna talk about ETR and BC. I touched on ETR for passion and BC and how it works. It was an overview of the on-course system and then talked about some of the benefits of ETR as well as the impact on these values and then just briefly touched on a couple things we have coming up in terms of changing our model. Next slide. So in terms of extent producer responsibly, I forget this question, what does that mean? You know, what the extent is to what? So the reason why we talked about extent producer responsibly is that it makes the producers responsible for the end-of-life management of their product and packaging. And in terms of what does that mean in responsibly, it means that producers under the care of the producers are responsible for collecting, recycling, and diverting the material from landfill. And as part of that, paying the cost of such a new activity set out in the series plan, which in the case of BC, is ultimately approved by the BC of Ministry of Environment. In terms of producer responsibly, it's really the producer. So in BC's model, the actual legal obligation is on those producers who either are made into the product in BC or who import the product into BC. Now they can go through party agency like awkward to ensure that they meet the obligation of the regulation, but if they don't belong to an organization like ours, then ultimately they need to do something on their own to meet their obligations under the recycling regulation. I just to note here, producers sometimes don't use a sewer in other products, as I typically refer to the producers. And really producer in the BC definition is, you know, brand owners. So someone that's a manufacturer of risen in BC, and if there is no manufacturer of risen in BC to the product, then that ultimately falls to the retailer or distributor that imports that product into the product. In terms of our law, BC is somewhat unique. So we have an environmental management act that we enacted before that's not unique. What is unique is that in the same year we filed the recycling regulation. So this is an umbrella regulation under which all the separate programs are guarded. And what it means is the legislature doesn't need to introduce a new regulation each time that they include different programs. So instead, what I do program is brought into effect. It's done through the addition of a schedule which contains information that's specific to that product category, but otherwise all the obligations are similar, are the same for all the different product categories as articulated in the overall framework for a second regulation. So very container to schedule one, packaging and purchasing would be schedule five. And we now have over 15 security agencies and B2 management channels, such as paint, powders, and electronics. There are some smaller agencies and individual one-offs. So companies specific, EPR programs, but those are becoming less and less of something we see in a more and more organizations and industry are working through collective organizations such as Encore, return it to administer their obligations of second regulation. Next slide. I have just a quick question. Sure. It's, do you have, do your joining jurisdictions have comparable laws or do you have any issues with cross-border reasons? For instance, in a jurisdiction that doesn't have that kind of obligation on stewardship and yet their product is flowing into your products? Yeah, that's a good. For the most part, under those 15 search agencies that may bring jurisdictions, at least in Canada, not so much Washington State, but in Canada, I have similar programs. There are slight deviations. So if I looked at our deposit program, we have differences in the deposit rates. And so for example, you know, lives in cans right now only have a five-cent deposit, whereas that's a 10-cent deposit in Alberta, the neighboring province. So I'm very sure that there is some movement of material from my province to Alberta to gain that extra five-cent. I don't know that it's significant, but I'm conscious that there is some leakage for sure. In terms of packaging in the RMBC, I think it's important to remember that we've got two programs. So our program, packaging in the RMBC on Corp. Pacific, we've achieved a 74% recovery in the last year. And that's for beverage containers in both the residential and the IC&I system. So for the beverage containers in, we don't differentiate from where the product or where the product is sold. Every beverage container that's sold in the BC must be part of our program. And we must work out for every one of those containers. I think that's pretty consistent for deposit programs across the country. The other programs of CycleBC, and part of what we're gonna have to do is presentation. So before my current role as president and CEO of Angkor, I choose to manage the year of the CycleBC for five years. Now, CycleBC is the first program in North America where the industry has actually taken over responsibility for basically your household or to paper packaging. And so that's schedule five. Last year, CycleBC had a 70% recovery rate. It's been over 75% each of the years it's operated. And that's for packaging and paper products, but it's only in the residential sector. I just wanted to know that for anyone that's thinking about this work, the IC&I system is still actually run much like it is in any other jurisdiction. And I think one of the challenges going forward is the commercial system in large population centers like Vancouver, which has, you know, Metro Vancouver has population of roughly 2.5 million people. Still works relatively well. It is a challenge in some of the more rural places in terms of managing that commercial outside on the care system where you're suddenly having to manage a smaller amount of material. So that's an opening to consider as well. Next slide. Can you tell me any hack in here? Just a question for both of the rates on the previous slide of recovery rates, are those recycling rates or just diversion rates? They're coming into the process. For CycleBC in 7.4, that's on the United Nations. So we diverted 77.4% of the containers both in the process directed to recycling. I would note that a certain portion of that material would end up being residue or waste. So I think in a typical year of about 5%, so that 78% of the cottage would end up being residue or material that ended up going to land on. Not because of anything that CycleBC did, but because, you know, when they collected that container of material from the portion was, you know, garbage that was put in there by mistake. Is there waste energy in the province or for CycleBC? There is waste energy. Thank you, yes. In addition to the operation in this space, both in BC and other parts of Canada, in addition to where we provide all their collection of infrastructure and manage their collection of logistics, as well as the major appliances or second and round tables, the program responsible for recycling major appliances, and we essentially provide back office functions or accounting and auditing functions for them. In terms of our membership, really five of the various organizations that are who form the basis for our organization, say beverage association, juice council BC, recap council of Canada, a bottled water association, and beverage alcohol containers management council BC. Just briefly, beverage containers in the system were responsible for any liquid that is ready to serve steel drinks except for melting melt substitutes. I should note that the government's currently in consultation that consultation is wrapped up on September 30th, and when is their recommendation, when is the recommendation they're consulting on, without any melting melt substitutes to the deposit program. We're also not responsible for beer when we can refill a glass, and that's because there's a separate Stewart Burr's posterior, wrapped up in the beer industry. They're responsible for managing those containers. In terms of corporate governance, I think this is important in terms of looking at each jar. So we had nine board members, seven industry members who were pointed by those five members I talked about, and then we also have two unrelated members, unrelated directors. So those unrelated directors are recruited, particularly on the basis of trying to provide additional two things. One is providing independent views so that the board doesn't become solely just industry focused but is conscious of other viewpoints outside the industry, but also bring to bear skills that may not be existing among the current industry members. And so by practice, we usually have account or a lawyer or some sort of governance expert. Those unrelated members by practice typically share both our other and government committees and that's the practice certainly today. In addition to the board, we also have an advisory committee and so that represents local governments, our recycling NGO, citizens, depots, and small brand owners. And that group has the ability to provide a report every year and make recommendations to the board about the program. And we're just in the process of updating the terms of reference for that committee. In terms of our search obligation, we need to follow the search plan every five years. Under the recycling regulation, we must meet a minimum of 75% recovery rate. We must provide PPE and access to collection plans. We have some consumer awareness targets to meet as well as very good consultation process. We must go when we're putting out our search plan. In terms of reporting requirements, we have to provide, we have to provide audited financial statements as well as recovery rate and non-financial audits. And all of that is included in the annual report to the Ministry of Environment. So what's important to note is under the recycling regulation, we have to, because we have visible fees, we must make our financial statements public, full-term, and reported to your report to the Ministry of Environment. But then we also have auditors review key non-argued. So all the information used to calculate a recovery target must be reviewed by the head of auditors to be assigned off of that, as well as our collection points must be validated by the head of the auditor. And then the end fate of our materials, we must provide access to both source documents as well as facilities so that independent auditors can actually verify and validate that where we said the material ended up actually ended up in waste recycles. I think that is rather unique in the search of world of East and North America. And I think it's actually a very effective way for the government to ensure appropriate oversight and that what's supposed to happen under the recycling regulation is happening without adding and creating more work for government, which in our view is not always the best use of their resources are. So we've been very happy with this sort of model. And certainly we think that the independent auditors provide the right level of verification and oversight. And certainly we have to make that report available to government and they can question details around that report and ask for further information required. In terms of system infrastructure for all four, we have 170 and a family on depots. That works at 90% of our volume. Retail makes up about 7% of our volume. That's 350 grocery stores and 220 government liquor stores. Again, that means we're recycling about one billion a year, about 77.4% recovery. And that equates to about 95,000 metric tons as well as 25,000 tons of electronics. It's also important that we do a set of these four awareness. That includes public information tools and social media outreach programs. We'll do specific programs around education awareness, partnerships and community support programs and then use the traditional and non-traditional media. Typically our annual budget will be between three to four million dollars. And that equates to around somewhere in the neighborhood about 60 cents to 80 cents per person across DC. And over 25 years, we've built a rather reputable brand that I would say would be in the between 96 and 98% consumer awareness across the province. As I talked before, we have to actually have it in kind of order to certify what happens to our material. What's happening today is about 100% of our, 100% of our new aluminum cans actually manage in the facility in Kentucky. And we do that in partnership with all the deposit programs in the country. We actually operate as a selling group. So I'm cooperative to selling this area. That all that deposit containers from across the one facility in Kentucky, so maybe some ideas fail. 100% of our plastic is processed at our partner room of plastic, either in DC or Alberta, the neighboring province. 90% of our new glass goes to the wine bottle glass through the facility in Seattle, with a remainder to sample those bees to stand by to make sure they're in DC. And then the other thing that's in Gable Talks, so the tester pack in Gable Talk Gardens, the only place you're all currently going outside either Canada or the US, and that's going into the facilities in South Korea. And just really aim recognition of the fact that we don't have facilities like that on the West Coast of Canada or the US. Probably would be a different situation if we're in the Midwest or on the East Coast. In terms of the benefits of the BC model, this would apply to both packaging as well as the deposit program. We really think this is an opportunity to create reverse supply chains and manage materials with opportunities for standardization and optimization. I want to emphasize how important that is. In an economy, we're packaging both in the beverage side and on the consumer packaging side, it's changing very quickly. It also supports the future economy where producers have influence on both creation and its life management of the material. I think one of the things for us to all understand is that we want producers to do things differently. It's hard for them to do that. If the system that they're trying to manage for is in communicating with them and providing opportunities to have their material collected and recovered. And so, how is this kind of model where producers can actually work with the system in a much more proactive way? I think it's actually going to lead to the outcomes we want to see. Is that happening today in BC? Certainly there's parts of it. Would that be more commonplace if the BC model was used in other jurisdictions as well? Absolutely. And we're certainly seeing in Canada more and more jurisdictions moving to 100% EPR model. We also think the benefits of BC model provides producers with the best long-term opportunity to manage their material in light of increasing costs, volatile commodity markets, and continued innovation and impact-type materials. I think anyone that's watched and resected in over the last year knows about the impact of China, knows that it's had huge impacts on local recycling programs. And really, it's going to impact producers in the long-term in terms of at least, in the short-term in terms of the material, not be resected or recovered. But maybe in the long-term as well, in terms of not providing the kind of systematic approach that would lead to investments in domestic recycling capacity that can handle that material and lead to the opportunity to freeze recycled content. In terms of impact on this valley, I think to maximize the benefits of EPR produces the required control of the system in order to develop and optimize the reverse supply chain. That's really what we want again to have that sort of model producers need to have influence on both the creation as well as the design of recovery. That transition can be difficult, but as we prove to be, the state can be managed as long as you have collaboration from industry and local governments. It was not an easy process, but I think if you went and asked me to stop these five years after the program started, whether they're happy with this price, it's undoubtedly, they would say yes, in part because of the changes in China. They no longer have to deal with managing those markets they're insulated because it's the produce organization that has to take on those challenges. And I think for most of this time, that ended up being a very positive choice. And look at those, how does it look like? Yeah, I want to just hear. It's here, Dr. Sherpen. Yeah, and again, a quick question. You talked about the producers having control of the system and control the supply chain. Do they actually take, in essence, possession of the material? Is that, the material is then managed by RecycleBC? Correct. Marketing on material on behalf of RecycleBC, and so the prices provided us with a range of choices and timelines. I think in the BC system, for a range of reasons, unfortunately, we were rushed. But we did try and provide these products with choices. And I think in the end, that was a positive approach. And so some of these products came to the table later than others, but the ability to choose their destiny I think was a key requirement in making the program successful. In terms of what I think are requirements for effective ECR, we shut out from the state's legislation to provide the industry with safe targets and then the flexibility to develop the most efficient and effective approach. So in BC, both from the bottom program and on the RecycleBC packaging program industry has developed the system. They're on board. We've developed a network with independently owned hundreds of independently owned depots that manage our materials. In the RecycleBC program, they've effectively created a waste shed for all the packaging to show them the promise to the residential system. And they've taken existing infrastructure and revamped it to allow for consolidation. We've got a large problem of millions square kilometers. And so they revamped the facilities to allow for consolidation at certain points. And then to manage most of the material, particularly the containers through networks, small network of facilities in the lower mainland. And I think by managing things on a product-wise basis, they normally made the system more effective and efficient. But they've also made it adapted or made it that can easily be adapted for future changes to packaging. A second point would be a search for agencies needs strong governance. And I think there needs to be a balance of industry representation and independent directors. And by independent directors, I really think these organizations respond to the huge operations that are managing a lot of money. And so they need to have experienced corporate directors that have the understanding of how to manage, of how to provide stronger perspective to these organizations from a financial perspective, as well as from an operational perspective. And again, the third be effective oversight and as I talked about before, in BC third party audits, three to five monitors are required for both financial and non-financial information. And I think that's provided effective oversight for the new organizations that are doing what they were intended to do in their group. In terms of what's next, I'm just going to add these as quickly and then happen to take any questions. Well, it's great to have a program that's been up and running for 25 years. We're conscious that consumers are changing. And so we decided to change our basic core model. So we moved away from the system where consumers need to come to a depot and sort their containers and sand lines and put a deposit.  The containers are then sorted and counted as a depot. And then their refund is actually uploaded to an online account they've created through our program. Once that account reaches $10, consumers are able to redeem their refund through an online, through the electronic funds transfer and emailing transfer. We found huge increased satisfaction with that program. And over this past year, we've actually got 40,000 registrants for the goal of having 100,000 registrants in the program right next year. Just want to give you an idea. This is actually a depot in the Yale Town area in downtown Vancouver. So the surrounding area for this depot would all be 20 story plus condo buildings. It's actually in the bottom of a condo building. The depot size is about 700 square feet and people can only drop off, express or bag containers and there are no cash refunds. So all the refunds are done by emailing transfer. Now, the thing we've done is express and go, which is intentionally taking a decantor and revamping it as a depot. This smaller format is something we're hoping to use for rural areas that don't have the population to actually warrant or support a full-time depot. So these decantators offer access to the community and can be cleaned out once or twice a week and don't have to be stopped. And we think this smaller format, again, will be not only for smaller rural regions, but also in dense urban regions where it's just not, we're just not able to access a commercial location to locate a depot. And then finally, we introduced a tech talk collection. So part of our program is trying to make the punch use of the shared infrastructure we have. We have this network of 171 depots. So on our own, when this is not done through the yard, but actually a voluntary program that we've put forward, we've actually developed a tech talk collection program. We now have 40 participating locations all in the lower mainland for the Vancouver area. And in the six months we've had the program, we've already collected 1,200 bags and diverted 20 metric tons from tech talk. And we're hoping to double or triple out the next year. And if you have any more information, you can go to our website, returners.ca, lots of information, not only about our benefits program, as well as our electronics, major clients, and tech talk programs as well. Great, that was very helpful. And I have a quick question. So if you were talking about sort of their reverse supply chain model, can you say a little more about that? How it works? I mean, is it through the governance council? What's the sort of the flow of information in terms of making it a successful model? So in terms of reverse supply chain, it's really just, you know, when the, what you're trying to do is the challenge with recycling for the most part is it's being done in an ad hoc manner by each municipality in a different way. By creating a supply of reverse supply chain, you develop consistency and standards throughout the system, but allow the system to work in a much more efficient manner. So if I take PPP, Recycling BC as an example, some of the things that have been done is the materialist has been standardized for the entire province. So every municipality works with the same materialist. This means that all the processors know essentially what kind of material they get, and that's gonna be the same amount they're getting material from the north of the province itself or the province or from the local part of the lower mainland. It also means you can treat the material differently if you move through the supply chain. So in the past, you would try to sort everything in one facility because it would have sort of a different pre-collector because it was different material. In the BC system, you can install different materials, you know, it's all the same. And really in the BC system, how to use this supply chain is the materials collected, and then it goes through some sort of consolidation to slowly work and separate it into two streams, paper and in containers. Paper is traditionally bailed and marketed as quickly as possible. And so it would go from that consolidation slowly right to a marketing silly and set off for primarily. The containers would all be bailed and then sent down to one container recycling facility established in New Westminster, which is at the core of the Metro Vancouver area. And all the containers from across the province, roughly 40,000 tons of containers each year would be sorted at that facility into their respective material groups. So the alumina would be sorted in aluminum, gapel top into gapel top, and each of the different plastic categories would be separated into each of the separate category. And many deposit containers that have captured in that system would also be sorted out. And then through the group that we have with the processors that work, so we have for cycle BC, those containers would be returned to our program and we would provide them with the appropriate deposit for that. So I think the idea of the supply chain is to replicate what we often do in the commercial sector, whereas we try and develop these supply chains for distributing and providing this to the network of stores in an efficient manner. The reverse supply chain is just trying to do the reverse. And like other supply chains, trying to standardize and optimize the system to make it work in a more efficient manner. Any other committee questions for Mr. Omdine? All right. So thank you again for your help today. Okay, my pleasure. Have a great day, everyone. Thank you. Thank you. Hi, this is Rachel. Hey, good morning. Yes, we can hear you great. This is Chris Brown. You are on speakerphone in Room 10 in the State House with about 60 other folks and so the floor is yours. Great, well, thank you very much, Mr. Chair, and for this decision. I am a former state legislator from the Newporting Institutes. I now work for the McDonald's Corporation, the government relations for Vermont and the Biotherm landing base. McDonald's is proud to count 20 big restaurants throughout the state of Vermont, where we employ over 2,000 people from rental firms and owners. My comments today will be brief, I promise, but will be syncytically focused on packaging and recycling. Though on another occasion, I can also describe the numbers of Vermont legislature, the executive, policy leaders, this commission, the way in which McDonald's is also working to combat climate change, by setting science-based targets to keep the community leaders our renown commission. So, as you can imagine, we're McDonald's, a pretty big company, and manufacturing and transporting for over 37,000 restaurants in more than 100 countries does require significant national resources, including water, trees, fossil fuels, and more. And how can we work as a company to see that the impact from Vermont and the needs of the world is as small as possible? Well, McDonald's is on something on a sustainability journey, and it has never been as important to consider every step for real policies and practices in our restaurants and throughout the organization. So, why does it matter what McDonald's does? It's just a company. Well, by 2025, the World Bank's destiny of staggering 6 million tons of waste will be purchased every day. Once more, the Alabama Carter Foundation at World Economic Forum predicts that by 2050, oceans will contain more plastics than fish. As the world's largest restaurant company, McDonald's has the responsibility and opportunity to take action on the most pressing social and environmental challenges in the world. We know that our global supply chain can have a significant impact on the planet and will constantly improve in our sourcing, packaging, and transportation processes to lessen that footprint. And as I mentioned, when you operate over 37,000 restaurants in more than 100 countries, there are 6,000 to 8,000 to 59 million people every day, even small changes, and make a difference to even move the needle. Our customers tell us that their number one environmental concerns for us to address in the environmental space is the impact of McDonald's restaurant packaging and waste. And I'm scared today by video and reliance to say that we're listening globally and locally. One of the latest and most tangible steps in an ongoing journey are our 2025 goals to improve our packaging and reduce waste, such that by 2025, 100% of McDonald's gas packaging will come from renewable recycled or certified sources. Also by 2025, our goal is to recycle gas packaging in 100% of McDonald's restaurants. We understand the recycling infrastructure, regulations, and similar behaviors vary from state to state, city to city, country to country, but we plan to be part of the solution wherever we are and how influence power will change. Together with employees, franchisees, and suppliers, the companies and committees use our Scale for Good initiative to make changes that our customers want and that will have a meaningful impact all the community deserves. Our vision is nothing less than transformative. In fact, our sustainable packaging and customer recycling work supports the United Nations sustainable development goal, a global agenda and poverty, protects the planet and human prosperity for all. I will not go into the entire report that this means, but I would like to specifically reference the following goals. Goals 12, responsible consumption and production, goal 14, life of all water, and goal 17, partnerships for the goal and specifically consumer goals recycling are matched directly to the company's Scale for Good initiative. And now before this commission, I wanted to award our packaging recycling journal. This dates back to 25 years ago from the Donald's Establishment Partnership with environmental, with the Environmental Defense Fund. Since the beginning of that partnership, the Donald's not only fades out polystyrene sandwich boxes, but has also significantly reduced our environmental impact by a type of solid waste and streamlining the curable traces. The initiative eliminated more than 300 million miles of packaging, recycled one million tons of orientated boxes and reduced waste by 30% in a decade following the partnership. Then in 2014, the Donald's had its first global role to reduce waste and recycle more. The company joined the World Wildlife Fund's Global Forest and Trade Network program and set up cyber-sourcing projects to store all fiber for packaging or recycle for certified sources by 2020. The Donald's restaurant across 12 of our top 15 markets globally, which of course includes the United States market, has introduced programs and partnerships to reduce litter and increase recycling in our communities. In some communities with recycling and structural regulation, the Donald's restaurants offer customer-facing cycles, but disordering them will collect gas waste and sorted for recycling by encounter. Many of these Donald's restaurants offer environmental messages in their lobbies. As of 2019, 50% of the Donald's gas packaging comes from renewable cycles for certified sources. We've also made significant progress on fiber-based packaging, which comprises the vast majority of what we use. And as of 2018, 70% of the Donald's fiber-based gas packaging comes from certified or recycled sources. Now we are resending our packaging by working with packaging specialists to reduce material volume wherever possible and designing packages to capture the value of materials for recycling, which minimize the cost and environmental impact associated with disposal. And so what do these actions look like? As we work to achieve our 2025 goals, we're setting milestones in any process along the way. We aim to support 100% of fiber-based packaging from all certified recycle sources and as by 2018, we're 70% away from that goal and making more progress every day. From 2018 on, all centrally managed gas packaging is fully out of foam. We are foam-free. It is a requirement now that market do not use foam for any local gas packaging item. While the majority of our foam is renewable years ago, we're proud of this important step as big-leash to raise the bar and our system and the industry. Additionally, we're proud of behind the counter at kitchens and service points, cruiser recycling, used cooking oil, and cardboard, and up to 85% to 90% of the dollar truck costs. And while we've made a lot of progress, there are more recycling challenges to overcome. On the customer side, promoting the site is not always as straightforward as we might think. The recycling infrastructure, regulations, and consumer behavior are varied from city to city and a tremendous variability in how we use every site that's been tracked and measured waste volume, making it different, difficult, to capture and display data. It's gonna take a lot of work, and so we are resolved to be a part of the solution wherever we operate, and help use the lunch change. One of our current challenges is called the Next Gen Up Challenge. In 2018, McDonald joined forces with Starbucks as a convening member of the Next Gen Solution and Cup Challenge to develop a fiber-to-go cup and create a fully and widely cyclical and more sustainable cups in collaboration with closed-loop partners. The Next Gen Cup Challenge has opened supply chain leaders to innovate, solution providers, and anyone with promising solutions to recover some of these cups. The 12 winners were announced in February of this year, and six will now enter an accelerator program to help care for the solution and bring about our Next Gen Cup. In fact, we are setting goals and making progress every day. And one of the world's largest restaurant companies, McDonald's, is that ambitious goal to use less packaging for more values of circularity in our packaging design, drive innovation in sustainable packaging and recycling, and engage millions of customers in the thousands of consumers we call on to adopt recycling behaviors as we want. We're rethinking our packaging as I described in the Next Gen Cup, working with past is a specialist who will use material volume, and we know that these efforts will not be successful unless there is a strong recycling infrastructure. So, to make a note of our progress on our goal one of 2025, 100% McDonald's guest packaging will come from renewable, recyclable and certified sources. We are 70% there. We're fully out of form but we're making our goals or keeping our promises. And in our goal of 2025, to recycle less packaging of 100% of our restaurants, we are now recycling less packaging and estimating 10% of McDonald's restaurants around the world, and some markets will decide on the annual 100% of our location. I don't have this number to write out for the line, but I will get this with the name of the guest, I just didn't get it, I'm just kidding. So I apologize, I will get it. This results in the recycling infrastructure used to take care of your regulations through the data variability results in us to happen. Some of it's more challenging than we may like, and through the line, I'm sure we captured my data as possible and used best practices that we've seen in our various learnings. And in summary, we are always looking to improve our big volume, and all of our environmental practices. The initiative goal is demonstrating our commitment to Vermont and wherever we do business to making environment stewardship synonymous with the McDonald's brand.  The opportunity is now looking forward to showing you what's next and working with members of the commission and people in Vermont from all sectors of policy and advocacy and hopefully at all the other goals. So I'm happy to answer any questions if I can, but I really appreciate the ability to tell you what we're doing at the 70 dollars. Thank you very much. We do have some questions here. Lauren. Hi, thanks so much for calling in and for sharing what you're working on. One question I had that is part of the charge of this group that I didn't hear reference about is the intersection with the use of toxic chemicals in packaging. And we know for example that PFAS chemicals which we've had some PFAS water contamination issues in Vermont as the entire nation and globally struggling with. No, just curious what your, do know if there's PFAS. If you're moving to a lot of paper often that's coated with a PFAS containing coding and just curious what you can share about how that plays into your sustainability goals and requirements and is that an issue that you're also addressing as you address this? Yeah, thank you. Mary, you can imagine I actually look at lots of different bills from all over the country in particular in New Orleans. And any time there's been a PFAS bill it's never been a bill that affects anything that we're doing at McDonald's. So we are more advanced in a lot of other companies. But I can get you a little more specific that any PFAS anywhere is sort of where we fit with some of the measures that some of the legislation and that your commission is trying to get to. This is Chris. I have a question about use of post-consumer waste in your packaging. So does McDonald's get our all, is all your packaging created by others?  I think it's mostly with supply partners and we're always challenging our supply partners to be as progressive as they can on environmental packaging. I think it's safe to say that among companies certainly major American companies that we are the way in having the most and the most sustainable and up-to-date packaging. There's lists, I can probably speak to your staff offline if you have anything more specific. But in general, it's not so vertical that we don't use our supply partners. Sure, and I think we've talked to some about kind of the chicken and egg problem of having post-consumer waste valued enough to become sustainable in terms of economics. And so one side of the equation is looking at packaging that's created with a post-consumer waste specification. So it ends up driving the market and then sustaining the recycling industry that partners with it. And I'm just wondering if in your work as you move to more post-consumer waste or more recycled content, if your dialogue basically with your vendors saying we want a higher specification, a higher percentage, can you create such a product? Are you helping design the packaging that's created before you that way? Very much so. And we're trying to get ahead of it and lead with some of the best technology on post-consumer materials from what I saw on yesterday with the sustainability person. A lot of states in some of my, I'm doing a lot of municipal regulations and we have a connection with the exception of a total ban on straw. If there was a total ban on plastic straws around the country, there aren't enough alternative straws being produced on planet Earth to supply all the materials at this moment in time. We are working on alternative straws as well and trying to lead in that space as we're beginning to meet them town by town or in some cases. And I don't think it'll be safe by ban on straws. So some of it is just keeping up with the ability to supply and technology when we want to be as a hand-on as we can be. So far, supply chain has met in the municipal regs and some of them have been pretty strange. And as Vermont moves forward from your perspective, what can Vermont do while we're intent on making progress that's helpful to the corporation like McDonald's? What sort of the productive route we can pursue versus one that you would call challenging or problematic? Well, one of the ways that I think we've added to the dialogue is in trying to describe our journey, for example, and this is a practicing aside from that, but manually, manually came up restaurant industry all over the country, various programs about doing it and what kind of liability would there be? McDonald's moved years ahead of time and did all this manually and then started to resource to other restaurant chains and other entities who were grappling with that, say, hey, it wasn't so bad, we did it and trying to move policy when we already discovered practice and a journey, particularly if it matches with the company's values. And the company's values is to be a progressive company environmentally now lean and be a part of the solution and the climate change, some of the climate change issues, particularly not in practice with some of the large scale things that are happening for another day, but how we can share our experience as you're trying to pass a legislation or policies that we already experienced with, we're happy to share that with our colleagues in the sense. Okay, great. Any other, any questions? Rachel, Andy, I have a question for you. So we've had some discussion within the group or within the working group around reusability and trying to force establishments to your reusable utensils and containers.  That does, because in the last, there are a lot of food safety measures that McDonald's get used to that are part of our practices and even just some health codes that are variable. It depends, but when we have had reusable on a bag, we push against that because of the health concerns. But it's something I'm happy to talk to you to members of the community about more extensively because I think the company's response to a lot of things is like, well, maybe not now, maybe not maybe it's one guy, yes, and how can we possibly get there? So we're open to other steps of discussion, but yes, it has problems, it's a problem. Yeah. I have another question. Yeah, Catherine James, I'm going to E.C. So with things such a large global restaurant that does generate so much material that can get out into the environment, what is the single best thing McDonald's can do to make sure that when the material leaves the McDonald's restaurant, it will not cause an environmental impact? Well, it's the sum of what I described we're just sort of just practices that we have our restaurant actually here to. It's the kind of a big subject that is... Right, but recyclability is not going to solve that and that plastics will break down into microplastics or nanoplastics. So just being able to have recyclable plastics won't solve that. And so that's one of the things, one of the charges of this group is to make sure that these materials minimize environmental impact. Yeah. And we're looking for solutions. Yeah, well I'm happy to go to some of my colleagues in sustainability in case they have more specific ideas in mind, but I did sort of a multi-prong approach. Better materials, more recyclable, and fewer materials. Right, fewer is important. Fewer is a good goal and there's plenty of disposable out there in the world and we don't want to add more. Any other committee questions? All right. Well, thank you very much for zooming in today. Well, thank you for letting me zoom in. I will be there again in person. Well, thank you so much. Have a good day. Right. Hello. Hello. Well, thank you very much for the opportunity to speak today to the single use products for King Group. My name is Katie Riley. I work for the consumer technology presentation. There you go. Can I have your presentation? It didn't stick in the system, so it didn't print it. But we fixed it, and so now it is. Everyone has a copy. Okay, well there's not a whole lot on the presentation. There were just kind of general slides. So sorry, there's going to be a paper copy of this. We'll have to do some ways. Yeah. Thank you. Sorry about that. It's not the first irony that happened to you, right? I know we'll have you all say it. Usually it's legislator-in-views, so. Okay, thank you. And there's more coming for the table. Okay, you got it. All right. Well, thank you again for the opportunity to speak here today and for the working group. My name is Katie Riley. I work for the consumer technology association. We go by the name of CTA. I submitted longer comments. Hopefully you all have a copy of those. So I'm going to keep my testimony today. I only have about 10 minutes. I'm going to keep it a little more focused than what I elaborate on in the written comments themselves. But I guess if you want to turn the page to you, a quick introduction to who CTA is. So we are the trade association that represents the U.S. consumer technology industry. Like I was saying, we are the trade association that represents the U.S. consumer technology industry. We are members of the world's leading innovators from startup companies to a lot of the global brands that you guys probably know and use on a daily basis. We help support more than 18 million jobs here in the U.S. Our members have long been recognized for their commitment to leadership and innovation and sustainability, often taking measures to exceed regulatory requirements on environmental design, energy efficiency, and product and packaging stewardship. So I go into a little more length in my written comments but I just wanted to start off with a slide that shows sort of the four major areas of consideration that our members take into account when designing packaging for their consumer electronic devices. There are two that I really want to focus on specifically for my short time today. The first is the overarching concern in the consumer technology industry as a durable goods industry that packaging must protect the high value products that we're shipping out. When we're talking about shipping servers to businesses that cost tens of thousands of dollars or we're talking about that high value laptop that's going to a consumer's home, the fact that that packaging has to serve the role of protecting the product is of the utmost importance to our member companies. Additionally, for small, small high value electronic devices, packaging also does serve the role of product protection from the perspective of theft. We want to make sure in a retail setting that those high value smaller devices aren't stolen off of retail store shelves. And then the second consideration that I wanted to touch on was the bottom right of sustainability. So over time, as an industry, our products or electronic devices have gotten lighter and smaller, which means that in general we've seen a significant reduction in the use of packaging among our member companies. In addition, our members have made a lot of voluntary goals to make their packaging more sustainable. So whether that's sustainably sourced materials, whether that's recyclability and compost goals, whether they're looking at it from a greenhouse gas emissions reduction. In my written testimony, and hopefully if you go online and look at it, you'll see links to our sustainability report for CTA, where you can gain a little more information on what some individual companies are doing. But given both of these two considerations that are the utmost importance, we really look at them together, product protection and sustainability together. And that's because it plays an important role in reducing the environmental costs that occur when a product's actually damaged. So damage goods from the consumer technology industry, they can have 10 times minimum the environmental costs when those products were damaged from a carbon footprint standpoint. So that's why it's so important from us to ensure that high value items like this don't get damaged and transport. I'll kind of gloss over this page. I believe we're actually gonna hear from the recycling partnership after my presentation today. But these are just a couple examples of some of the voluntary industry supported efforts that are happening when we talk about packaging in general. If you have any specific questions about any of these organizations or the work that they're doing, I'm happy to follow up after this meeting as well on those. But what I really wanted to come here today and touch on a little bit, and Kathy, I'm sure you're pretty aware of this, is I wanted to bring the perspective of to address, extend and produce a responsibility. And given that one of the focuses of this task force or this working group is to examine whether an EPR program would improve the management of single use products in Vermont. I really wanted to bring our industry's experience here today to share with you all. So as you can see from this map, we have 24 states, including Vermont, plus the District of Columbia that have implemented EPR programs for electronics. I think it's safe to say we are the industry with the most experience with EPR here in the US. And what we've seen is a padlock of laws, each one varying in scope, significantly in some cases, that have proven both costly and inefficient across jurisdictions for the electronics industry. We've spent well over a billion dollars complying with these various laws. And our key takeaway from that experience is that we do strongly caution against a state-by-state approach for managing packaging materials similar to what we've seen with electronics. So our experience has found that EPR programs oftentimes do have some unintended consequences of putting extreme pressure on local recycling markets. These adverse effects that we've seen on these local markets have had some long-term negative impacts on long-term sustainability of local recycling jobs around the country. Local governments must typically surrender control over their collection and recycling systems. And additionally, EPR structures, they operate outside the normal market influences. So what we see is the resulting winners and losers are being chosen by stewardship organizations and leaving others unable to operate outside the structures that these EPR programs create. Ultimately, this lack of market forces with EPR tends to lead to higher cost for the collection and recycling system as a whole. Specific to Vermont, since we are here today, it's a great example, the Vermont Electronic Waste Program or Vermont E-Cycles Program, which we use the proper term, has one of the highest per pound rates in the country that we see among these programs. And because the Vermont system is not market-based, the Department of Environmental Conservation, they have sole control over selecting the program administrator and recyclers under the state standard plan. DEC approves the price for recycling based on submitted applications, not market pricing. And then the program builds manufacturers at non-competitive rates. The Vermont Collection Infrastructure, and I actually used to work for one of the recyclers that participated in the Vermont State Standard Plan, and the Collection Infrastructure for Electronics is some of the costliest in the US with no incentive for collectors to strive for efficiencies. And so this isn't a pattern that's necessarily unique to Vermont, I will say that. We have seen this in other similarly structured programs here in the US, but additionally, and thankfully, this does not happen in Vermont, but we've also seen where EPR programs in other states have ended up approving recyclers under their programs that have gone out of business and abandoned path of RayTube or CRT stockpiles. So I just kind of want to stress with all of this that EPR does not always equate to an effective or an efficient system. Proponents of EPR also argue that the program does lead to product redesign. As an industry, in our experience with EPR, we've not seen it drive design for the environment. Progress on this front has been specifically connected to product innovation, consumer demand and preference, and companies' commitments to reduce hazardous material. So CTI in conjunction with Staples, we've been working with the Rochester Institute of Technology as Galasano Institute for Sustainability. And what we've actually found is that while the number of consumer electronic devices sold has actually continued to increase, the net material impact of those devices has actually gone down over time. It is now down at levels that we haven't seen since the early 1990s. RIT also reported that materials of concern, lead and mercury have significantly declined even though the general overall material profile has remained relatively steady among our products. So I just want to stress that these achievements have been driven by innovation and advancements among the industry, not as a result of our industry having to pay for collection and recycling of electronics across multiple jurisdictions. Lastly, I do kind of want to point out that product stewardship does little to can change consumer behavior. Product stewardship is not free. I don't know if you know that, but I was sitting here today. But where manufacturers can consumers do end up paying for recycling through the cost of the products they purchase, plus any premium market as those products move through the distribution and retail channels. A concern that we have with product stewardship is that consumers then aren't necessarily directly engaged and actively participating to understand how the recycling system itself works. Hidden fees and equitable distribution change markups this kind of sends the wrong message to consumers in our opinion that recycling is free and we're not creating that ethos that's really needed to support a robust consumer recycling program. So my next slide just kind of addresses some of the challenges of the Vermont E-Cycles program. I already addressed those in my conversation. I do want to note a lot of these challenges are not unique just to Vermont. I'm not picking on Vermont's program as I'm sitting here. We do see them in many other states and manufacturers are trying to be proactive. They're currently reaching out to DEC as well as some of the other state programs with concerns and ideas about how to help modernize these programs to help make them more cost-effective and efficient. But lastly I wanted to wrap up talking about my experience serving on the Connecticut Task Force that was tasked with studying methods for reducing consumer packaging that generates solid waste in Connecticut. This task force was established in 2016. We wrapped up our recommendations and released those in February of 2018. I kind of want to talk through the process a little bit. It was a very well thought out and structured task force. We had over a year of stakeholder meetings in which we heard from stakeholders expert testimony, public comments. We structured it so that at each meeting we heard from different stakeholder groups including local governments, industry which included packaging producers, trade associations and product manufacturers, the NGO community, academia, EPR program representatives from Canada and Europe, as well as the waste and recycling community both national and local. And the testimony focused on the impacts of an experience with EPR as well as alternative programs and policy options for managing and reducing packaging. And really the key finding of this task force was we are one of the key findings of the task force was that we did not recommend product stewardship as means of reducing consumer packaging that generates solid waste in Connecticut. I handful of the concerns you can see them up here. We were worried about creation of a recycling monopoly. We were worried about pushing Connecticut recycling firms out of business. We were worried about increasing costs on the entire collection recycling system as a whole. But one of the other things I also wanted to stress is there was general acknowledgement among all task force members that a state by state approach would not achieve the results touted under other EPR programs and other jurisdictions specifically Canada and Europe where the US tends to look. State by state approach would not achieve those achievements that we see under some of these other programs. And I think that's really a key concept to keep in mind here. I do want to stress, you know, we spent a lot of time in significant resources as a task force member like you all. I spent a lot of time researching various policy options including product stewardship, prepared questions for the experts that came before our committee. It did a lot of follow up research as well. And some of the concerns that I raised were surrounding the potential economic impact and costs of an EPR program. So some of those concerns, again, I'll end in my written comments, but we didn't have a full analysis of the costs associated with the product stewardship system for Connecticut. There was no understanding of what the full cost of the system was going to be or any cost savings to local governments. We didn't know the full cost of the current collection recycling system as a whole in Connecticut either. So we couldn't understand if a product stewardship program would achieve any increased efficiencies or create any type of economies of scales there. Other industries that were currently complying with product stewardship laws, not just electronics, but we also have paint and mattresses and carpet. They stressed that showing the cost to consumers actually sends a signal to the buyer that recycling is not free and something that they felt was important for creating that consumer recycling ethos. And lastly, while acknowledging that an EPR system for packaging could theoretically have a potential to incentivize product design, one of our co-chairmen did note that Connecticut alone would not have an impact on design because it's such a small portion of the country as well. So these are just some of the concerns and arguments that I want you all to keep at the forefront of your mind as you continue your work as a working group, because I think a lot of these same arguments and concerns translate over here to Connecticut as well. And we encourage you to explore all policy options and take a deep dive into cost assessments and economic impact analysis of what these programs could really mean for the state of Vermont and businesses that are doing work here. So I appreciate your time. I thank you very much and I'm happy to answer any questions if any of you have any. Sure. So I don't want to get into a debate about the E-Lays program per se, but we do have market-based pricing in that our contract goes out to an R&P that is competitively good and the manufacturers do have an opportunity throughout the law to participate and have a room program through your opt-out. But let's put that aside. When that program was created in 2010, the electronics manufacturers were presented an opportunity or an option to manage the program on their own. They declined. They said, no, thank you. We don't want to cooperate or collaborate together. So the legislature chose to have a program that the state implemented. So my question to you today is would your manufacturers be interested in having a pilot program in Vermont where we are looking at an EDR program or an EDR-like program where we are managing the single-use products? Rather than have that pilot project like Painkare did so that you don't get the patchwork of 24 different programs throughout the country, but Painkare saw what happened to E-Lays and then they were strategic and they piloted it out in three states in EDR program and they're replicating that same program throughout the country. So they don't have to manage those things. So my question to manufacturers are, are you willing to pilot the program? I can't say that at this point in time if we are or if we aren't. I will say obviously, the discussions around E-Waste, we had a lot of division among the industry as these programs were initially being discussed and talked about. So I'm just here several 10 plus years later to talk about what our experience is with what resulted from I think some of the inability at times of industry to come together and decide to have the opportunity to forward it. The reality, yeah, the reality is we're the, what's up guys, the dog wagging the tail wagging the dog. The consumer technology industry, we're just a small component when we come to the discussions of the overall packaging industry. I think there's a lot of discussions and maybe that's a great opportunity as part of this working group to have more representatives from the overall consumer product goods industry to come together and talk about whether or not that is a viable option, whether or not having them, if there's any interest in sitting down and looking at a pilot type program. Unfortunately, I think in this scenario, consumer technology is not necessarily the one that's going to be driving it given that we're, you know, the packaging that we put on the market is such a small component of I think what we're talking about among this overall working group. But it's an interesting idea and I think it's a good food for thought to take back to a lot of the trade associations. I mean, another strategy to address or patchwork is to go to the federal government and ask for national legislation. Is your organization working at the federal level to have a uniform standard? So we are not at this moment in time. We are speaking with several congressional offices. As you can imagine, there's not a lot happening at the congressional level right now. There is an interest, obviously, in recycling that we are seeing among several of the congressional offices at this point in time. We are talking with them about what options might exist for federal approaches to help manage consumer material, consumer recyclable, specifically packaging. Laura?  I mean, bottom line, do the EPA start EPR? Senate Producers was really states recycling more electronics than the non-EPR states. I can't say that for sure. A lot of states don't track. Well, I mean, the states that they don't have an EPR program are necessarily tracking that data. Would your guess be that they're probably recycling more? Potentially, I don't know. I think it all comes down to the collection and recycling infrastructure. We have some EPR programs. You can go on the Electronic Recycling for Nation Clearinghouse program website. You can see by state what the recycling rate per capita is. But we don't have the information from a majority. We don't have the information from states that don't have EPR programs to know how much they're actually recycling. One of the quick things. You mentioned at one point that how it's not EPR programs that drive things like innovations and you mentioned lead and delivery specifically in design. To me, that was just, that was a good example of EPR can potentially play a role for some things. But I know there's some ideas in front of the group too of still looking at things like vans and other things. There has been quite a bit of legislation around lead and mercury, for example, around which products can contain it. So I think for us all, I think that was a good example of what can EPR realistic would do for us and then what other kind of complimentary strategies might be needed to address that issue. I'll pass because I think it's capturing that question. I'm actually Michelle Morrison on behalf of Jen Holiday. To rephrase Lauren's question, understanding you can't track the success of an EPR program against the state that never had one, can you say that there was a significant difference in the state once they implemented EPR for collection of electronics where they had no EPR program previously? I also have not seen any of the before and after data because again, I don't think a lot of these were traveling before their programs or after their programs. I mean, it is likely that I did increase the amount of material that was collected or it's just that now it's actually being tracked. But I think a lot of the questions also come down to what are the costs associated with the different types of programs and structures that are under these programs? Where can we be? I think our industry right now is focused on where can we find efficiencies in collection infrastructure and how we can support sustainable programs is really our key focus at most of our time. And I would be happy to send you Vermont because when we did deny that the EPR program didn't increase three times, threefold. Gotcha, I worked for this percent. Yeah, I just worked for the state of Indiana of their electronic waste recycling program similar to Vermont e-cycles. All those structured differently and state of Indiana never had any data on how many electronics were being collected part of that program going in place. So I think it's very jurisdiction specific. Okay, any other committee questions? Thank you. So one point you stress was the balance between packaging and delivering the product. If you get any analysis on the potential loss to breakage compared to other consumer rates for your industry? Other consumer rates? Yeah, in general, the margin on cost to improve damaged product and what that impact would be. No, we haven't. It's something that we've actually been talking about looking into as well. Obviously, we're a little bit different than shampoo bottle in terms of our product gets damaged. There's a significant environmental impact, cost impact versus that shampoo bottle. Not to putting shampoo bottles under the bus or anything, but we're coming at it from the perspective of the durable goods industry. And I think there is a distinction when you're talking about shipping and durable good versus a consumable good. But at the same time, there are life cycle impacts of any product, whether it's shampoo or whether it's a laptop that you're gonna experience from the other product as a result of insufficient packaging. Thank you very much. Thank you. This is Dylan. Hi Dylan, this is Chris Bray. I'm calling you from room 10 of Vermont State House. There's a speaker phone and about 60 of us here from any of 10 and a room full of people. And sorry, we're running just a little behind. Really okay. We'll be getting your presentation distributed to people around the room and table. And we have it up on our PowerPoint. So the floor is yours, take it away if you call out slide changes. Mike on our end will keep pace. Terrific. Well, thank you so much. I'm honored to be able to participate in this working group. And I'm grateful for the opportunity to speak to everybody there today. Like again, thank you again very much for including us. I'm gonna kind of step back and say who we are. My name is Dylan DeThomas. I'm VP for industry collaboration for the recycling partnership. The recycling partnership is a national nonprofit 501C3 dedicated to do what this says there on the screen is transforming recycling for good. Maybe you can go to the next slide and I can show who makes us up. We're an industry-funded group of big brands like Hope and Pepsi and big retailers like Amazon and Target. And then all of the various folks that main goal the various things that go on the store shelves that we want to be able to put back into the recycling system. And we really have a lot of different stakeholder groups, obviously a lot of plastics but we have a lot of paper. We have a lot of metal, even a little bit of glass as represented to help support our mission. You go to our next slide. And we were formed to get at this central challenge which is that roughly half the U.S. doesn't have the same level of access to recycling as they do to the trash. And then those that do have access to recycling are only recycling half of what they can as the household. And so that's roughly what we were created to try to fix. If you can switch actually and switch one slide and then switch to the next slide we're gonna give a little bit of context on our working model. We do that through four distinct work streams. The primary work stream where a good deal or funding goes is the infrastructure. We give grants to communities to help cart them. So either bring them from no recycling to recycling or to switch from the little 18 gallon tows to larger easy to use 96 gallon roll carts. We also giving grants for trucks and we are currently trying to identify communities that we can give grants for, transfer stations. And then we also offer expert assistance. A great deal of the U.S. Recycling coordinators don't just manage recycling in their community. Oftentimes the guys in charge of gals in charge of recycling is also in charge of rabbit raccoons and we try to make it easy on them and we give them as much help as we can. And we have a robust set of free tools and project plans and best management practices available on our website, recyclingpervorship.org. And all of the work that we do there is supported by a robust data sets where we have as iterated and tested the work that we've done to be able to improve it. And then lastly, we always try to work within the entire system. Recycling is not a thing. It's not just when you put a can or a box into the cart, but it's an entire supply team. And we want to make sure that that entire supply chain is healthy so the recycling system can work better. The next slide gets into a little bit of our economic impacts of $43 million of new infrastructure with city matching. That's what we always have leveraged grants. We give the dollars for the communities to help this day and then unlock those private dollars rather to be able to put the carts and trucks on the ground. And then you can see a little bit of the other dollar amounts impact. And we've worked, if you could go to the next slide, we've worked in over 1,000 communities around the US just impacted more than 15 million households. We've placed, actually this number is outdated. We've placed more than a half a million recycling carts around the United States and have that boost in both recycling and obviously the environmental impact that results from positive environmental impact that results from recycling as you've grown. If you could go to the next slide.  The US is obviously very big and this gives a little picture of where we are doing our work. Some of those places are, those aforementioned infrastructure grants. And then some is obviously one of the big challenges that I'm sure as folks in the room have been talking about this morning, the challenges surrounding contamination and recycling. So people who are recycling things are not recyclable. We have a lot of tools and best managed practices and programs out there to help reduce contamination. And then also working at a regional or state level to help improve recycling system change. And then obviously connect folks, we often at different conferences around the country who bring together recycling professionals to be able to help improve recycling to share those practices and ideas from different regions of the United States. The first is one of our largest programs working with Atlanta. We have watched recently a three year, four million dollar program in support from the Coca-Cola Foundation. And this is primarily not an infrastructure project but rather a quality project. There's a little bit of infrastructure helping make sure that all residents in the Atlanta area have carts. But for the vast majority of it is to help improve the recycling that is occurring in Atlanta. And we are doing cart tagging, which is those little carts that you can see there where people are walking out ahead of the recycling trucks to make sure that what they're putting in the cart is appropriate. One of the biggest challenges in Atlanta is bagged recyclables because we found that at the sortation facilities in Atlanta, if they have a bag of recyclables, they treat it the same as if it's a bag of trash because they don't know what's in it. And it can go further to town in the loads and so those are discarded. And so a great deal of the work is trying to get those recyclables into the cart that's loose. And we've had a great deal of success we're currently working on that right now, also said in a three year program. And similar work to the work that I just described in Atlanta is occurring statewide in Ohio. We've partnered with the Ohio Environmental Protection Agency to be able to work with the large cities in Ohio to do that same work, we're partnered with Rivers and haulers, or sorry Rivers being those sortation facilities, material recovery facilities and haulers in those cities to be able to do the same work. And the exciting thing there is that the verse themselves are testing the effectiveness of that work and they've all seen roughly 40% reduction in contamination rates. And seems a real great success there and we're going to be building out that project again working statewide in Ohio over the next year. We also are always trying to, not just in reduced contamination but also again move those carts, we have roughly a million dollars that we're giving to carts to communities that are on waterways and one of those is Sarasota, Florida. And not just giving carts, so they used to have bins that were loose. So the recyclables, if a wind came by it escaped into the marine or other wise environment. So the carts obviously have lids and are able to stay closed and they're one of those communities. We also have done some coastal cleanup in Sarasota as well as some anti-contamination work. And then we are also trying to increase participation. So this is where the behalf of the residents that are still throwing out recyclables, this is trying to increase participation in recycling. We've done a similar work in Denver. We're working in Newark which is a dual stream community and working piloting program in 50,000 communities just started a few weeks ago. And our goal is to increase participation by 10% as well as raise recycling awareness in the community. And those results aren't back yet but it's worked hard on in those communities in Newark. It's measured matters and we work very hard with the communities that we work with but also other communities to help measure the success or lack thereof of their recycling programs. This is a partnership we did with a software company called Retrack Connect called the Municipal Measurement Program. It's a free tool that allows communities, any community anywhere to track so they can make sure that they can compare their success to other communities and make sure that they're preparing apples to apples as opposed to apples and pretzels. And that just gives a little free tool there of late. And then that's a brief overview of what we do. We've done quite a bit as I mentioned across the United States but it's also a big country and there's a lot of work still to be done and we've worked lightly with Vermont in the past. I know that they've used a few of our tools in the past that downloaded some of the things that we've used and we would welcome any other partnership availabilities that would come our way. It will be at the American Conference next week in province as I'm sure a number of folks from Vermont will be there and I'd be happy to answer any questions. Great. Any questions from the committee? I have one quick one. I mean, I know that your organization's about recycling. In the scheme of things, we're also talking about reducing from the outset. Do you play any role in with your partner organizations in going upstream to try to reduce the volume of material that needs to be recycled? Yeah, that's a great question. Obviously recycling is the third on the waste hierarchy and obviously an important part of what we would hope to be the circular economy and reproduction and reuse are ahead of it. We are focused currently on recycling just because that's how the system is currently set up but it is something that we work hard to support and we work with states like the state of Oregon, their sustainable materials management, the roadway pathways at 2050. We support any states or cities that are able to work on reduction and reuse but we don't currently have programs because again, we are the recycling partnership and work with existing solid waste systems and there aren't a great deal of solid waste systems that deal with reduction and reuse. So those are a lot of words to say no, we don't work in that space, sorry about that. Okay, thank you, Kathy. Sure, are you aware of any Vermont municipalities that have received funding from your organization for infrastructure? No, that's a great question. I don't have a list of all the municipalities that have applied for funding but I don't believe Vermont is on that list currently. Our grants or the carts in particular are open for any community to apply and we are, apologies, sorry, I got a chemical on at the same time but I know that Vermont communities have used our tools that we have available on our website but I don't believe they've applied for funds that they would be eligible to. Thank you. We have another question. I'm curious as to whether recycling partnership is doing any work on hard to recycle materials in particular outside of the commonly recycled and recovered material. I'm sorry, you broke up a little bit. Could you repeat that, please? I'm curious as to whether recycling partnership is doing any work on capturing hard to recycle materials apart from the normal fibers and containers and packaging that we're already capturing pretty well. Yeah, that's a great question. So I did not share that slide. We did recently launch an initiative called the Film and Flexibles Task Force that is working with both existing and potential programs to be able to capture those materials, film being like overwrap on toilet paper or your plastic shopping bags and then flexibles which are termed as like the pouches that we see at grocery stores a lot and we're working with different programs to be able to figure out how we can recover those bags. Currently, that is definitely not in the curbside system and for the film part of it, trying to get those returned to retail and also really bolster the infrastructure to make sure that the return to retail pathway is actually supported by the retail establishments. We're currently doing work in Seattle they are pulling film out of their curbside program and going to be putting it into the return to retail and we're helping make sure that those retail establishments happen. We are also working, we announced a big report today called the Breach Circularity that discusses we're going to be developing with other industry partners to find a pathway to recyclability for items that are currently not captured by the system but that is, we just made that announcement today I don't want to say that we're doing it we are calling to other organizations like the Sustainable Packaging Coalition like the Association of Plastic Recyclers to be able to support research and infrastructure investments so those hard to recycle items like tubes or small format materials or film and flexibles to be able to get into the system in some path. Great. Well thank you very much for calling in today and your presentation. Thank you so much for having me it was a pleasure and please if there are any follow up questions I believe my contact information might have and reach out and I'm sure you'll be happy to follow up with anybody in the room. Thank you. Good afternoon. Good afternoon and thank you for the opportunity to come to Vermont which is always a pleasure to testify. My bio was on the last slide in my power plant but I want to give you just a brief introduction. My name is Jazz Miller. I have my own little recycling consulting firm I retired after 40 years plus in the business. Thanks. Started in 1976 the US EPA in their source separation program which was the first attempt by the federal government to advocate recycling. Worked at EPA for over a decade in both recycling and noise-related issues worked in the glass packaging industry as the director of recycling and spent my last quarter of a century working for the National Waste and Recycling Association working primarily on recycling issues but not exclusively. And interestingly enough I'm also the chairman of my home county's Aiming for Zero Waste Task Force. So living this issue every day as we try to increase the recycling rate in our county. Now during these hearings you've heard a lot from many speakers about extending producer responsibility for paper and packaging. And I want to make it clear that EPR has a place for some products. Sharps come to mind immediately. They're dangerous. They're generated several times a day by their users and they have a very small number of producers. They are the perfect product for product stewardship. But the bigger question is what problem are we trying to resolve with an EPR program for paper and packaging? For Sharps it's obvious. It's all about safety. What is it for paper and packaging? Are we simply trying to maximize recycling? Or are we trying to minimize environmental emissions in energy use? Now these are the EPR goals that are from Chikathic Jamison's presentation a month ago. And I'd like to look at these a little bit more closely in terms of how they actually play out. Let's start with less toxic. Vermont was one of 19 states to pass the Toxics and Packaging Reduction Act. That law became de facto national law. The European Union liked it so much they adopted it for all of Europe. And in that law the intentional introduction in the packaging of lead, mercury, cadmium and hexavalent chromium. That took care of toxics right there. It's an excellent law. What about product redesign? We're told time and time again that EPR will lead to product redesign. Well, the problem is it doesn't. The Organization of Economic and Corporate Development, OECD, which is a big booster of EPR, has conceded there is no product redesign due to EPR. EPR Canada has conceded there is no EPR. There is no product design due to EPR. EPR began in Europe in 1991. And 20 years later they adopted the disruptor fees. With the idea that the disruptor fees would force and change, they should force the packaging design because they have not seen it. And now the European companies are adopting eco-modulation fees to try to up the ante because EPR failed, the disruptor fees failed, so now they gotta get a third time up at the plate to try it. But this is the fundamental problem. There are many costs that go in designing and making a package. And the EPR fee is one small little aspect of that. If you're making a package, you're looking at raw material costs, you're looking at manufacturing costs, you're looking at transportation costs, and you add those up, the EPR fee just does not have an impact. Now from a company's perspective, essentially, EPR fees may be material as a whole on a product's company, but on an individual package, they are simply totally immaterial. And the companies also see the environmental benefits of lowering their raw material purchases, less extraction emissions, of lowering their manufacturing emissions, and most importantly, of lowering transportation costs and emissions. Yet this fundamental misunderstanding about packaging and costs is embedded in EPR. What about convenient collection opportunities? So to be honest, I'm a little perplexed by that goal. I was debating EPR two weeks ago in Toronto at the Canadian Waste and Recovery Conference. And my debating opponent at that conference talked about rationalizing recycling. And you heard a little bit of that from Al Menden's presentation. Well, when I hear the term rationalizing in case of a business, the first thing that comes to mind is somebody or somewhere is gonna lose a job. And usually when a business gets rationalized, it's a lot of somebody's who lose their jobs, and it's businesses that go out of business. I know that there's a concern here in Vermont over protecting the two MRFs, totally understandable. But this is the question on that issue that you gotta keep in mind. The producer group will pay as little as possible to cover those collection and processing costs. They will not want to write a blank check. In the case of the program in British Columbia, the contracts they offered all the MRFs had a 60-day automatic cancellation period if the PRO decided it wanted to exercise it.  Do you want to sign a contract and buy a machine or an equipment if somebody can pull a plug on you with 60 days notice that comes out of the air? It's kind of a risky place to be, which is why a lot of the MRFs refuse to sign those contracts. Now, one of the thoughts is that if EPR for paper and packaging is adopted by any of the other New England states, New York state, what is to prevent a producer organization from just saying we've got a bigger MRF in the neighboring state, we're going to ship all the recyclables out of Vermont to be processed. Perfectly logical under the control, and you heard Alan Langdon talk about control, that a PRO wants to have, because as far as they're concerned, once they pay that collection price, they own the recyclables. What about finance relief from municipalities and taxpayers? Well, that raises the obvious, congressional taxes be lowered. Are you going to get finance relief to taxpayers if they get the joy of paying twice? One's as taxpayers and one's as consumers. EPR, by its very nature, is a regressive tax, just like a sales tax. It follows most heavily on lower income residents who have to spend a higher proportion of their income on non-discretionary purchases, including food that comes in packages or other consumer goods that comes in packages. Now, let's look at some myths of EPR. Let's start off with the idea of producer groups and industry working together in harmony to solve the problem. That may well work for paint or thermostats. Those are industries with a very small number of producers. You can get them to work together, under the right antitrust protections, of course. But what about packaging? Well, the reality is, in British Columbia you've got 1,200 stewards. You cannot get 1,200 stewards in one room at the same time to work out these problems. In Quebec, you have more than twice as many. So what happens is the producers simply write a check and they leave it up to the staff and the consultants of the staff of that producer organization to actually figure out what they wanna do and how they wanna do it while they're writing the check. And another thing, EPR costs are not just the fee that an EPR program pays. Each producer has their own significant compliance costs that they have to cover as a part of that EPR program. They include the cost of filling out the product reports. They include dealing with auditors from the producer group who quite lovely. The auditor's goal is simply to squeeze as much money as possible out of the producer so the group can have more money to play with. And then constantly revising those reports as product lines and shipments change. Now my presumption is for mom would do like British Columbia and a lot of other places. You're gonna look at the national product distribution for a package and you're just gonna allocate Vermont's share by its percentage of the population. Well, that's always so good but that means say a producer totally changes its products in Texas. Those changes may never see Vermont but it's gonna affect the money that comes into Vermont. And most importantly, I have never heard EPR proponents talk about those compliance costs and the impact they do. But I can tell you right now Vermont businesses will notice them because they'll have to pay them. What about economies of scale? And we're told that a producer group rationalizes so it creates economies of scale and allows a system of lower cost. Well, economies of scale are good. Why don't we just have one grocery chain in the state of Vermont or one gasoline station chain in the state of Vermont. Just think of the economies of scale you will get with that kind of monopoly. But there are a lot of reasons to think that kind of monopoly may not be a good idea. And in fact, in British Columbia the provincial ministry of the environment had an application from a group to compete with what is now recycled British Columbia and then rejected that application for a number of reasons. One of which, quite frankly, was RBC was too big to fail. It's putting a lot of A's into one basket. There's the method producers pay for recycling. They pay the full cost of recycling. Well, this is the reality. The producer group pays what it thinks is a reasonable cost for collection and processing. A reasonable cost based on the analysis of their consultants and their staff. British Columbia claims to cover the full cost of recycling yet the incentive fee. They call it an incentive fee that they pay to the communities. That incentive fee is based on what they think the cost should be. And in generally, in many cases, it simply does not cover a community's costs. To the point that now the communities in BC have absolutely demanded transparency and how that fee is set because they want more money. They want to cover all their costs. And interestingly enough, the fee was so low that the city of Vancouver simply got out of the recycling business. They turned it all over to recycle British Columbia. Now, in Quebec, Echo Enterprise, I think is much more honest when it simply says that they're responsible for the efficient and effective cost of recycling. They don't claim to be responsible for all of it. But at the same time, they decide which is efficient and effective. And remember, as I said earlier, and you heard it from Mr. Langdon, under EPR, the producers own the recyclables at the point of collection. They want full control of the system and its cost. They will not write a blank check for cost they cannot confirm or control. The idea of producers internalizing costs, but really the spark plug reason for the original EPR programs, but do they internalize it or is it just a pass-through? Something the consumer never knows about. I mean, to remind businesses, this is just another cost of doing business in this state. It's accompanied by the additional compliance costs that I mentioned. It's a hidden cost that will pass on to their consumers who will have no idea they just paid for recycling. And yet, the paint, the mattress, the carpet companies and their retail programs, they are adamant that there be a shown fee so that the buyer knows that there is a cost to recycling and that they have a stake in success for recycling. And is EPR good for the environment? Are we talking about design for recycling? Are we talking about design for the environment and sustainable materials management? Now, several speakers at previous hearings have tried hard to square the circle. They want to encourage recycling to the maximum extent possible, while also encouraging that the environmental benefits are maximized to that maximum extent possible. But you can't do that in every case, in a lot of cases.  Recycling is a manufacturing process. Recycling destroys in order to create, whether it's shredding, whether it's crushing, whether it's grinding, whether it's smelting and melting down. Recycling is an inherently destructive product, excuse me, process that does lead to a new product, and in that process, materials are lost and emissions are created. I love recycling, it does a lot of great work, but we have to be upfront about what recycling really accomplishes and how. And you know, virtually all greenhouse gas is related to consumption because what we have in this country and in North America, this is what I said in Canada two weeks ago, we don't have a waste problem, we have excellent waste management systems. We have a consumption problem, and it's consumption we should be focusing on. And yet if you look at the greenhouse gases caused by our consumption problem, 98, 99% are caused by material extraction, manufacturing and transportation, only one or two percent by disposal. And yet EPR penalizes waste reduction with its emphasis on higher fees for non-recyclable products. Even if those products are greener than the recyclable competitors, that's a real paradox. I've been no recycling for so long, I really had to struggle to wrap my little pea brain about this one, but the data is irrefutable. This is EPA and the environmental impacts of coffee packaging choices. The 100%, if you will, recyclable steel cam, the rigid plastic container and the flexible pouch. The data is very clear, flexible pouch, can't be recycled, everything goes to disposal. Lowest greenhouse gas emissions from cradle to grave, lowest energy use, it even takes up less landfill space than its recyclable competitors. Yet, why are we punishing it because it can't be recycled? Why are we doing this to me? That makes absolutely no sense. You know, do you really want to have more diesel powered semi trucks driving down Vermont's roads so that they can deliver heavier, more recyclable products? I don't think that's progress. I certainly would not want to do my home state of Maryland where I live now. I want to make one thing clear, recycling does a great deal of good. It is absolutely necessary, but it is not the end. It's a way to get there, it's a tool, but it is not the end result. You know, the environment and the universe do not revolve around recycling. They revolve around ways to use less and less raw materials and create lower and lower emissions. That is what we want, and that's what we should try to achieve. So, everybody's finger words from the speaker. In conclusion, packaging is a particularly complicated area when it comes to EPR. Behavior change is absolutely crucial to recycling. To an extent, a producer's responsibility does not change packages, nor does it change individual recycling behavior. It creates a monopoly that is now responsible for collection and repression of traditional recyclables. And you know, one thing you've really got to think to very carefully, what is the goal? What do you want to accomplish here? Because beware of what you wish for. You may get something quite unexpected. Thank you very much for your time. Thank you. Any committee questions? Hi. Hi, John. So, I'm glad you brought up the flexible couch scenario. It's something we've talked about as a group, and I think the focus that we've mentioned as a group is wanting to address how single-use products add to the waste problem in Vermont. And recycling is part of the solution, I think, as you mentioned. And we have mentioned EPR as a way to drive both reducing the number of single-use products that are entering the waste stream, but also making those products and packaging better for the waste stream, whether it be recyclable or if a flex use package. If EPR isn't a way to push or persuade producers to create packaging that helps reduce our waste stream, then what is? Well, I think in the first place, per EPR the effective cost signal to a producer, the fees have to be significantly higher. And what that may well mean when it comes to those flexible packaging, when that fee hits and it is significantly higher, you may find yourself dealing with irate consumers who are furious over the cost increases of the packages they use on a daily basis and don't understand why the cost increases that way. Because again, EPR sends such a small, small, small price signal to a company. They're looking at a much bigger cost to raise. Frankly, if you're into sustainability, you care far more about reducing your overall impact than you do about the number of packages you produce or how recyclable you are. You're looking at that overall environmental goal. So, and what is a single-use product? I saw the definition of the law in that space that's pretty vague.  Magazine, probably. Clearly single-use, but my refillable jug is full of cold-root coffee and I really don't need any more. Yet the work done by the state of Oregon show very clearly that reusable has the best impact. Why do you put tap water in a plastic bottle when you can put it into a refillable container?  To me, it doesn't make any sense. In the other hand, in an action to emergency, everybody loves plastic bottles for water because they fill on a media's need. There will always be single-use products that will be excluded from this law. One is anything health-related. I had the misfortune to have something called cellulitis in June. Don't get it, it involves either a staff or a strep of getting into your system through an open wound. It's not fun. And as I was sitting on that table at the emergency room, seeing with the IV pumping the antibiotics into me, I just thought to myself, you know, I'm so happy that the sharp, that the tube, and the transporter device all came in sterilized individual packages. I didn't want somebody to just pull them out of a bin and say, here, let's use this one, it looks okay. So there will always be exceptions to that. And I think you may be trying to accomplish too much. I have a question on, we've heard a little bit before about the coffee packaging data that you were sharing, but I hadn't seen it all, so thank you for bringing that. Is this representative? I mean, I'm just wondering if it serves as a representative example of many packaging situations or it's unusual and at least makes us ask a question. I think that's a great question to the answer. It's most representative for the products that it examined, which in this case had to be those three. You can do other LCA's for different products that will have a different type of potential packaging, because in this case, you know, flexible packaging is simply not available for all products. And in those cases, you're probably going to get different results. I might add one other thing, this was done by EPA, so I totally trust the conclusions.  And I think in part we're looking at some of this work here as kind of a stitch in time saves nine. How can we help the entire system think ahead so there's less of a problem to manage downstream? Do you not see, are there no opportunities and taking that sort of frame of mind and bringing into this work? First of all, you're asking about predicting the future, the future of packaging. When I started at EPA in 76, do you want to know what everybody was complaining about for recycling? It was groundwood computer printout paper. Now, who here remembers printout paper? Much less groundwood printout paper. Times change, the materials we use change. I don't know how to predict 10 years down the road. I don't know how to predict what the new products are going to be, what the new materials are going to be. And I think that's one fundamental problem that we're all struggling with in these programs. In terms of, we've also looked at post-consumer waste requirements as part of packaging as a way of creating demand for a product that can end up accumulating and becoming problematic. So you create demand for that product and fold it back into new packaging. Is that a way to drive product redesign? When I started at NSW May, Congress was taking its first real luck of packaging and recycling. And in 1994, as an association, they were the only private sector trade association to endorse post-consumer minimum content requirements for newspapers. And we were adamant about that because at the time, newspapers, the biggest thing you collected and we desperately need markets. Now, actually, as it turned out, the industry made enormous investments in the use of secondary content in newsprint. That problem went away. That was unfortunately, over time, did newspapers. But it was, we had great markets for lighter half of the 90s and to about 2010 or so. I think when it comes to post-consumer content requirements, they had no problem with them whatsoever. You've got to figure out a couple of things. First of all, is it simply shifting the markets? For instance, if you require a post-consumer for, say, a PET bottle, will that simply shift the market away from fiber to that PET bottle or will expand the market? Personally, I'm not interested in anything that simply shifts the market. I'm interested in something that expands the market. And secondly, it's a real big mystery about this. What is the loss rate in PET and HTTP and on the plastics recycling? You can figure out, I mean, everybody knows the loss rate for paper. It's seven times and then the fiber is shot. Loss rate for glass, I know from my own experience, is somewhere around 10 to 20% of the glass but that goes in, let's call it, gets lost through the smelting process. I know offhand what the numbers are for plastic or I'm sorry, for steel and for aluminum. Nobody knows what the loss rates are for PET and HTTP or if they know they're not talking. But it's a mechanical process that creates finds, things get lost. That's a good piece of information to know because until you know that number it's harder to know how effective the post-consumer requirements will be. But hey, I'm all for them, if they can expand markets. And then the last good question is, I think quite catch the name of it.  So what's the, if you gave us a short version of what you're aiming for there, does any of it apply to our packaging conversation here? Yes and no. Our charge from our county, exactly when there were seven of us, is very direct and simple. He wants us to eliminate, to increase recycling and recovery to an extent that essentially we send as little as possible to disposal. And he's told us exactly what his goals are county politics, that don't need to get it in now but this is the problem. Essentially it would mean at least, we're 41% recycling now and recovery. Yardways and a very strong dual stream program in the county. We would have to go up to about 60 to 70% to meet his goal. We voted unanimously to continue doing dual stream. I think people either consciously or subconsciously knew that we were trading off quantity for quality. But it was the unanimous vote. We want to stay with dual stream. It's all about food waste in my county. It's all about how do we really increase the food waste because we do virtually nothing in the county. So that is what we're focused on. And we did benchmark, we benchmarked our county against Austin, Minneapolis, Toronto, King County, Washington and San Francisco. And what we discovered from that benchmark is first of all, we only found one, maybe two that actually got to 50% recovery slash recycling. San Francisco, by the way, was not one of those. The real recycling rate is 49%. Forget what they tell you in the press. The real number is 49%. It was King County, Wisconsin, or I'm sorry, King County, Washington was almost at 60%. But like Seattle, they can never quite make it to 60. They've done incredibly good work over the last three decades. They've been very patient, very steady, slowly rolled out their programs. But they still cannot get above 60%. And that's really informed our thinking because we're wondering, what is that realistic goal? And where do you get to the point where you simply run out of recovery options because people are people or whatever, that you're just, you're running into reality, if you will. So to build on that, you commented a couple of times about behavior change. We all know that behavior needs to change. Have you found practices that have worked to change consumer? Are there, is there information out there that shows progress based on changing consumer behavior? We know the curbside works very, very well because everybody sees what their neighbors do.  You don't have that in apartment buildings. You don't have it in public spaces. And we know that we just have not made that cultural shift. So the behavior change occurs in anonymity, not just in broad daylight. That's the problem. Are there incentives though that you're considering that you've talked about? No, but if we come up with some, I'll tell you, I promise. All right, I think that's it. I'm sorry. So with our work group, I think three of the main issues that we're trying to address is we have a significant amount of environmental capacity, a third of our annual study or a single use of products. About half of that third could be recycled if it were put in the right bin. Our recycling costs, just like the rest of the country have stored and we're really struggling with markets, you know, the story there. If you put any more material in our recycling system people are already debating on whether or not they should continue recycling. So that's a stressed system. And we are hearing about the negative environmental and human health impact from single use products and packaging. And while we addressed some of the heavy metals, you know, 10 or 20 years ago, we're concerned with T-foss and other emerging contaminants of concern. So those three big topics are what we're trying to explore. And EPR was one of the tools we were looking at for that, not necessarily to solve all the ills of our system but to help with that cost that's going on. And if there aren't many manufacturers are looking at making more materials recyclable, we need to do something for the system and asking taxpayers to pay more right now isn't one of the better options for us. So what would be your recommendation to solve those issues? Well, in the first place you may be overreaching as much as you're trying to, the goals you're trying to have. That's the first one. In the testimony you had in the hearing a month ago you talked about the mandated recyclables you're getting 72% recovery. The question I would have is what is the overlap between the universe of single use packages and the mandated recyclables? So what is the potential extra recovery you're going to get out of that? Because 72% is a very good rate for mandated recyclables. Suggest that what we are required to put in a loop in the plan, but manufacturers as you know are creating more and more of these materials and different kinds of materials that can't go through our recycling system right now. And I don't think that's going to change. There's two demographic trends you've got to keep in mind. One is the fact that there are twice as many Americans living in single person households today as there were 20 years ago. What does that translate to? It translates to small packages to avoid food waste. And the other one ironically enough is to warn people eating by themselves, even married couples. And that too translates into smaller packages to avoid food waste. I don't know how any government can control or change those kinds of changes because right through what you have are companies who make food products and sell them in the market. They don't want that food to go bad because they had it in the big package that's too big for the user. And you may be asking for too much. Yeah, you said that these are probably new material to manufacturers for EPR. And if that's the case, and if that would help with our recycling system, why not go ahead with that? But will it help with your recycling system? How becomes the next question? It will help with the finances of it. And right now, it's in need of financial help. In that case, I think you have