Clean Virginia Waterways acknowledges and values the Department of Environmental Quality's effort to enhance comprehension regarding the environmental and economic impacts of Virginia's recycling system. We have a few comments to help Virginia improve recycling systems.
Increasing Recycling Rates in Virginia
Recycling is intended to be a cyclical process. As stated by the Environmental Protection Agency (EPA), “A circular economy keeps materials, products, and services in circulation for as long as possible.” A true circular economy is dependent on a robust mechanical recycling industry to create a system with minimal waste. Taking this approach to bolster markets for glass, metal, and cardboard recycling markets is critical to improving Virginia’s recycling rates.
Melting plastics to be used as additives for fossil fuels (advanced recycling) is a linear system, and these processes are not considered recycling by the EPA. In fact, the EPA specifically outlines that “Activities that convert non-hazardous solid waste to fuels or fuel substitutes (“plastics-to-fuel”) or for energy production are not considered to be ‘recycling’ activities.” This includes pyrolysis, gasification, chemical conversion, and all other plastic-to-fuel technologies. (Language is modified from the EPA Draft National Strategy to Prevent Plastic Pollution).
Economic burden on taxpayers: The report fails to address the economic burden that recycling programs have on municipalities (taxpayers). Curbside recycling programs are mainly funded by municipalities rather than the producers of the items that are found in recycling. The DEQ report could be strengthened by including data from other states that have policies that have the “polluter pay” through extended producer responsibility requirements.
There are proven policies that reduce the economic burden on localities and strengthen recycling programs. For example, in 2021, Maine signed LD 1541 into law. This legislation is intended to reduce the volume and toxicity as well as increase the recycling of packaging material. Producers of packaging pay into a fund based on the volume and recyclability of their products. The funds generated are used to reimburse localities for recycling and solid waste management activities. This approach is also supported by Virginia voters. In a 2022 Clean Virginia Waterways survey of registered Virginia voters, 71% of registered voters expressed support for policies that shift the costs of recycling programs off of community taxpayers and onto producers. The complete survey results are available on the CVW publications page.
Litter Prevention & Recycling Grants (page 10): The DEQ report could be strengthened by comparing the income of the VA Litter Tax ($2.9 million in FY2023) to other states and communities. Virginia’s Litter Control and Recycling Fund generates the lowest revenue per capita of any state using a similar system. Much of this information can be found in the CVW publication: “Opportunities to Reduce Plastic Pollution: Policy Recommendations & Best Practices for the Virginia Litter Fund” available on the CVW publications webpage.
Plastic Recycling is shockingly low in Virginia: The charts on pages 9 and 10 (CY2021 Principle Recyclable Materials Recycled in Tons) shows that plastics are in 13th place in terms of recycled tons—well behind metal, paper, tires, glass and eight other types of materials. Research by CVW and the Virginia Aquarium & Marine Science Center found that 83% of all debris on Virginia’s shoreline is made of plastic—and most of that is single-use items such as plastic beverage containers, caps, bags, food wrappers, etc. Data collected by volunteers during the statewide “International Coastal Cleanup in Virginia” show that about 85% of littered items are made of plastic.
The DEQ report could be strengthened by doing a comparison of plastic recycling rates in states that have deposits on beverage containers (bottle bills) vs. states like Virginia which do not have recycling refunds for such containers. The consistently low rates of plastic recycled in Virginia is evidence that the Commonwealth would benefit from exploring source reduction (creating less waste), increased mechanical recycling, expanded responsibility from the producers of single-use packaging, and economic incentives to consumers (deposits on beverage containers, for example).
Recycling Credits: Recycling Tax Credits are mentioned on page 11: "For 2022, 38 applications were received from manufacturing and recycling facilities to obtain DEQ certification for the state tax credit." The DEQ report could be strengthened by expanding this section. What companies applied, and are they engaged in mechanical recycling.
State tax credits for recycling should not be available for “plastic to fuel, plastic to fuel additive, or plastic to fuel substitutes” manufacturing. According to the EPA pyrolysis and other plastics-to-fuel technologies are not to be considered recycling, this will make Virginia consistent with the EPA that states: “Activities that convert non-hazardous solid waste to fuels or fuel substitutes (“plastics-to-fuel”) or for energy production are not considered to be “recycling” activities. (Language is modified from the EPA Draft National Strategy to Prevent Plastic Pollution)
Expanding Recycling Access
States across the United States have historically struggled with providing recycling services to underserved and rural communities. Michigan is investing to improve recycling in underserved areas with their Rural and Small Community Recycling and Waste Reduction Program. The program explores viable options for small, rural, and underserved communities to address waste reduction while simultaneously strengthening local markets for recycling collection. Ultimately, the program seeks to empower localities to implement policies that achieve both of these goals.
Given the diversity of communities in Virginia–from highly-populated urban centers to suburbs, coastal towns, and rural farm regions–as well as concern over the increased cost of recycling, it would behoove Virginia to conduct similar investigations into how an aging and inadequate mechanical recycling infrastructure can be updated equitably and economically, instead of shuttered in favor of new, even more costly, false solutions to manage waste.
We encourage continued conversation about how Virginia can improve our recycling infrastructure to benefit human, environmental, and economic health.