As someone who has worked the last 15 years in Fairfax County on recycling and plastic pollution issues, embedded as a non profit entity within Fairfax County’s Department of Public Works and Environmental Services, and who sat on the Governor’s Plastic Waste Pollution Advisory Council as the only environmentalist, I absolutely agree with the premise that Virginia needs to increase its recycling rate, and the value of that recycling. The question is: how do we do that in a way that is both environmentally and economically friendly? 

Virginia’s recycling systems (and frankly, its streams and sides of the roads) are overwhelmed by plastic, the majority of which is single use and its ability to truly be recycled into something useful is slim. All of this low quality plastic (like film and flimsy single use water bottles) reduces system efficacy and lowers the value of Virginia’s recycled material–the good stuff like metal and cardboard, and paper and glass. 

I would like to suggest that one of the first items that is missing from the DEQ’s report is the EPA’s assessment of Advanced Recycling/Chemical Conversion/Plastic to Fuels. Specifically, the clarification 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” (from the recent EPA Draft National Strategy to Prevent Plastic Pollution). Consistent with this guidance from the foremost national entity on the environment, “advanced recycling” technology is not recycling, and thus should not be part of any economic discussion about recycling in Virginia. 

Secondly it is indeed a shame that the report relied on the Census numbers from 2012 to report out the amount of jobs in recycling and the amount of income recycling brings to Virginia, because between then and now there was this epic recycling disaster that we all know as Operational National Sword (ONS) in 2017. ONS caused the bottom to fall out of recycling as we know it here in the US, which is why the convenient “solution” since has been to simply melt it into fuel stock. But this process of turning waste into fuel derivatives and feedstock is not recycling, for it is not re-generating or re-producing any material to its original form. For those who are still unclear about the difference between a linear and a circular economy, I give you this: a circular process takes a glass bottle or a cardboard box and recycles it back into a glass bottle or a cardboard box. 

Third, it is unfortunate that the report did not go into the value of getting back to our roots–multi stream recycling. I do know how hard it is to get decent data from localities around the Commonwealth (maybe that should be a goal!), because there are several different ways recycling is collected–by the municipality, by private hauler, and by dedicated drop off locations that are serviced by private haulers or localities. But the “Purple Can Club” in Northern Virginia which collects glass dropped off by residents after the localities and haulers stopped picking it up has proven to be a very successful project–because that glass is clean and there is a market for it. Imagine if we had a dedicated collection for cardboard, metal cans, specific PET bottles, etc. that were already sorted for the recycling companies and MRFs? CAN YOU EVEN IMAGINE?! Excuse me while I breathe into a paper bag. 

In many of the discussions hashed out while I was a member of the Plastic Waste Pollution Advisory Council, it seemed we were discussing two very different topics–reducing the amount of plastic pollution, and propping up the recycling industry. And the question always was–are these two issues mutually exclusive? As an environmental advocate I believe that we can work on less plastic on the front end while supporting high quality mechanical recycling on the back end, and support the areas where there is a market for actual recycling (such as cans, paper, cardboard and glass.) And, if industry was truly concerned about plastic pollution, they’d be lining up to support plastic bottle deposit bills all around the country. Which brings me to another interesting omission in this DEQ report: of the states used in this study, only one, Michigan, has a bottle bill (which works hard to collect CLEAN plastic) but the report fails to actually mention that. 

Bolstering markets for glass, metal, cardboard and even plastic recycling markets (while we can quibble on whether recycling plastic bottles into industrial carpet is truly recycling and a circular economy, what we will not capitulate to is whether pyrolysis is recycling) is critical to improving Virginia’s recycling rates. It is our hope that the Commonwealth supports true recycling initiatives and is not controlled by the interests of the plastics and petrochemical industries who cry crocodile tears about the sorry state of recycling while fighting every single attempt to reduce plastic pollution and limit extended producer responsibility.   “Advanced Recycling,” “Plastics to Fuel,” “Pyrolysis,” “Chemical Conversion,” or any number of industry rebranded terms designed to make the process more palatable to legislators and localities, reflect a soft and disingenuous way of saying “using chemicals and heat to melt plastic which then gets burned as fuel.” These terms and technologies should not be promoted by Virginia, ever. 

Thank you for taking Clean Fairfax’s points into consideration as you move forward with rewriting this draft report to support not just the Recycling and fossil fuel/plastics  industries, but the residents of Virginia as well. Surveys have shown that we are at a time when Virginians are willing to pay for better environmental solutions, so it behooves us to lead with solutions, not to follow industry lobbyists down the plastic-strewn path to, well, an Advanced Recycling Facility.