Definition of recycling

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).

Changes to population and the waste stream 

How has this changed in the past 30 yrs. As our population has grown, are we recycling more per person? Are we generally using more per person? How has the change in materials impacted recycling, contamination rates, waste management costs and total waste?

Source reduction should not be included in recycling rates

This should not be included in recycling rates. It should be included in the report but credits should not factored into recycling rates. Source reduction is critical but SWPUs should have separate minimums in reduction. These economic and environmental impacts would be helpful to have presented. 

Industrial vs consumer

Most litter comes from post consumer waste yet there is no clear information on how much post consumer waste is recycled v landfilled. Metal and yard waste are clearly heavier and more likely to be industrial than household waste so it skews how well consumers recycle. 

Contamination

The report does not explain how contamination or lack of end markets are calculated into the recycling rate. Intent to recycle is not the same as actual recycling. Ultimately, people recycle things that should not be recycled and sometimes there is no market for a material that has been collected. Less valuable recyclables sometimes are landfilled due to virgin material costing less. 

 This report should clarify if the contaminated waste was:

• counted in both categories (recycling and landfill), 

• reported as recycled but not landfilled

• or contamination weights were reported and the total weights for recycling and sw were adjusted accordingly. 

If the contamination rate is not calculated and it is assumed everything that is collected is indeed recycled then many of the calculations would be incorrect. 

1. Contamination or lack of an end market increases emissions and energy use. Items go through transport, sorting, cleaning etc. to ultimately end up in a landfill.

2. Better understanding inefficiencies in the system is critical to determining Virginia’s state of recycling. 

3. How much money is wasted through contamination or lack of end market? Is this calculated into the economic benefits and environmental impacts?

Clarification on this point would highlight the impact of contamination which is an expressed issue raised by Virginia recyclers that manage comingled materials.  

Material Recycling Rates

A shortcoming of this report is that it does not indicate a recycling rate by material. It calculated a breakdown of all recyclables and their share of the total recycling weight. This is quite different from the material recycling rate. 

This provides an incomplete picture of where Virginia’s recycling really stands, in particular when it comes to costly household recycling programs. This is critical information because it informs how well we are actually doing with each material and the potential for growth, material source reduction, or increased financial support from producers of materials to more efficiently process Virginia’s waste.  

1. What materials are processed? What is the rate of recyclability (what materials can be recycled if collected properly vs what materials must be landfilled) of the materials?

2. What percent of a material recovered is ultimately landfilled? 

3. What has no end market? Where are we losing on investment of infrastructure?

4. Where could we be investing in order to better recycle high value materials?