welcome to the webinar - carton council
TRANSCRIPT
Welcome to the Webinar:
Policy Tools Driving Post-
Consumer Packaging and Printed
Paper Recovery
July 23, 2014
2 2
Betsy Dorn
Reclay StewardEdge
Scott Mouw
North Carolina Department of
Environment and Natural Resources
Elisabeth Comere
Carton Council & Tetra Pak Inc.
Peder Sandhei
Minnesota Pollution Control Agency
James Short
Delaware Dept. of Natural Resources
and Environmental Control
3 3
But first…Who is the Carton Council?
Carton manufacturers united to deliver long term collaborative
solutions to divert valuable cartons from disposal
Associate Member
4 4
Improving Recycling in
the U.S.
Policy: State and Local
Levels
Improving Access:
End markets, Processing
and Collection
Industry Collaboration
Education to Improve Recovery
Our Comprehensive Approach
5 5
No Silver Bullet – Policy is Only a Piece of the Puzzle
6 6
Why this Webinar?
Carton Council has achieved 50% access however
more work is needed.
Exploring policy’s role as tool for building access
AND recovery.
Purpose of the webinar is to share learnings to
date and hear others’ perspectives.
Webinar will be followed by release of full report
and half-day forum at Resource Recycling
Conference in September in New Orleans.
7 7
Webinar Agenda
I. Overview of Carton Council Research
II. NC Disposal Bans: Giving Recycling a Boost
III. Implementing Delaware’s Universal Recycling
Program and Lessons Learned
IV. Volume Based Pricing and the New Commercial
Recycling Mandate in Minnesota
V. Wrap Up and Q&A
8 8
Overview of Carton Council Policy Research
Focused on state and local level policy and related programs:
o Recycling laws
o Disposal bans
o Pay-as-you-throw (PAYT)
Primary and secondary research including:
o Literature review
o Review of past studies
o Internet research
o Interviews
National research covering all post-consumer
packaging and printed paper materials
conducted by Reclay StewardEdge
9 9
Research Findings
State-level disposal bans in 4 states
Three types of recycling policies in 18 states
PAYT policies in 5 states
Numerous local governments employing policy
tools – with or without overarching state policy
10 10
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P
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Policy Type
Service Provision/Level
Participation/Source Separation
Target/Goal
Disposal Ban
S
P
T
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Disposal Bans & Recycling Policies by State
11 11
State-Level Packaging & Paper Disposal Bans
Jurisdiction Glass Steel Aluminum Plastic Paper(a)
Massachusetts Containers Containers Containers 1-6 Bottles OCC, RP
North Carolina Containers(b)
Containers 1-7 Bottles
Vermont Containers Containers Containers 1-2 Bottles OCC, RP
Wisconsin Containers Containers Containers 1-2 Bottles OCC, ONP, OMG, OP
Notes:
(a) OCC=old corrugated containers, ONP=newspaper, OMG=magazines, OP=office paper, RP=all recyclable paper
(b) Applies only to certain restaurants and bars with alcohol permits
12 12
Types of Recycling Policies
1. Recycling Service Provision:
o Local governments/haulers expected to provide specified
recycling services based on defined criteria
• e.g. population greater than 4,000 or by generator type
2. Recycling Participation/Source Separation:
o Requires source separation of recyclables by all or certain
types of generators
• e.g. single-family, multi-family, commercial
3. Recycling Target/Goal:
o Local governments/state agencies expected to achieve
specified target or goal
• e.g. 50% recycling rate or diversion rate by X year
13 13
State Level Recycling Policies
Jurisdiction Service
Provision/Level
Participation/Source
Separation
Target/
Goal
Material
Specific
Not Material
Specific
Material
Specific
Not Material
Specific
California
Connecticut
Delaware
Florida
Maine
Maryland
Minnesota
New Jersey
New York
North
Carolina
Oregon
Pennsylvania
Rhode Island
Vermont
Virginia
Washington
West Virginia
Wisconsin
14 14
Disposal Bans and Recycling Policies:
Conclusions
State policy can drive local policy and infrastructure
development.
Recycling policies are preferred by states over disposal bans.
Emphasis for bans has been voluntary compliance with threat
of enforcement in background.
Three types of recycling policies equally prevalent and often
used in combination.
State and local policies involve local implementation and
behavior change.
States generally expect local governments and/or haulers to
implement and enforce.
15 15
Disposal Bans and Recycling Policies:
Best Practices
Employ program tools to support policies.
Combine policies and programs for synergistic impact.
Require use of recycling program best practices.
Provide funding, particularly for initial compliance.
Phase in compliance to allow for infrastructure development, public
awareness and transition time.
Use “supportive” enforcement involving monitoring, feedback and
technical assistance, with penalties as a last resort.
Clearly define compliance points and mechanisms.
Require data to benchmark and track performance.
Identify champions and cultivate stakeholder support.
16 16
Types of PAYT Programs
Can/Cart: Generators pay fixed price based on size
or number of containers they select, e.g. 30, 64 or
96 gallons.
Bag, Tag & Sticker: Generators buy special bags or
stickers for their waste. Price of each bag/ sticker
includes cost of collection services.
Hybrid: Generators pay fixed amount for specified
maximum volume of waste per collection day.
Excess waste accrues additional charge.
Weight-based: Weight of container contents is
determined at curbside. Generators are charged
accordingly.
Other: Generators are offered a PAYT fee structure
as a voluntary option.
17 17
States with PAYT Policies
State PAYT Policies
Minnesota
Local governments that charge for solid waste collection must implement a fee structure that increases as the volume or weight of waste collected from each generator's residence or place of business increases.
Washington
Applies mostly to private collectors that operate in unincorporated areas. Does not apply to local governments; however, the law’s existence has led to PAYT throughout the state.
Oregon
No legislative mandate, but PAYT is on list of nine recycling elements that municipalities choose from when designing their recycling programs to comply with state regulations.
Iowa PAYT at the local level can be required if recycling goals are not met.
Wisconsin PAYT at the local level can be required if recycling goals are not met.
18 18
State-Level PAYT: Conclusions
State policies can drive local recycling program performance
and provide non-tax source of funding.
States historically have refrained from dictating means by
which local governments fund their solid waste services.
States can promote PAYT, provide technical assistance, offer
incentives, and fund implementation – with/without requiring
PAYT.
Example: MA DEP sets best or minimum infrastructure and
services standards regarding PAYT and specific pounds per
household levels. If municipalities achieve those standards,
they are eligible for a specific $/ton diverted incentive
payment. 40% of MA communities have PAYT.
19 19
State-Level PAYT: Best Practices
1. Require PAYT to be paired with recycling
service provision with costs imbedded in waste
collection fee.
2. State policy language should specify:
Recyclable materials to be collected
Minimum frequency of collection
Container sizes and fee setting expectations with sufficient
spread in size and pricing
Who is responsible for public education about PAYT and
recycling options
Reporting requirements
20 20
PAYT Best Practices: Local Level
Conduct extensive customer and service provider education
and outreach.
Incorporate cost of recycling in the waste collection fee.
Develop recycling programs with convenience equal to that of
disposal.
Ensure pricing increments and container sizes are different
enough to impact behavior change.
Inspect hauler records.
Adjust pricing over time to ensure stable financing.
Provide sufficient staff to oversee PAYT program.
21 21
Conclusions: Future Policy Decision Making
Collect a wide range
of recyclable
materials (and
increasingly
organics)
Provide waste
generators with
convenient access
to recycling
opportunities
Have strong
recycling
promotion
programs
Are supported by
policies and funding for
infrastructure
development and to
incentivize participation
High-
performing
municipal
recycling
programs
22 22
Conclusions: Future Policy Decision Making
Existing Policy:
EPR, deposit,
mandates, bans, PAYT
Recovery
Infra-
structure
& Access
Available Funding
Mechanisms &
Programs
Political
Climate:
Legislative
initiatives,
stakeholder
positions
Local Circumstances
Dictate Best Policy Approach
23 23
Looking Ahead: Future Policy Decision Making
Trending practice is multi-faceted
programmatic and policy approach
with Universal Recycling as the
centerpiece – opportunities to recycle
everywhere
o Examples: Vermont, Seattle, San Francisco
NC Disposal Bans:
Giving Recycling A Boost
Scott Mouw, NC DENR
Policy Tools Driving Post-Consumer Packaging and Printed Paper Recovery: Disposal Bans, Recycling Policies and Pay-As-You-Throw
25 25
State Level Disposal Bans in US
• Widely adopted policy tool for special waste
streams: lead acid batteries, oil, tires, white goods,
yard waste, etc.
• Many bans were part of foundational state
recycling laws in the late 80s/early 90s
• Northeast Recycling Council (NERC) 2011 study:
– 47 states have banned at least one material from disposal
◦ Details:
http://nerc.org/documents/disposal_bans_mandatory_re
cycling_united_states.pdf
• Electronics are most recent target for disposal
bans.
26 26
State Disposal Bans on Paper and Packaging
• Three existing: MA, NC, WI
• One pending: VT Effective July 2015
• Only MA consistently enforcing bans
• 150 enforcement actions for waste generators and haulers
since 2009
• Packaging Industry/Brand Owners interested in
Disposal Bans
– AMERIPEN 2013 Policy Study recommends a combination of
three legislated approaches within the U.S.: PAYT,
Mandatory Recycling, and Disposal Bans
– Bans seen as acceptable alternative to EPR
27 27
History of NC Disposal Bans
• Senate Bill 111 in 1989: disposal bans on lead acid
batteries, used oil, tires, yard waste, and white
goods.
• Aluminum can ban and antifreeze added by Senate
Bill 59 in 1993.
• Senate Bill 59 also added:
“The accidental or occasional disposal of small amounts of
prohibited solid waste by landfill or incineration shall not
be construed as a violation of subsections (f) or (f1) of this
section.”
28 28
History of NC Disposal Bans, cont.
• In 2005, Representative Joe Hackney sponsored
H1465 and H1518:
▫ H1518 required certain ABC permit holders (bars and
restaurants) to recycle beverage containers and included a
disposal ban on those containers – effective 1/1/08.
▫ H1465 banned the disposal of wooden pallets, oil filters,
oyster shells, and “rigid plastic containers,” defined to
mean bottles, effective 10/1/2009.
• Disposal ban on computer equipment and
televisions effective July 1, 2011 as part of NC’s
electronics law.
• Ban on fluorescent lights and mercury thermostats
in unlined C&D landfills effective July 1, 2011.
29 29
Main NC Ban Statute
No person shall knowingly dispose of the following solid wastes in landfills: (1) Repealed by Session Laws 1991, c. 375, s. 1. (2) Used oil. (3) Yard trash, except in landfills approved for the disposal of yard trash under rules
adopted by the Commission. Yard trash that is source separated from solid waste may be accepted at a solid waste disposal area where the area provides and maintains separate yard trash composting facilities.
(4) White goods. (5) Antifreeze (ethylene glycol). (6) Aluminum cans. (7) Whole scrap tires, as provided in G.S. 130A-309.58(b). The prohibition on disposal
of whole scrap tires in landfills applies to all whole pneumatic rubber coverings, but does not apply to whole solid rubber coverings.
(8) Lead-acid batteries, as provided in G.S. 130A-309.70. (9) Beverage containers that are required to be recycled under G.S. 18B-1006.1. (10) Motor vehicle oil filters. (11) Recyclable rigid plastic containers that are required to be labeled as provided in
subsection (e) of this section, that have a neck smaller than the body of the container, and that accept a screw top, snap cap, or other closure. The prohibition on disposal of recyclable rigid plastic containers in landfills does not apply to rigid plastic containers that are intended for use in the sale or distribution of motor oil or pesticides.
(12) Wooden pallets, except that wooden pallets may be disposed of in a landfill that is permitted to only accept construction and demolition debris.
(13) Oyster shells. (14) Discarded computer equipment, as defined in G.S. 130A-309.131. (15) Discarded televisions, as defined in G.S. 130A-309.131.
30 30
Which Of These Things Are “Waste?”
NC Statutes say: None
31 31
Making the Case for Bans
Disposal bans on wooden pallets, oil filters, and plastic
bottles proposed in 2003 Ten Year State Plan
o Response to robust market demand and available
infrastructure
o Way to close “loophole” on disposed oil, banned in 1990
Presence of market demand and infrastructure consistently
presented to Legislative
committees
Documentation of general
growth
in recycling jobs and the NC
recycling economy
7,757
11,762 12,776 14,490 15,187
17,002
0
2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
18,000
1994 2000 2003 2008 2010 2013
Emp
loye
es
Year
32 32
The (Recycling) Business Case
Oil Filters:
o Strong and consistent markets for steel and oil in filters
o Over 30 separate oil recyclers in NC also recycle filters
o 250,000 gallons of oil wasted into NC landfills annually
Wooden Pallets
o Solid hierarchy of management option: source reduction,
reuse, repair, mulch, compost, fuel, and other end uses.
o 77 different pallet markets in state Markets Directory – NC
State study finds over 1,000 jobs in pallet recycling in NC
Plastic Bottles
o Southeast U.S. rich in bottle plastic processing and end-
use capacity: 1.439 billion lbs/year
o Carolinas home to major PET and HDPE recyclers
33 33
Plastic Bottle Recycling Capacity vs. Local Supply in the
Carolinas (in lbs.)
-
100,000,000
200,000,000
300,000,000
400,000,000
500,000,000
600,000,000
700,000,000
Capacity Amountfrom
Carolinas
34 34
Critical Support of the Disposal Bans
• Technical Assistance
– Training
– Education Materials Development
– Contact with Generators
– Outreach to Media
• Grants
– NC recycling grant funds split between public and private
sectors
– Specialized grant cycles and bonus points in traditional
cycles aimed at banned materials
35 35
Market Development Effects of Bans
• Indirect but inter-related development of recycling
businesses and jobs – synergy of supply & demand.
• Explosion of small start-up collection companies
across North Carolina.
• Expansions at MRFs and processing companies.
• New large processing facilities – e.g., Clear Path
Recycling in Fayetteville:
▫ $80 million investment and ~90 new jobs.
36 36
Beneficial Effects of 2005 NC Bans
0
500
1000
1500
2000
2500
3000
3500
4000
2008 2009 2010
Oil Filter Collection Customers
0
5,000
10,000
15,000
20,000
25,000
30,000
2009 2010 2011(projected)
Change in # of customers for Independent Haulers
Increase in business activity for small haulers encouraged by ABC law, disposal
bans, and some funding support
Tripling of tonnage handled and 250% increase in customers for filter recyclers
from the oil filter disposal ban.
37 37
Beneficial Effects of 2005 NC Bans
81%
62%
91%
38%
0% 20% 40% 60% 80% 100%
Increased pallet tonnage
Increase revenue
Increased Customers
Hired more workers
Pallet disposal ban increased tonnage and business activity for
recyclers
Plastic bottle collection by local programs doubled in four years
-
5,000.00
10,000.00
15,000.00
20,000.00
25,000.00
30,000.00
35,000.00
40,000.00
FY 0
0-01
FY 0
1-02
FY 0
2-03
FY 0
3-04
FY 0
4-05
FY 0
5-06
FY 0
6-07
FY 0
7-08
FY 0
8-09
FY 0
9-10
FY10
-1
1
FY11
-12
FY 1
2-13
PET HDPE Other
38 38
Beneficial Effects of NC Policies
Encouraged by plastic bottle disposal ban, disposal tax grant funds, and technical assistance
Decline in waste disposal encouraged by combination of NC policies, protocols,
grants, etc
0
50
100
150
200
250
300
350
FY
19
98
-99
FY
19
99
-00
FY
20
00
-01
FY
20
01-
02
FY
20
02-
03
FY
20
03-
04
FY
20
04
-05
FY
20
05-
06
FY
20
06
-07
FY
20
07-
08
FY
20
08
-09
FY
20
09
-10
FY
20
10-1
1
FY
20
11-1
2
FY
20
12-1
3
Number of Curbside Programs
39 39
Limitations of Bans with no Enforcement
-
20,000
40,000
60,000
80,000
100,000
120,000
140,000
160,000
FY 05-06 FY 06-07 FY 07-08 FY 08-09 FY 09-10 FY 10-11 FY 11-12 FY 12-13
PET/HDPE Recycling PET/HDPE Wasting
40 40
Material Banned Effective Date of Ban Estimated Tonnage of Diversion
since Effective Date
Whole Tires October 1, 1989 1,939,339
Used Motor Oil October 1, 1990 61,137
Lead Acid Batteries January 1, 1991 23,979
White Goods January 1, 1991 1,025,786
Yard Trash January 1, 1993 11,020,232
Antifreeze July 1,1994 2,010
Aluminum Cans July 1, 1994 110,081
Oyster Shells January 1, 2007 5051
ABC Permit Holder Glass January 1, 2008 165,000
Used Oil Filters October 1, 2009 666
Rigid Plastic Containers (bottles) October 1, 2009 130,201
Wooden Pallets October 1, 2009 90,893
Computer Equipment July 1, 2011 11,844
Televisions July 1, 2011 17,004
Fluorescent lamps and thermostats July 1, 2011 84
TOTAL TONS: 14,603,306
Retrospective on NC Disposal Bans
41 41
Lessons from NC Disposal Bans
• Bans are an effective way to declare material to be
commodities (and to transition to “materials
management”).
• Enforcement a tough issue and bans alone are not
a “magic bullet.”
• Successful bans require both presence and
development of infrastructure.
▫ May need lead time for infrastructure to mature.
▫ Success can be encouraged with program and grant
support.
Thank You!
Scott Mouw
NC Division of Environmental Assistance &
Customer Service
919-707-8114
James Short, Delaware Dept. of Natural Resources and Environmental Control
Implementing Delaware’s
Universal Recycling Program
and Lessons Learned
Policy Tools Driving Post-Consumer Packaging and Printed Paper Recovery: Disposal Bans, Recycling Policies and Pay-As-You-Throw
44 44
Universal Recycling – History/Background
Comprehensive drop off yet low diversion rates.
Resulted in citizen interest in curbside recycling.
Initial Draft Legislation developed in early 2000’s.
Pilot subscription and municipal curbside collection
programs started in response.
45 45
Universal Recycling – Unifying Stakeholders
Important to have legislative support of haulers,
bottle distributors, retailers, municipalities and the
general public.
Important to be both convenient and cost effective.
Single stream collection offered both and single
stream separation technology was nearby.
46 46
Universal Recycling – Bottle Deposit vs. Bottle Fee
Delaware “Bottle Bill” was a litter control bill with no
requirement to recycle.
Large percentage of population did not redeem nickel
deposit.
Escheat deposits kept by distributor estimated at $3
million/yr.
Therefore bottle deposit was supported as a good
candidate for the revenue needed to fund capital costs
to implement a comprehensive recycling program.
Four cent bottle fee used to fund capital start up costs
(trucks/carts/processing equipment) and educational
costs awarded through the recycling grant and loan
program.
Four cent fee started 12/1/10 and sunsets 12/1/14.
47 47
Universal Recycling Implementation – Key Components
Haulers required to provide residential recycling
service and bill for both trash and recycling
services.
Recycling participation by resident encouraged but
not required. Residents advised to take advantage
of recycling services since they pay for it, i.e.
residents cannot get a lower rate and therefore be
financially rewarded by not recycling.
By providing the service to each resident the
economy of scale reduces overall costs.
In many instances competition lowered prices.
48 48
Universal Recycling Implementation – Key Components
Reporting and Measurement required.
Established Recycling Public Advisory Council in Legislation.
MSW Recycling Goals – 2015: 50%, 2020: 60%.
Enforcement capability.
Grant and Loan program supported via bottle fee.
49 49
Implementing Universal Recycling – Status
Single-family requirement started 9/15/11.
Multi-family requirement started 1/1/13.
Commercial requirement started 1/1/14.
MSW Recycling Rates:
o Residential prior to 2006 estimated around 10% at best.
o 2006 with DSWA/Wilmington voluntary curbside 23.2%.
o 2012 at 40.1%.
Delaware fortunate to have excellent waste
characterization data courtesy DSWA.
Resulted in construction of $15,000,000 MRF and
creation of approx. 200 collection/processing jobs.
50 50
Universal Recycling Implementation – Lessons learned
Funding - Revenue from bottle fee 1/3 less than expected.
Delaware fee collection is from retailers.
Know your waste/recyclables – residential well understood,
commercial still learning.
Service and Participation - verifying compliance is a function
of observation, reporting and a measure of tons diverted.
Education – A never ending necessity.
Planning – What gets measured gets managed.
51 51
Universal Recycling Implementation – Going Forward
Commercial Recycling rate behind residential.
Focusing on organics and C&D. They represent a
large amount of waste and DE has processing
capability for them.
New waste characterization study in 2015 will help
prioritize which areas of diversion to focus on.
Thank you!
To view additional information about
recycling in Delaware, including the universal
recycling legislation visit:
http://delaware.gov/topics/recycling
For questions, contact:
Jim Short, [email protected]
Bill Miller, [email protected]
or call 302-739-9403 ext. 8
Volume Based Pricing and the
New Commercial Recycling
Mandate in Minnesota
Peder Sandhei, MN Pollution Control Agency
Policy Tools Driving Post-Consumer Packaging and Printed Paper Recovery: Disposal Bans, Recycling Policies and Pay-As-You-Throw
54 54
Volume-Based Pricing
Only one
community in MN
has a true PAYT
system
o (City of St. Cloud)
MN has a volume
or weight-based
pricing
requirement in
statute
$30 $20 $10
Approx.
5-7 Approx.
4-5 Approx.
2-3
55 55
Volume-Based Pricing – Minnesota
§115A.9301 SOLID WASTE COLLECTION;
VOLUME- OR WEIGHT-BASED PRICING.
o A local government unit shall implement charges that
increase as the volume or weight of the waste collected
increases
o If a local government unit implements a pricing system
based on volume instead of weight under subdivision 1, it
shall determine a base unit size and establish a multiple
unit pricing system that ensures that amounts of waste
generated in excess of the base unit amount are priced
higher than the base unit price
56 56
Volume-Based Pricing in Action
Statute doesn’t
state how much
more expensive the
larger size must be
Result: larger
container is only
marginally more
expensive than the
smaller sizes
Due to overflow
penalties, most
residents select a
larger container
than they need
$22 $20 $18
Approx.
5-7 Approx.
4-5 Approx.
2-3
57 57
What’s needed to make it effective?
Pay-as-you-throw is more effective in communities
with contracted service
In Minnesota, the language would need to specify
the percent increase in cost by volume or weight in
order to be effective – difficult to implement
politically
Challenging in MN due to wide variety of policies at
the local level
o Many communities have subscription service/not
contracting
58 58
Commercial Recycling Mandate
Historically, MN has focused on residential recycling
Funded by the solid waste management tax
Commercial buildings (January 1, 2016)
In metro counties only (section 473.121)
o Anoka, Carver, Dakota, Hennepin, Ramsey, Scott and
Washington
Contracted for four cubic yards or more per week
of solid waste collection
Sports Venues (January 1, 2015)
College and Pro venues only
Statewide
59 59
Who is impacted?
NAICS 42 to 81
Service-Providing Industries
Trade
Transportation
Utilities
Information
Financial Activities
Professional and Business
Services
Education and Health
Services
Leisure and Hospitality
Other Services (except
Public Administration)
These are Exempt
NAICS 11 to 33
Goods-Producing Industries
Natural Resources and
Mining (including
agriculture and forestry)
Construction
Manufacturing
60 60
Public Entity Recycling Requirements (115A.151)
Must collect a minimum of 3 materials
o By type: (ex. paper,
glass, metal, organics)
o Single-sort meets requirement
Must provide containers
o Emphasis on co-locating
all trash with recycling
Collection Requirements
61 61
Collection Requirements
Is collection required in areas with public
interaction?
o Intent of bill is that the business establish an effective
recycling program
• Where there is public garbage,
provide public recycling
62 62
State Policy Best Practices
Why recycling? We
already do that!
o Not true – continuous
improvement is critical
Establish a consistent
funding mechanism
Find ways to make
recycling and diversion
convenient and easy to
understand
Develop good
partnerships with the
private sector
64 64
Conclusion and Next Steps
65 65
Robust MRF Processing dependable flow of material
to create quality bales
Strong End Markets create demand and
appealing price points
Thoughtful Outreach
boosts participation, reduces contamination
Supportive Policy recognizes the connection to manufacturing
Committed Community
provides ample access & opportunity for expansion
Private/Public Partnership coordination across sectors
What does healthy, robust recovery look like?
Source: SERDC 120/The Recycling Partnership
66 66
Looking Ahead
Carton Council Policy Report on
CartonOpportunities.org
Policy Forum, Monday morning,
September 15, Resource
Recycling Conference, New
Orleans
Thank You!
67 67
Elisabeth Comere
Carton Council & Tetra Pak
Betsy Dorn
Reclay StewardEdge
Scott Mouw
North Carolina Department of
Environment and Natural Resources
James Short
Delaware Dept. of Natural Resources
and Environmental Control
Peder Sandhei
MN Pollution Control Agency
Contact Information