[OKRA] What should Count as Recycling? EPA gets an earful

[Ellen Bussert]

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Asking what should count as recycling, EPA gets an earful
<https://resource-recycling.com/recycling/2021/04/20/asking-what-should-count-as-recycling-epa-gets-an-earful/>
Published: April 20, 2021
Updated: April 20, 2021
by Jared Paben
<https://resource-recycling.com/recycling/author/jared-paben/>
[image: Sorted materials at the recycling facility.]

*The U.S. EPA received 108 public comments as the agency seeks to revise
its recycling rate calculation methodology.* | *janstarik/Shutterstock*

If food scraps from households are composted, should that count in the
nation’s recycling rate? What if they’re fed to livestock or processed in
anaerobic digesters?

Those are just a couple of the many questions the EPA is grappling with as
it seeks to define exactly what “recycling rate” will mean
<https://www.epa.gov/americarecycles/national-recycling-goal-recycling-rate-measurement-comment-period#comments>.
Last fall, the agency released a national recycling rate goal of 50% by
2030. Using current methodologies, the EPA estimates
<https://resource-recycling.com/recycling/2020/11/16/epa-waste-generation-far-outpaced-recycling-in-2018/>
the
U.S. has a 32% recycling rate.

But the EPA is considering changing the calculation methodology. In
particular, the agency is examining which sources of material, types of
materials, management pathways and destinations to count. Not
surprisingly, among
the 108 comments
<https://www.regulations.gov/document/EPA-HQ-OLEM-2020-0443-0068/comment> from
different recycling industry stakeholders, advice differed dramatically.
The following are some takeaways from comments submitted by industry
stakeholders.
Pointing to ‘recycling’ pathways

In addressing organics, Waste Management (WM), the largest residential
garbage and recyclables hauler and MRF operator in North America, said
composting should be counted toward the country’s recycling rate (and
reported separately from other recycling activities) but anaerobic
digestion shouldn’t. Use as animal feed should only be counted in the
recycling rate if the material came from residential or commercial sources,
not from farms or other industries, WM wrote.

WM also suggested crushed glass used as alternative daily cover (ADC) on
landfills should count toward the U.S. recycling rate, with the company
noting that it offsets the use of raw materials.

In a couple areas, WM, a giant publicly traded for-profit company, agreed
with small nonprofit MRF operators: chemical recycling of plastics should
not count if the outputs are fuels. Chemical recycling, which is sometimes
called “advanced recycling,” is a blanket term for technologies that use
heat, pressure and/or solvents to break down scrap plastics into chemicals,
which can be used to make various products, including new plastics, fuels,
and waxes.

“These pathways should be considered in the numerator of the recycling rate
calculation where the feedstock is processed to make a new product,” wrote
Michael Jensen, director of regulatory affairs for WM. “These pathways
should not be considered in the recycling rate calculation where the
feedstock is processed to make fuel.”

WM also urged excluding waste-to-energy plants from the recycling
definition.

Those were sentiments mostly shared by the Alliance of Mission-Based
Recyclers (AMBR), a group of nonprofit MRF operators Eureka Recycling,
Ecology Center, Eco-Cycle and Recycle Ann Arbor. AMBR urged EPA to exclude
plastics-to-fuel technologies, but it also recommended holding off on
counting plastic-to-plastic technologies as recycling, until they’re
further developed. In the other camp, the chemical recycling companies have
urged the EPA
<https://resource-recycling.com/plastics/2021/04/07/epa-hears-divergent-opinions-on-chemical-recycling/>
to
count the activities as “recycling.”

Other commenters urged either wide or narrow definitions of recycling. For
example, the Indiana Department of Environmental Management’s Julia Wickard
suggested a broader definition that includes composting, anaerobic
digestion, chemical recycling of plasic, glass and tires used for civil
engineering applications, and fiber and wood waste from C&D sorting
facilities. Indiana called for only landfill disposal and waste-to-energy
pathways to be specifically excluded.

The Association of New Jersey Recyclers (ANJR), on the other hand,
recommended only counting traditional recycling and composting as
“recycling.” “ANJR believes in a “best use” definition of recycling. That
is, it is better to recycle glass into glass bottles than to beneficially
use it for landfill cover,” wrote Angela Andersen of the ANJR.

The New York Department of Sanitation (DSNY), the nation’s largest
municipal sanitation department, shared its own methodology with EPA. For
example, New York City considers composting, donations of goods, diverted
household hazardous waste (HHW), rechargeable batteries recycled through
the producer responsibility program, beverage containers collected through
the deposit program, and scrap electronics recycled through e-waste
programs as “recycled,” wrote Bridget Anderson of DSNY.

But New York City does not count a host of other materials and pathways,
including waste-to-energy, construction and demolition (C&D) debris, sewage
sludge or material from commercial recycling programs, which are tracked
separately from the municipal recycling rate.
Debate over factoring in exports

Parties also submitted comments on whether exported scrap materials should
be counted as “recycled.” Meanwhile, in recent years and continuing to this
day <https://resource-recycling.com/recycling/?p=19444&preview=true>, the
U.S. has exported markedly less paper and plastic recyclables, largely as a
result of China’s import restrictions
<https://resource-recycling.com/recycling/2018/02/13/green-fence-red-alert-china-timeline/>
.

Waste Management said exports should count, even as the company has reduced
its overseas shipments
<https://resource-recycling.com/recycling/2019/02/05/wm-spent-110-million-on-recycling-infrastructure-last-year/>
in
recent years.

“Most recyclables are global commodities with robust end markets, where the
feedstock is needed for the manufacture of new products,” WM’s Jensen
wrote. “A global recycling marketplace supports markets for recyclable
materials, as well as supply and demand ‘checks and balances’ that help
keep our domestic markets strong. Global trade also provides a safety valve
when domestic demand cannot keep up with supply.”

AMBR said material exported outside North America should not be considered
in the recycling rate.

“Recent years have shown that there is little to no accountability of what
happens to those materials after they leave the U.S.,” Kate Bailey of
Eco-Cycle wrote on behalf of AMBR. “Without adequate safeguards or global
data tracking to ensure those materials are responsibly recycled, the EPA
should not include exported materials in the recycling rate.”

DSNY’s opinion landed somewhere in between. The department did recommend
including exports in the recycling rate, but it urged the EPA to separately
report exported versus domestically recycled material, as a way to provide
transparency in the final steps of the recycling process and measure the
resilience of the U.S. recycling industry.

“While there is at least some level of oversight and quality control in
domestic recycling-what happens overseas is never quite certain or easily
traceable,” Anderson wrote. “While there are market forces that pressure
international recyclable buyers to act in good faith, there can certainly
be instances where recyclables are landfilled, burned, or picked through in
unsafe environments.”
Not just the ‘what,’ but the ‘how’

Beyond which materials and pathways to count, other commenters also weighed
in on how to count.

The Environmental Research and Education Foundation (EREF) suggested
creating a methodology to create the methodology.

“EREF suggests that EPA consider developing a methodology to evaluate the
additional pathways listed, which could also be used for any future
pathways not yet identified, such that these pathways can be reported on
when they reach a predefined threshold and can be measured accurately,”
wrote Bryan Staley and Suzie Boxman of EREF. “As additional pathways meet
these criteria, EPA can provide individual rates for those activities to
demonstrate growth, but would not necessarily need to include them in the
national recycling rate.”

The Pennsylvania Department of Environmental Protection (DEP) urged EPA to
abandon the weight-based rate metric altogether. Instead of calculating a
single recycling rate percentage, Pennsylvania measures environmental and
economic benefits, wrote Patrick McDonnell of DEP.

When it comes to dividing weight recycled by total weight generated, both
numerator and denominator suffer from incomplete data sets, he wrote.

For its part, ANJR shared its hope that the EPA’s exercise, itself, would
bring improvements to nationwide data tracking.

“For far too many years, states have measured recycling rates differently
which has resulted in inaccurate comparisons between programs,” wrote
Andersen of ANJR. “It is our hope that with the EPA’s leadership, states
will adopt a consistent measurement methodology to enhance the accuracy of
national recycling metrics.”
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