Friday, August 23, 2013

Updated Carpet Recycling Plan Rejected by CalRecycle

AB2398 is the first mandatory carpet stewardship program in the country. As an extended producer responsibility program (EPR), the bill requires all manufacturers of carpet sold in California to 1) register with CARE, 2) assess a fee to their customers of an additional 5-cents per square yard of carpet purchased, and 3) design and implement a stewardship program using the collected funds.

At the bill’s inception CARE was elected by the industry to be the umbrella Carpet Stewardship Organization to all manufacturers.  Accordingly CARE was tasked with the preparation and implementation of a Carpet Stewardship Plan that would appropriately and effectively address the bill’s goal in its critical early years; namely, to increase the diversion and recycling of post-consumer carpet in the state of California.

Since AB2398 was and still is the first legislation of its kind, CARE has had the exciting opportunity and challenge of developing an implementation plan from scratch. One of the key thoughts behind AB2398 was that the best way to encourage carpet recycling would be to maximize the outlets for PCC, essentially increasing the diversion of carpet from landfills by working from market-based solutions backwards.

AB2398’s focus on incentives is unlike other extended producer responsibility programs. Specifically the existing Carpet Stewardship Plan (conditionally approved by CalRecycle in January 2012) pays processors 6 cents for every pound of Type-1 product (high value) sold and shipped and 3 cents for every pound of Type-2 (low value).

Since the Carpet Stewardship Plan went into action in July of 2011 CARE has worked with 80 registered manufacturers and 11 registered processors to divert roughly 210 million pounds of post-consumer carpet from landfills and increase recycling output from 8% to over 15% in Q2 2013. Furthermore, greater than 90% of all recycled output is high value material.  That said, while the plan has led to substantial success, there is recognized room for improvements.  

Recycled Output by Type as a Percent of Diversion

Annual Report to CalRecycle, July 2013
In the past months CARE submitted both a revised Carpet Stewardship Plan and an Annual Report to CalRecycle and various public/stakeholder meetings were held to review their content. While CalRecycle acknowledged the significant recent Plan modifications highlighted in the Annual Report, statute only allows Staff to rule on the actual Plan content. At the most recent meeting this past Tuesday, August 20th, CalRecycle specifically organized their concerns into seven principle issues: goals and baseline, market incentives, amounts of funds in reserve, financial assurance, consumer convenience in rural counties, California staff and accounting and auditing standards. 

Staff acknowledged that many of these issues have been addressed in the recent Plan’s incentives and CARE has been given sixty days to address Staff’s concerns and produce a revised Plan. Some of the key points CalRecycle would like to see CARE focus on are:
1.    More clarity in how the sales-based formula for determining diversion and recycling rates is calculated, with strong emphasis on the collection of more transparent and reliable data
2.   Higher diversion goals that better demonstrate ‘continuous and meaningful progress’ in PCC recycling
3.   Greater emphasis on the education of both carpet installers and consumers about AB2398 and carpet recycling in general
4.   A detailed job description of the new California-based staff member, with specific focus on how their role will help to further the success of AB2398
5.    How market incentives, such as the proposed 12-cents per pound incentive for development of non-nylon market, are expected to work
6.   How unused funds will be allocated, with the recommendation that they remain no greater than 35% of annual operating cost
7.   How to prevent adverse consequences to human health or the environment in the case that a recycler is forced by the market to close their operation
8.   Details of how the rural county collection program was implemented and a plan for its expansion

CARE deeply appreciates this feedback and is actively working on adding language to the Carpet Stewardship Plan that will respond and resolve these reasonable concerns in a timely manner.  In the end, considering California has several cities, large and small, that have declared goals of zero waste by 2020, AB2398 can help play a major role in helping to accomplish this objective.

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