Commenter:
Daniel Baxter, President Virginia Recycling Association
VRA Recommendations for the 2023 DEQ Solid Waste Planning & Recycling Regulations
DEQ Reporting requirements in 9VAC20-130-120 B.currently require only the reporting of Municipal Solid Waste. However, that is not consistent with the other language in the regulations which indicate a goal of a more comprehensive environmental approach to waste and recycling in the Commonwealth. Please see examples below.
9VAC20-130-10. Policy states: “to develop comprehensive and integrated solid waste management plans that, at a minimum, consider and address all components of the following:
Source reduction;
Reuse;
Recycling;
Resource recovery (waste-to-energy);
Incineration; and
Landfilling
9VAC20-130-120. Planning requirements 3. States, “Estimates of solid waste generation from residential, commercial, institutional, industrial, construction, demolition, debris and other types of sources, including the amounts reused, recycled, recovered as a resource, incinerated, and landfilled. Entities engaged in the collection, processing and marketing of recyclable materials should provide data for incorporation into the recycling rate calculation when requested by the planning unit;
