Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Virginia Waste Management Board
 
chapter
Solid Waste Planning and Recycling Regulations [9 VAC 20 ‑ 130]
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6/26/23  12:41 pm
Commenter: Elly Boehmer Wilson, Environment Virginia

The future of waste diversion and source reduction in Virginia
 

Virginia's solid waste and recycling regulations are unclear and lacking in ambition. Reducing waste is extremely important. The DEQ should first and foremost look at ways to incorporate source reduction into their regulations starting with the most littered as well as difficult to recycle products. The ultimate goal should be a truly circular economy and the plan should be in line with this mission. 

Other recommendations:

  1. Increase monitoring and benchmarks
    1. Right now, VA monitoring for recycling is lacking and gives an unclear picture of the current state of waste diversion in Virginia. Currently recycling rates are likely much lower than what is reported due to the fact that litter is not included in these metrics. Reporting is also not broken down by materials so we have no way to determine what areas of source reduction and waste diversion are the most important to focus on. It is unclear how recycling contamination impacts these rates as well. 
    2. With no benchmarks or required improvements, waste diversion rates are unlikely to change or get better.
  2. Measuring by weight rather than volume also complicates this picture. 
    1. Some of the most harmful materials that cannot be recycled are lightweight, filmsy plastic. While they may be the most harmful, they do not weigh much. Land use for landfills is more impacted by volume of waste rather than the weight of it.
  3. Comprehensive list of recyclables in Virginia
    1. If something is not recyclable in Virginia, the DEQ should look into ways to recover management money of these products. This cannot happen until we know what can be recycled and how accessible these recycling methods are.
  4. Increase overall goal
    1. Once we have a clearer picture of what materials are in our waste stream and how much we are diverting waste, we need to increase the amount we are recycling. 80% mechanical recycling is more in line with where we should be.
    2. There should also be a goal on overall reduction of waste generated in Virginia.
  5. Require producers to hit goals
    1. EPR is a popular option among cities and counties to include producers in the management of their products waste. If it cannot be sustainably managed in Virginia, producers should pay the costs in order to hit our goals. Localities should not continue to lose money when they have no ability to regulate the products sold or thrown away that they then have to deal with. (Example: set a goal of 50% plastic bottles recycled by 2028 or producers are fined, by 2030 if rate is not met then the product is banned in Virginia). Producers need to start designing products with localities and local waste programs in mind and DEQ should include any and all regulations that would achieve this.  
  6. Eliminate greenwashing of recycling
    1. Contamination or wish-cycling is a waste of energy and resources. By requiring better labeling, Virginians would have a better understanding of what can and cannot be recycled which will help achieve goal recycling rates. Example: plastic bags cannot be recycled with curbside in VA and cause significant problems for recycling facilities. Yet many have the recycling symbol that people assume means it is recyclable. The recycling numbers do not translate to more informed recycling and need to be reevaluated. 
CommentID: 217453