Lynnhaven River Now (LRNOW) is a 501(c)(3) organization that for over 20 years has been dedicated to protecting and restoring Virginia Beach’s waterways, which all flow into the Atlantic Ocean. Our diverse and complex waterway systems are significantly impacted by both runoff pollution and plastic pollution, including micro-plastics . In order to address this, one of our main priorities is to reduce plastic consumption in the Hampton Roads region through our public education and outreach efforts that includes engagement with local businesses and decision markers. We also organize monthly waterway cleanups that have removed over 35 tons of trash since 2003, much of which is plastic waste. In 2022 alone, we removed 10,000 pounds of trash and are concerned that the problem is growing due to the expanding demand and widespread use of plastics. According to the International Energy Agency, plastic production is anticipated to double by 2040 and become the biggest growth market for oil demand over the next decade.
While it is worth noting that recycling in the United States has experienced significant cost increases and setbacks due to China's 2018 “National Sword'' policy, (which halted the import of plastics and other materials destined for its recycling processors) we maintain that we need to continue domestic recycling programs and work to improve them in order to help reduce plastic waste in our landfills and oceans. We have outlined key policy recommendations we support to help address some of the cost and logistical hurdles of domestic recycling in the Commonwealth.
Implement extended producer liability for plastic products (EPR).
The financial burden of plastic waste should not entirely fall on the public as it does now.
EPR model is very efficient for reducing waste because producers have the most influence over the design of products and packaging. If they are partially (if wholly) responsible for the cost of recycling or disposal, they will be incentivized to design their products to be more easily recovered and/or disposed of.
The Plastic Waste Makers Index, (developed with partners including Wood Mackenzie, and experts from the London School of Economics and Stockholm Environment Institute among others) has demonstrated that just 20 companies produce over 50% of the world's single use plastic.
Many other industries are required to process their own waste, why should these plastic producers be an exception?
A 2017 survey by the Northern VA Waste Management board found that 84% of local governments indicated that they would like to see manufacturers, distributors and retailers take more responsibility for the management of difficult to handle waste.
Improve transparency around recycling reporting by Solid Waste Planning Units (SWPU)
Under current practices, the actual statistics produced by SWPU do not provide a clear breakdown of what is being recycled or how.
This makes it harder to tackle our recycling issues since we do not have clear data on the actual breakdown of what is collected and processed.
Raise Required Recycling Rates
According to the 2021 VA DEQ Annual Recycling Summary, current required recycling rates are being surpassed by all SWPU. This suggests that we should explore being more ambitious.
Urban areas, where most of the single use plastic is being collected, should observe a minimum of 40% for their recycling rate.
Rural areas should have the rate increased to 25%
This increase will be more achievable once measures are taken to improve SWPU data collection.
Furthermore, we cannot support any policies that would in any way entertain or encourage any type of advanced recycling programs that use dangerous pyrolysis methods which are known to produce hazardous waste such as dioxins and toxic air pollution. VA DEQ already codifies pyrolysis as incineration, not recycling, and the EPA has already affirmed that it does not consider activities that convert non-hazardous solid waste into fuel, fuel substitutes or energy production to be recycling activities. We feel that this categorization is both accurate and appropriate.
In conjunction with the public health concerns posed by pyrolysis, a diverse range of studies on the viability of this process have demonstrated that it is a panacea for our plastic issue. In 2019, a study commissioned by Reynolds Consumer Products and completed by Sustainable Solutions Corporation examined the “Hefty EnergyBag” program which operated in 4 regions in the US (Cobb County, GA; Omaha, NE; Lincoln, NE; and Boise, ID). The study examined the environmental impact of recycling plastic waste through pyrolysis versus two conventional methods of disposal: burning it in cement kilns or landfill. In the Boise case, pyrolysis fared worst in terms of its overall global warming. Another analysis examining the final recycling process and its contribution to global warming, found that "pyrolysis scored better than landfilling but was worse than burning plastic in a cement kiln". Pyrolysis is also known to be both highly energy intensive and inefficient because the energy required to heat plastics and extract chemicals from the waste is more than the energy produced by the chemicals. Therefore, at this point in time, it is a distraction from more viable alternatives and should not be pursued at the Commonwealth's expense or at the expense of the health and safety of its residents.
Thank you for your time and consideration of our recommendations. If need be, we are available for further follow questions.