Oregon DEQ rejects CAA’s second draft plan

In a letter to Circular Action Alliance CEO Jeff Fieklow [sic] dated Nov. 8, the Oregon Department of Environmental Quality (DEQ) says that while the Circular Action Alliance (CAA) has made “considerable progress” on its second draft of the producer responsibility program plan, particularly its “thoughtful and novel work on a verification standard for responsible end markets and on a life cycle assessment-based approach to ecomodulation,” it has rejected the proposed plan.

The DEQ says the decision was made after reviewing the plan and considering input received through public comments and the Oregon Recycling System Advisory Council (ORSAC).

The agency has requested CAA submit an updated version of its plan by Dec. 6 or within the statutory maximum of 60 days allowed for making the revisions. ORS 459A.878 allows for up to three drafts to be submitted in the review process.

The Oregon DEQ reviewed and approved 18 sections of the plan individually, but approval of all sections is required, with the DEQ saying it “continues to be confident in CAA’s ability to ultimately produce a revised version of the plan that meets all requirements” and enables launching the program by July 1, 2025. 

Eight sections have not been approved:

1. system expansion;

2. transportation reimbursements;

3. additional local government funding;

4. convenience standards;

5. performance standards;

6. financing;

7. equity; and

8. management and compliance.

The DEQ writes, “As expected, all eight of these sections either were not updated in Draft 2 or included substantial portions that were not updated. These sections are awaiting inputs from CAA’s system costing survey, the Oregon System Recycling Optimization Plan, completed in early October. CAA will revise the content of these sections in Draft 3, incorporating feedback from DEQ, the Recycling Council and the public.”

Sections receiving conditional approval included establishing overarching goals for the program plan that are objective and measurable, the addition of transparent blue and green polyethylene terephthalate (PET) bottles to the Uniform Statewide Collection List and the achievement of statewide plastic recycling goals.

Upon submission of the third draft, conditionally approved sections of the plan will be approved immediately if CAA updates them according to the approval conditions. The eight remaining sections will be subject to full review, including ORSAC review and public comment, the DEQ says.