CAA submits second draft program plan to Oregon DEQ

Circular Action Alliance (CAA), headquartered in Washington, has submitted its second draft program plan to the Oregon Department of Environmental Quality (DEQ). The plan outlines how CAA intends to administer Oregon’s extended producer responsibility program for packaging, paper products and food service ware under the Oregon Recycling Modernization Act (RMA).

CAA is a nonprofit U.S. producer responsibility organization (PRO) working to deliver what it says are harmonized, best-in-class compliance services to all producers to advance an efficient and effective circular economy through extended producer responsibility (EPR) programs.

In late July, the Oregon DEQ rejected the first draft of the PRO program plan CAA submitted March 31.

The updated PRO program plan has been posted on DEQ’s Recycling Modernization Act web page. Public comment on the plan will close Oct. 28 at 5 p.m. PDT and can be submitted to RethinkRecycling@deq.oregon.gov.

The DEQ has provided guidance to parties interested in submitting public comments:

• Commenters should limit their plan review and comments to unapproved sections of the plan that have been updated in the second draft to avoid duplicating the first round of public comment. CAA has included an appendix in the document indicating where revisions have been made and a list of the revisions that commenters can refer to. The list appears at the end of the plan document.
• Sections of the plan that were conditionally approved in the first round of DEQ review, including sections pertaining to education and fee categorization for producer fees, are not subject to public comment in the second draft, as these sections are considered closed as long as revisions align with approval conditions. Commenters can refer to DEQ’s response letter on the first draft to identify the plan sections not included in public comment (plan components No. 2, No. 8, No. 14 and No. 15 in the appendix table.
• Note that some components of the plan pertaining to system expansion and the PRO Recycling Acceptance List collection network are awaiting results of a system costing survey, the Oregon Recycling System Optimization Project, before being updated in CAA’s third draft submission.
• DEQ will take the comments it receives into account in formulating its response letter to CAA.

The Oregon Recycling System Advisory Council also has an advisory role in the plan review process. The CAA will present information about its plan at the Oct. 8 Recycling Council meeting. Those interested in attending the meeting can register at the Recycling Council webpage.