Dive Brief:
- Circular Action Alliance, the producer responsibility organization selected to implement California’s extended producer responsibility for packaging law, on Monday hit a highly anticipated deadline to submit its program plan to the SB 54 advisory board.
- In the draft plan, CAA projects a California program budget of up to $1.87 billion in 2027. Looking at the next five years, it could total between $9.35 billion to $17.2 billion.
- A public comment period is open until Aug. 14. CAA will consider the comments as it prepares the final program plan for submission to CalRecycle in October.
Dive Insight:
The draft program plan offers an insightful road map as to how to implement the plastic waste reduction law signed back in 2022.
The more than 350-page document includes sections related to fees and funding, such as budget development, fee-setting, ecomodulation, and reimbursement and payment processes. It also covers materials topics, including source reduction, covered materials and compostables. Still other sections relate to public engagement, such as education and outreach, and equitable access and environmental justice.
The program plan follows SB 54 regulations that were finalized in May, over a year behind schedule after Gov. Gavin Newsom raised concerns over costs. Around that time, CAA shared estimated material-specific fees for packaging to help producers plan.
But in general, CAA was having to prepare the program plan without the benefit of those finalized rules. “We have worked closely with producers, local jurisdictions, service providers and other interest holders to develop a robust plan, taking decisive action even ahead of final regulatory certainty,” said CAA Chief of Staff Shane Buckingham in a statement on Monday.
CAA again noted the challenges that those delays presented in the program plan. It wrote that adjustments may be needed to account for those delays; namely, pushing back the law’s 10% source reduction target.
“CAA California is considering submitting a unique challenges exemption application seeking a three-year exemption from CAA California’s PRO-level requirement to achieve the 10% source reduction target with at least 2% through reuse and refill,” the plan states.
Already, environmental groups are displeased by what they see as recent weakening of the law. The Natural Resources Defense Council, Oceana and the Californians Against Waste Foundation filed a petition and complaint in San Francisco Superior Court alleging that CalRecycle’s finalized regulations fail to meet SB 54’s requirements.
CAA leaders are expected to present on the plan at a June 26 meeting of the state’s packaging EPR advisory board. CAA is also hosting an informational webinar on July 8 to discuss the plan.