WEBVTT 00:00:00.000 --> 00:00:01.030 OK great. 00:00:01.820 --> 00:00:07.360 I am Brian Beneski, the head of the Department Sustainability Unit, and I will be handling the technical issues of the meeting. 00:00:08.240 --> 00:00:11.210 I would just like to introduce Elena Bertocci and Jessica Nadeau. 00:00:11.220 --> 00:00:16.270 They own the sustainability unit and the staff in charge of implementing the EPR for packaging program. 00:00:16.280 --> 00:00:19.420 Jim Guerrera Sustainability unit is here as well. 00:00:22.880 --> 00:00:32.130 They will be acting as moderators for this meeting, although we've had several meetings now, there still may be some technical bumps that arise, so I asked for everyone's patience when those happen. 00:00:32.500 --> 00:00:35.110 We actually had someone from OIT here to help us set up. 00:00:35.120 --> 00:00:37.650 So I think we're going to be good this this meeting. 00:00:38.060 --> 00:00:38.670 We are. 00:00:38.800 --> 00:00:42.510 These meetings are part of the stakeholder process and initiated by the department. 00:00:42.660 --> 00:00:46.690 This is the second meeting regarding the topics of producer payments and reporting. 00:00:47.200 --> 00:00:51.030 The opening meeting held earlier, allowed stakeholders present comments. 00:00:51.120 --> 00:01:05.810 This second meeting provides an opportunity for the stakeholders to ask questions of each other regarding the various persistent various sorry got slowed down, various positions presented in the earlier meeting and made available on the these topics through the programs web page. 00:01:06.850 --> 00:01:11.330 We will make sure that everyone who wishes to make a statement or ask a question will get a chance to do so. 00:01:12.720 --> 00:01:18.210 I would like to add that this meeting is being recorded and that the recording should be made available within the next week or so. 00:01:18.340 --> 00:01:26.580 Additionally, it transcript will also be made available with the speeding with any additional comments received through a link on the programs website. 00:01:27.800 --> 00:01:42.050 The information from all the comments submitted in these discussions will be used as the basis for drafting rules that will be submitted to the Board of Environmental Protection as part of the formal rulemaking process in December of 23 comments. 00:01:42.060 --> 00:01:44.630 Submittal is not limited to the attendees of this meeting. 00:01:44.640 --> 00:01:49.350 The department will accept all comments for consideration that are submitted in writing. 00:01:49.460 --> 00:01:56.630 Additionally, new or additional comments can be presented at anytime through the EPR for packaging email address found on our website. 00:01:58.050 --> 00:01:59.560 Uh, let me use registered. 00:01:59.570 --> 00:02:00.580 We currently have. 00:02:00.650 --> 00:02:11.510 I might up there 103 who are registered to attend the meeting in person and just US staff here live as this, both as an in person and virtual meeting. 00:02:11.610 --> 00:02:19.120 We ask that those who wish to speak raise their hand and hold your statements until a moderator recognize you to allow us time to mic you. 00:02:19.130 --> 00:02:20.680 So everybody hears your questions. 00:02:20.770 --> 00:02:24.580 You do not have to be attending in person to ask questions or make a statement. 00:02:24.650 --> 00:02:26.250 Just use the raise hand feature. 00:02:27.210 --> 00:02:30.610 I will now hand the meeting over to Elena, Jessica, and Jim. 00:02:40.850 --> 00:02:41.750 Everyone. 00:02:43.080 --> 00:02:51.080 Umm, so as usual, we we've come with discussion topics that can get the discussion started and sustain it. 00:02:51.780 --> 00:03:06.880 Umm, but if anybody has anything, you know that they're eager to get out before we start directing discussion with the topics we're going to open up the floor for that. 00:03:07.330 --> 00:03:13.900 So if you do have a direction you want to take the discussion regarding, we're producer reporting and payments. 00:03:13.910 --> 00:03:18.750 You're welcome to put up your hand now and we'll give you the floor and use that to get the discussion started. 00:03:25.760 --> 00:03:30.440 OK, Neal Cowles has raised his hand, so I will make you a presenter. 00:03:41.490 --> 00:03:42.070 Hey, Neal. 00:03:42.330 --> 00:03:42.640 Hey, Neal. 00:03:43.320 --> 00:03:44.360 Hello, can you hear me? 00:03:45.290 --> 00:03:45.440 Yeah. 00:03:46.750 --> 00:03:47.120 Wonderful. 00:03:48.740 --> 00:03:49.350 Yeah. 00:03:49.360 --> 00:03:59.610 So at the last meeting I heard some comments around the idea of not reporting at the product level and by product. 00:03:59.620 --> 00:03:59.890 I'm. 00:04:00.420 --> 00:04:00.570 I'm. 00:04:01.750 --> 00:04:24.680 I'm saying that as UPC, ISBN EAN umm I think there was some some comments around uh it would be difficult for producers to do this and there may be extreme volumes involved and so I I just wanted to kind of take a minute to dive into that issue a little bit deeper. 00:04:25.890 --> 00:04:31.740 Some questions I had and I'm not sure if Curtis Picard is is here or not. 00:04:31.790 --> 00:04:38.220 But he had mentioned a few things that I would I was just wanting to get some clarification on. 00:04:41.490 --> 00:04:45.790 I think the the 1st it's Curtis here. 00:04:47.270 --> 00:04:48.020 I think he is. 00:04:48.030 --> 00:04:50.480 I can Curtis if you want. 00:04:50.490 --> 00:04:52.130 Yeah, I can make you a presenter. 00:04:52.270 --> 00:04:52.570 OK. 00:04:52.220 --> 00:04:55.250 Hold right on and then they too. 00:04:55.490 --> 00:04:57.980 I'll make Andy a presenter as well right on. 00:04:57.820 --> 00:04:58.140 OK. 00:05:03.500 --> 00:05:28.720 Alright, so the the the first thing I'd like to talk about was the the sheer volume comment and that was I think Curtis had mentioned that there was some 160 million UPC's registered in the United States and that there was concern that the department or stewardship organization may not be able to to handle the volumes. 00:05:30.460 --> 00:05:33.510 And I guess uh, to that point, I would. 00:05:33.760 --> 00:05:50.570 I would just say that I would kind of like to separate the responsibility of the department and what the stewardship organization, what we suspect that they could handle because obviously if they need to handle it, we're building a lot of the stuff from scratch. 00:05:50.580 --> 00:05:59.160 And so if we know up front that we need to accommodate 160 million products at least, you know we can, we can accommodate that. 00:06:00.720 --> 00:06:17.300 So I guess that was the the first point I wanted to make and I didn't know if there was another comment about the the problems involved with obtaining this data at all. 00:06:18.020 --> 00:06:24.090 I'm specifically being able to determine if it was sold in Maine or New Hampshire. 00:06:24.200 --> 00:06:38.450 Maybe there's some blurriness, so I I didn't know if there were other specific problems around obtaining product level data that that we could discuss that would help steers one way or another. 00:06:40.660 --> 00:06:42.630 Sure, I'll can you guys hear me OK. 00:06:43.460 --> 00:06:43.670 Yep. 00:06:43.440 --> 00:06:43.920 Yeah, yeah. 00:06:44.360 --> 00:06:48.970 OK, so I knew I didn't catch the entirety of your question. 00:06:55.250 --> 00:06:55.490 OK. 00:06:48.980 --> 00:07:30.850 I came on a couple minutes late, so I think I caught the last 90 seconds 2 minutes or so, so I apologize if I missed some first part, but when I gathered, was your your have some questions regarding our comments from last time that there's likely to be, I don't know 160 million or so different UPC codes and that it's going to be very difficult either for the department or the stewardship organization to create some sort of database or list of anything that would be usable for anybody involved to understand which products are going to be compliant or non compliant with the there are system. 00:07:31.720 --> 00:08:08.440 So our understanding and what we had brought forward last time, which was actually built by experience that we had with Maine's recent pesticide fee, was that even with the 12,000 or so registered pesticide products in Maine, retailers were unable to create or the the Board of Pesticides Control was unable to create a database of those 12,000 products with any accuracy and it was impossible for a retailer to know which products were considered a pesticide and which ones weren't, which was the main impetus for that 15 cent fee for being repealed. 00:08:11.760 --> 00:08:11.880 Yeah. 00:08:08.850 --> 00:08:17.380 And so now that we're talking about all products, I think our point was that there's products entering and exiting the marketplace at all times. 00:08:17.390 --> 00:08:26.540 So it's never going to be static, so even you may have a product, there's likely to be a new size, a new flavor coming out in the time. 00:08:26.890 --> 00:08:35.020 So we just think it's going to be really challenging for anybody involved to put together any sort of master database. 00:08:35.030 --> 00:08:39.910 And I think we had some concerns about it being done at the UPC code level. 00:08:40.260 --> 00:08:54.030 I think Andy suggested that maybe there might be a way to do it more on a category type of level, so I don't know if that addresses your your question and maybe Andy has something more to add beyond that. 00:08:54.040 --> 00:08:58.560 But that's that's kind of what I gathered from what I did hear you say when I tuned in. 00:09:00.030 --> 00:09:00.250 Yeah. 00:09:00.260 --> 00:09:01.550 Yeah, that's that's that's good. 00:09:02.380 --> 00:09:03.520 Appreciate that. Yeah. 00:09:03.180 --> 00:09:03.730 Yeah, I'll. 00:09:03.740 --> 00:09:04.000 I'll just. 00:09:03.330 --> 00:09:04.360 So Curtis then. 00:09:04.900 --> 00:09:05.710 Ohh go ahead Andy. 00:09:06.730 --> 00:09:17.020 No, it's just gonna offer what we had suggested that still relies on the UPC or the the structure of the ISBN. 00:09:18.600 --> 00:09:25.010 Yeah, barcode system just would be reporting at the brick code level. 00:09:25.020 --> 00:09:33.770 So you would know, for example, that Frida Lay sells chips and there would be, you know, potentially, you know, some bifurcation within that. 00:09:45.960 --> 00:09:46.180 Yeah. 00:09:34.090 --> 00:09:48.380 And I'm not a database expert on how detailed the brick code level goes, but it wouldn't say that Frito-lay sells, you know, BBQ Ranch, you know, spicy hot vinegar, et cetera. 00:09:48.650 --> 00:10:17.370 That level of data in a different world in a different regulatory scheme, if we were trying to, you know, for example, the Department Overseas Chemical Regulation programs where the consumer might be trying to avoid a particular in, in a, in a consumer disclosure space might be trying to avoid purchasing something that might contain a chemical of concern that's that's a regulatory approach that that is familiar in the the Kids Safe Products Act. 00:10:18.100 --> 00:10:30.240 This obviously is just relative to paying the right amount of fees and tracking UPC codes versus overall volume. 00:10:30.790 --> 00:10:33.460 That is generally gonna be a more known factor. 00:10:33.770 --> 00:10:41.220 That you know that, that granular level, the same package it's being used across the 12 different flavors of chips. 00:10:41.670 --> 00:10:50.480 But Frito-lay knows that they're still in a certain volume of chips versus having to constantly have the pro and or the. 00:10:51.650 --> 00:10:55.480 Department received that information because it's a huge amount of data. 00:10:56.330 --> 00:10:56.490 Yeah. 00:10:55.770 --> 00:10:58.380 An example that's relevant in Vermont. 00:10:58.890 --> 00:11:07.050 They have a children's chemicals reporting program where they went down to the skew level actually and it's for just children's products. 00:11:07.060 --> 00:11:15.080 It's over 3,000,000 data hits and that it whenever you open the Excel spreadsheet it crashes and I know we can design like it around that. 00:11:15.090 --> 00:11:16.860 Perhaps because this is a new system. 00:11:16.870 --> 00:11:18.250 So and yeah, I take your point on that. 00:11:19.490 --> 00:11:22.920 But in terms of of the function of the law, right? 00:11:22.930 --> 00:11:32.680 Is is to deliver funding to assess packaging that all could be done at the brick code level without losing any performance. 00:11:32.690 --> 00:11:35.030 Sound of the the goal of the EPR system. 00:11:35.040 --> 00:11:42.020 I think in in our in you know collective our opinion and and also it's not done anywhere else in the world that I'm aware of. 00:11:42.030 --> 00:11:53.670 There are probably others that could jump in if I'm wrong and I'm happy to be correct on that, but the the reporting is that kind of that that brick code level versus the ranch etcetera. 00:11:53.680 --> 00:11:54.250 So late. 00:11:54.260 --> 00:11:54.570 I'm sorry. 00:11:54.580 --> 00:11:57.220 I didn't mean to cut you off, but that was that was kind of where we were going. 00:11:59.620 --> 00:12:00.650 Yet do you? 00:12:01.100 --> 00:12:08.170 I would love to see examples of other people that are using this this brick code for this reporting. 00:12:08.940 --> 00:12:12.660 If you know of any case studies or links, I would appreciate that. 00:12:14.120 --> 00:12:25.170 Yeah, I mean I the chemicals reporting programs that Maine uses Washington State and Oregon all use this brick code level. 00:12:25.180 --> 00:12:30.380 So I'm happy to find a way to try to share that off and I'll in the meantime here try to find those right. 00:12:30.390 --> 00:12:32.060 We don't have chat function on this, never mind. 00:12:34.150 --> 00:12:37.410 So you know, I'll try to find a way to get it to, you know. 00:12:38.920 --> 00:12:39.180 OK. 00:12:41.080 --> 00:12:49.970 And if so, if the the reporting is unobtainable at the lower product level. 00:12:51.250 --> 00:13:05.310 Ah, I guess I I I'm having a hard time seeing how producers would be able to build a a reliable report if they didn't have the the low level data accessible. 00:13:06.480 --> 00:13:08.650 Or maybe you're saying that it's accessible. 00:13:08.660 --> 00:13:14.990 It's just too hard to convey to an an outside party because of the volume. 00:13:19.620 --> 00:13:21.300 But it probably goes back to. 00:13:24.240 --> 00:13:32.750 The data is gonna be not at at the per unit per day sea level like we're not gonna be seen. 00:13:32.760 --> 00:13:38.840 Fees change daily to the PRO right, like you know, the second a bag is sold. 00:13:39.240 --> 00:13:42.690 The pro doesn't get $0.05 you know, or something like that. 00:13:43.760 --> 00:13:44.000 Yeah. 00:13:43.100 --> 00:13:45.090 Similar to the bottle deposit, right? 00:13:45.100 --> 00:13:55.180 Like, that's not how, because thinking too about the sequencing and the timing, there's constant has to be associated with packaging in general. 00:13:55.610 --> 00:14:11.020 And then there's money that will flow out in a future date and time, and then the PRO is gonna manage this, this budget, right based upon costs and achieving funding before the costs are actually reimbursed. 00:14:11.030 --> 00:14:22.780 So the PRO, at least in all the other sort of programs that again the regulation could certainly say differently here in Maine, potentially under the authority that's granted. 00:14:23.190 --> 00:14:30.490 But the PRO is going to establish that budget and they have the ability to make adjustments, right? 00:14:30.840 --> 00:14:53.060 But you're you're looking at the the volume of packaging and it it, you know probably early on like we've talked about and and I think the point was taken about population estimates and using that as a a proxy for you know what material it's sold in May you know we're going to get start getting more data back out of the system too. 00:14:53.070 --> 00:15:15.370 I'm assuming on what's what's it volume in in the system, but when it comes to to tracking skews and knowing exactly you know the the 15 units that were sold at a of a particular skew producers will get more generalized data back from may not be themselves, right? 00:15:15.380 --> 00:15:21.810 It might be from there's a group called NPD, which tracks data nationally and breaks it down to a certain markets. 00:15:22.230 --> 00:15:28.550 And then they might get different data back from their distributors and their retail partners. 00:15:28.560 --> 00:15:42.230 So manufacturer, what brand owner was probably the better term here because you know times that might be both retailers and your typical consumer goods companies, they're gonna get different data back from different points of distribution. 00:15:42.290 --> 00:15:45.450 So it's a whole lot easier. 00:15:45.460 --> 00:15:57.230 I mean just the the sending 165,000,000 skews to the PRO and saying 12 units, 5 units, 6 units, 10 units 1000 units. 00:15:57.560 --> 00:16:12.000 You know managing that data flow, is it the units and to a specific skew is a lot more complex in terms of of delivering that data and reporting it. 00:16:12.010 --> 00:16:22.660 The brick code level would still accomplish the characterization of the packaging that's used because it's, you know, when you get down to that sub level it's it's the same product. 00:16:22.670 --> 00:16:26.590 You know it's a red ball versus a blue ball, but it's in the same packaging. 00:16:27.580 --> 00:16:40.020 So from that perspective, you're not getting granular data that's gonna change fees and and you know, just adds a whole nother layer to the database that quite frankly. 00:16:42.260 --> 00:16:44.040 Gonna add complexity to the whole system. 00:16:45.760 --> 00:16:46.250 Yeah. 00:16:46.340 --> 00:16:46.900 Yeah. OK. 00:16:47.860 --> 00:16:48.000 Yeah. 00:16:49.000 --> 00:16:50.740 OK, OK, I understand that. 00:16:51.530 --> 00:17:00.420 Umm you you said something along the lines of reporting when something was sold. 00:17:00.680 --> 00:17:55.680 So I guess when when you're talking about this, are you, uh, and you you well we when you're saying product level data are you picturing in your mind that for every single transaction like a a point of sale transaction like this one unit was sold this one unit was sold this one I guess I I was thinking of of this more in terms of here's a product and for this time frame we sold this many of that product and I guess if it was at the brick level it would just be that this this brick number skew whatever this identifier is for this range we sold this many units so it's it's an aggregate of the individual transactions it's not the low level data but it's still attributable to a a particular product is does that make sense. 00:17:55.280 --> 00:17:56.070 Yeah. 00:17:56.380 --> 00:17:56.690 Yeah. 00:17:56.700 --> 00:18:00.630 And it's also gonna be less CBI too, with which we didn't really touch on before. 00:18:12.210 --> 00:18:12.370 Yeah. 00:18:00.640 --> 00:18:14.210 But you know, Frito Lays probably doesn't want their competitors to know that, you know, the atomic fireball chip flavors their hottest flavor for season, you know, cause there's the copy kind effect, too. 00:18:14.220 --> 00:18:15.020 So there's a little bit of that. 00:18:37.460 --> 00:18:37.640 Yeah. 00:18:15.030 --> 00:18:46.950 But yeah, I mean to if I understand your comment, it's you're still going to get data that is attributable to a brand owner uh and attributable to a product type that is in packaging because that's that's analysis that's still going to have to be done right, like you might be able to sell, you know, potato chips in a in a bag and maybe in the future they'll be drones that deliver paid potato chips. 00:18:46.960 --> 00:18:53.000 But I'm still really hung up on that idea like I like the idea of maybe a drone showing up and dropping potato chips, you know, in like a bowl. 00:18:54.830 --> 00:18:55.260 Everything. 00:18:54.530 --> 00:18:56.570 Yeah, and it may not have packaging, right. 00:18:57.150 --> 00:19:02.690 And so you're still going to have to as a producer. 00:19:03.450 --> 00:19:21.820 Understand the packaging that you're using and I you know, nationally and certainly what I heard from questions that were asked around you, maybe we allow national data without justification for the first five years. 00:19:21.830 --> 00:19:34.040 And then after that you have to justify, you know that there's and not state based data or state based data would be difficult and that's why you're using a a population you know approximate. 00:19:34.050 --> 00:19:54.270 But you're still gonna have to know within your product mix like bluntly 50% of our products were in plastic bags, 50% was in paper, you know, and that's that's the mix of our materials and the types that it was used in in order to pay your fees and also gets to how complex the eco modulation is. 00:19:54.680 --> 00:20:25.410 You know earlier in the system if if there's 15 different eco modulation factors either required in in the regulatory code, which again could be a possibility or if that's deferred to the PRO, it could have evolve with you know bluntly, yeah, if if if you eco modulation factors at a specific level or put it into regulatory code that's going to not change often unless there's, you know, deference somehow to the PRO. 00:20:25.470 --> 00:20:38.150 No, I'm not thinking of a way exactly the blend the two to make a hybrid, but you know your eco modulation factors, you know you're gonna get more complex into the few. 00:20:38.160 --> 00:21:00.560 I think everybody acknowledges that as we get more data and we get more experience with operating programs across the United States potentially again assuming that the PROs are the same, that that will get more data and they'll be greater ability to, eco modulate based upon certain factors that that's going to take some time to get to that level of granularity. 00:21:00.570 --> 00:21:04.830 And you know, to determine what, what's our optimal? 00:21:05.960 --> 00:21:07.320 Eco modulation mix. 00:21:07.330 --> 00:21:09.720 That's that's also not overly complex. 00:21:09.730 --> 00:21:09.870 Where? 00:21:10.950 --> 00:21:20.920 Yeah, you end up with a plus factor of two and a negative factor of 1 and a plus factor of three that you can do lots of different, you know potential. 00:21:22.340 --> 00:21:26.960 Now the algorithms, not the right word, but scoring around factors. 00:21:30.400 --> 00:21:30.560 OK. 00:21:26.970 --> 00:21:50.810 So, umm, the bank, I guess to to the shorter point of the the brick level should give both producers the stewardship, organization and department a level of understanding in detail that doesn't have to be 165,000,000 but might be 10 million. 00:21:51.710 --> 00:21:52.280 Umm. 00:21:52.430 --> 00:22:00.450 In terms of categories, perhaps, it's probably actually less than that, but you know categories that are in packaging. 00:22:02.330 --> 00:22:14.610 Yeah, as long as the packaging is identical to everything within the the brick code that seems I I can't think of a reason not not to bubble it up to that level. 00:22:14.880 --> 00:22:35.670 I I do think that I I heard the the concern about wanting to protect the the numbers of a producer and letting everyone know that Frito-lay sold this many fire whatever chips, you know, that's potentially useful information. 00:22:36.240 --> 00:22:36.570 Umm. 00:22:37.100 --> 00:22:42.450 And producers is probably would like to to advocate that somehow. 00:22:42.520 --> 00:22:46.190 So this seems like it would be a good good way to kind of shield them from that. 00:22:46.200 --> 00:22:49.280 So I think that's a really solid point about this, so. 00:22:53.400 --> 00:22:54.210 The brick codes. 00:22:57.420 --> 00:23:07.750 I'm not very aware of how a brick code versus UPC code gets assigned to a product and what. 00:23:07.790 --> 00:23:08.650 How can we? 00:23:08.720 --> 00:23:11.980 Where should we look to learn a little bit more about that system and how that just works? 00:23:13.270 --> 00:23:13.910 How does that happen? 00:23:13.750 --> 00:23:18.960 I mean, I think the department's got some experience that the Kids Safe Products Act level, right? 00:23:18.970 --> 00:23:19.570 So I know Kerri Malinowski. 00:23:21.310 --> 00:23:26.320 There's not been an incredible amount of data that has been required to be reported. 00:23:26.620 --> 00:23:39.810 You know, based upon the categories that have been prioritized and identified under the Kids Safe Products Act, I think you know there's about 8:00 or 10 chemicals that actually have required data submissions and then you know, move forward with restrictions. 00:23:40.570 --> 00:24:04.830 Umm, but there's some experience there that Kerri may be able to to explain Washington State Department of Ecology under their Children's Safe Products Act was this sort of the they were the foundational users of trying to decipher what level data should be reported. 00:24:05.430 --> 00:24:05.670 Umm. 00:24:05.070 --> 00:24:27.470 So from a Regulatory agency perspective, uh, they, they, they would sort of the first decision that we're not gonna go down to a skew level of reporting that was made by the Department of Ecology back in 20 been 2010 time, 2009, 2010 time. 00:24:27.480 --> 00:24:39.400 But time frame that they went through sort of that evaluation, but there's obviously existing staff there that are you know managing and that type of of reporting. 00:24:39.510 --> 00:24:43.180 And then the Interstate Chemicals Clearinghouse, too, run out of NEWMOA. 00:24:43.790 --> 00:24:50.680 And they manage the database that feeds into Washington State and Oregon currently. 00:24:50.950 --> 00:24:57.990 Now Oregon, depending upon what they do, they they, they may go down to a SKU level and just be full transparency. 00:24:58.000 --> 00:25:33.720 Here again, it's a different regulatory program where where consumers are potentially wanting to choose between different products, Oregon to see the governor's not signed the bill yet, no Oregon, but Oregon may deviate and go down to brand name, product model reporting Vermont like I mentioned is at a SKU level for children's products reporting and that's why they cannot participate at least currently as my understanding they cannot participate in the Interstate Chemicals Clearinghouse database for reporting because they go down to a SKU level and nobody is paid for the database to go down to a SKU level yet. 00:25:33.730 --> 00:25:39.320 So I would say Washington State and NEWMOA on the database structures. 00:25:39.330 --> 00:26:06.700 Probably you know you're sort of colleague type experts on this issue and then the the organization that owns the GDS, I think it's GDSN or going back here about the decade and and experience with with creation of those programs, but the underlying database system is owned by, I think it's still, I think it's a private company that manages that database, but it feeds down to all the retailers. 00:26:06.710 --> 00:26:12.460 And I mean it's what allows us to scan a product, you know, in a Hannaford and a Shaws. 00:26:12.470 --> 00:26:18.270 And you don't have to change the the barcode on the back of of that product. 00:26:18.280 --> 00:26:29.050 So there's there's commonality in that and and so that's and I know with QR codes there's, you know maybe some competition that space. 00:26:29.060 --> 00:26:33.150 But I think it's GDS, GDSN or GDS one. 00:26:33.400 --> 00:26:38.170 Anyway, they're the they're the owner of the database that feeds out into this whole system. 00:26:40.620 --> 00:26:40.830 Because. 00:26:43.880 --> 00:26:44.080 Yeah. 00:26:47.320 --> 00:26:54.940 Is anybody aware of how this umm, I don't know if Susan Bush is on here? 00:26:55.590 --> 00:27:08.730 How this relates to the so the Canadian programs, umm, in their advice to producers have this average bill of materials method. 00:27:10.060 --> 00:27:14.630 Uh, I think that is a little broader than the brick coat. 00:27:14.640 --> 00:27:32.820 And I I don't know if anyone is able to speak to that, but it's, you know it's it's an ability for producers to write group products that they have that have like packaging and or reporting reporting purposes. 00:27:33.270 --> 00:27:39.920 But I think it I think it's even allows the like packaging if it's different sizes and then it sort of averages sizes. 00:27:40.850 --> 00:27:44.900 Umm, looks like nobody knows what I'm talking about. 00:27:44.950 --> 00:27:46.090 Anyone what I'm talking about? 00:27:47.430 --> 00:27:49.270 No, they have to go there then. 00:27:50.140 --> 00:27:52.180 Umm yeah. 00:27:52.190 --> 00:27:59.050 Our question regarding that was, yeah, how are brick codes relevant when identifying products with life packaging? 00:28:00.050 --> 00:28:04.330 But yeah, it sounds like we have other places we can look for that information, OK. 00:28:15.840 --> 00:28:16.140 I think. 00:28:15.190 --> 00:28:16.340 Could you wanted to for this right? 00:28:18.150 --> 00:28:20.180 Yeah, I don't think we it doesn't sound like anybody. 00:28:20.530 --> 00:28:23.100 It's kind of place to talk about anyone. 00:28:23.370 --> 00:28:23.700 OK. 00:28:23.710 --> 00:28:25.850 OK, we've exhausted that. 00:28:25.900 --> 00:28:26.200 Yeah. 00:28:26.210 --> 00:28:27.280 OK, that's OK. 00:28:27.470 --> 00:28:28.340 Well, thank you all. 00:28:28.770 --> 00:28:29.790 Yeah, it's very helpful. 00:28:29.800 --> 00:28:30.630 Yeah, very helpful. 00:28:33.720 --> 00:28:35.880 So we went to the top of our list, eco modulation. 00:28:40.510 --> 00:28:42.430 Can I just add one additional comment? 00:28:43.600 --> 00:28:43.830 Sure. 00:28:44.450 --> 00:28:55.240 We wrap that section up because I was just rescanning the law and I just wanted to be clear in my mind when we're talking about UPC's, this is the section of the law where. 00:28:56.860 --> 00:29:10.040 You know the department is going to be responsible for maintaining a publicly accessible website with a regularly updated list of products which are considered compliant or noncompliant. 00:29:10.250 --> 00:29:29.840 And as someone representing retailers, I mean this has been my concern from the get go that it's gonna put retailers in a difficult position of trying to police what products are are not compliant with also the understanding that it's going to be impossible for the department to maintain this this website. 00:29:29.850 --> 00:29:34.340 So it really doesn't have to do my and I'm just I guess more of a question. 00:29:34.600 --> 00:29:40.140 This isn't the section of law that has to do with the reporting of the materials and the fees being paid. 00:29:40.290 --> 00:29:48.480 This is really just which products are allowed, are compliant with the law and which ones aren't, and how that's going to impact retailers. 00:29:48.910 --> 00:29:50.250 Am I understanding that correctly? 00:29:51.570 --> 00:29:55.800 Well, I think, I mean, I think it's very applicable to producer payments. 00:29:55.810 --> 00:29:59.040 I think that's the context that Neal and Andy are Speaking of it in. 00:29:59.350 --> 00:30:03.300 But but right you the law also requires the department to have a list. 00:30:05.840 --> 00:30:08.290 I believe, I mean, you're aware of the fact that there's no. 00:30:09.340 --> 00:30:13.250 Responsibility for retailers to not. 00:30:13.360 --> 00:30:15.230 There's no do not sell for retailers. 00:30:15.720 --> 00:30:24.910 You know they they it's it's unlike some of our other laws that make it illegal for a retailer to sell something that's not compliant. 00:30:25.010 --> 00:30:25.170 Right. 00:30:25.990 --> 00:30:31.880 So in that sense, the retailers don't have that same burden, but I take it you're suggesting. 00:30:31.890 --> 00:30:34.270 So like I was gonna, this is what I was gonna ask before. 00:30:35.220 --> 00:30:47.740 You're suggesting that that list in order to be useful to retailers, really should be more of like a brand product type list like it should be. 00:30:48.670 --> 00:30:50.220 Umm, it should be. 00:30:50.010 --> 00:30:50.760 Perhaps yeah. 00:30:51.540 --> 00:31:07.580 You know those potato chips as opposed to a bunch of, you know, it it in my mind, I I almost feel like as a retailer and and once again you brought up the the numbers issue. 00:31:07.670 --> 00:31:19.950 But if I wanted to check against this, I would want to have an Excel spreadsheet that had all in my UPC codes and I wanna have a Excel spreadsheet that I had all the departments, UPC codes and I'd wanna just. 00:31:22.260 --> 00:31:38.510 Right in there a function and make it spit out anything that was different between the two lists versus I would think would be much easier to do that than to have a list that says Frito lays potato chips and lays potato chips and whatever. 00:31:38.520 --> 00:31:40.180 They're Humpty Dumpty potato chips. 00:31:40.660 --> 00:31:48.520 And then I have to like manually read the list as opposed to right because it might not be exactly the same. 00:31:48.530 --> 00:31:49.760 I can't just compare a list. 00:31:49.770 --> 00:31:50.260 I would. 00:31:50.330 --> 00:31:55.840 I would think that it would be a lot more efficient to have something with a number that's a set number. 00:31:55.850 --> 00:32:01.290 That's not going to change so that you can have a computer compare the lists as opposed to something that's like. 00:32:03.820 --> 00:32:09.710 A full brand name written out and it might not be written the same way in two different lists, and so I actually have to read it. 00:32:10.000 --> 00:32:10.720 Does that make sense? 00:32:11.960 --> 00:32:13.830 It does, but that's that's. 00:32:14.470 --> 00:32:21.130 That's why with our experience with the with the list of pesticides, the list was constantly changing. 00:32:21.500 --> 00:32:40.930 And even though the the the you know board of Pesticides Control tried to compile a list of UPC because we thought that would be the way to kind of fix this problem or to try to address it and would ended up being impossible to do, you know, and I would, I would. 00:32:41.290 --> 00:32:54.820 I would urge you to give Megan Patterson a call because you know we we spend a lot of time trying to figure out how to make that law work, and we all eventually came to the conclusion that it was just too difficult to do so. 00:32:55.130 --> 00:32:58.800 That's just such a small subset of products as well. 00:33:01.740 --> 00:33:05.490 It and when it comes down to, we're really looking for here, right? 00:33:05.500 --> 00:33:07.940 Is that the producer is compliant? 00:33:09.000 --> 00:33:09.420 Right. 00:33:09.970 --> 00:33:10.170 Like. 00:33:10.200 --> 00:33:10.540 Right. 00:33:09.740 --> 00:33:10.600 It's not the same. 00:33:10.610 --> 00:33:13.020 There's no requirement on the on the retailer here. 00:33:13.900 --> 00:33:14.290 Right. 00:33:14.300 --> 00:33:49.410 And so the producers compliance is not inherent upon delivering unless the UPC codes, right, it's it's it's contingent upon them paying appropriate fees and and you know participating in the stewardship organization, it's not that that that they're screening each SKU because you're gonna get each UPC for premarket approval to be sold in Maine. 00:33:49.780 --> 00:33:50.280 Right. 00:33:50.340 --> 00:33:51.030 Like you're not. 00:33:51.200 --> 00:33:51.380 But. 00:33:51.040 --> 00:33:59.090 You're not registering your UPC code every time you go to sell a new flavor of chips in Maine, right? 00:33:59.100 --> 00:34:03.840 Because that's that's what we do on pesticides and that's there's. 00:34:03.850 --> 00:34:06.540 And there's more to to, to Curtis's point. 00:34:07.430 --> 00:34:20.350 There is premarket registration for pesticides in Maine and nationally, and so you start out with even a better data it it better regulatory structure from a from gaining this information's perspective. 00:34:20.820 --> 00:34:25.150 Then you do in this law and in commerce in general, right? 00:34:25.160 --> 00:34:33.110 There are only two or three different categories of products that need pre market approval before selling the consumer good in the United States. 00:34:33.360 --> 00:34:37.930 Pesticides, drugs and some cosmetics, right? 00:34:37.940 --> 00:34:49.270 Like those are the only things that need premarket approval to go into into commerce and you know, to to begin to sell product. 00:34:49.320 --> 00:34:50.430 You learn these things right? 00:34:50.440 --> 00:34:53.670 OK, I need a UPC code and I go to GDSN but it's not. 00:34:54.050 --> 00:34:59.060 It's not like the system is structured in a way that you know, you know it. 00:34:59.070 --> 00:35:04.700 Hackman chips can't sell his chips until he's registered with the state registered with the PRO. 00:35:04.840 --> 00:35:12.810 And only things you get into the marketplace and then you you make sure that you're able to sell through your retail channel partners and and and that. 00:35:13.780 --> 00:35:18.730 And so again, going back to kind of the the the meat of the UPC code is not a mother. 00:35:18.740 --> 00:35:20.950 May I sell when be in compliance? 00:35:20.960 --> 00:35:30.080 It's the producers obligation to ensure that they're properly accounting and you know to fulfill the reference to the UPC code. 00:35:31.060 --> 00:35:44.950 Again, the databases is is built around that and you can get a level of data that I think in could be to this whole idea of the public facing versus not public facing database. 00:35:44.960 --> 00:35:47.270 It's it's still a confusing concept all of us. 00:35:47.280 --> 00:36:01.690 I mean, right, obviously during legislative process we some of us are raised concerns, but you know it it's not something where a consumer is gonna say, hey, I'm not buying, you know, this bag of freedom always because it's not on the the departments list. 00:36:03.320 --> 00:36:11.920 And then you also run into the problem of like you introduce a product midway through the year and the department hasn't updated their database yet or updated the list. 00:36:11.930 --> 00:36:14.000 And like you know, you're not consumers. 00:36:14.010 --> 00:36:15.220 Not gonna stand there and not buy it. 00:36:15.230 --> 00:36:15.840 It's right. 00:36:15.850 --> 00:36:17.900 Like that's, that's where it feels like. 00:36:17.910 --> 00:36:25.790 This is a an oddly placed requirement on the department, in particular to publish this information. 00:36:25.860 --> 00:36:36.370 So you know we I think we can fulfill the obligation of providing data at this brick code level to the department. 00:36:36.740 --> 00:36:39.350 I think you are gonna have some, you know. 00:36:41.780 --> 00:36:50.830 It's it's probably most understandable to the retailer into a consumer at a brand you know level like you know Frito-Lays chips are compliant. 00:36:50.960 --> 00:37:21.890 You know, and participating in the program, so maybe there is like a you know, a market pressure that if retailers are seeing that you know hackman's chips based in New Hampshire, I haven't registered with the PRO and I'm you know managing to sell at farmers markets and fly under the radar like there could be that you know maybe that's where the where the intent is that they'll be this market pressure to get into compliance and it becomes sort of a yeah pleasing mechanism. 00:37:21.900 --> 00:37:44.160 So that there are no free riders in the system, you know, but for for those that that are registered with the SO and you know achieving compliance yearly based upon the fees, this doesn't, it's not it's not really a you mean you're already in compliance because you paid your fees to the state or not to the state to to the SO. 00:37:44.880 --> 00:38:04.130 So there's a bit of a disconnect, I think, between this idea that the publicly facing list is is something that's ensuring that that every little, you know, piece of of packaged product that comes across the border or is made in Maine is is suddenly registered in, in this global system of compliance. 00:38:04.140 --> 00:38:05.150 I mean, you're in compliance. 00:38:05.160 --> 00:38:06.770 If you paid your yearly dues right? 00:38:06.780 --> 00:38:07.940 Like so. 00:38:09.400 --> 00:38:19.110 It's just a matter of tailoring those fees based upon your packaging mix for the year and what's you know, what's actually sold from a volume standpoint. 00:38:19.120 --> 00:38:23.760 But it's not that you know you have appropriately registered every SKU number. 00:38:25.270 --> 00:39:00.490 So and you know for the for the retailers right they could also say to their what's what's what is happening in the marketplace right now, whether it's recycled content, or the EPR, you know, as we get into implementation retailers that don't have their own brand are saying to their producers like certified to me that you're in compliance like that's that is the easiest way for a retailer because if you don't do that. You're not going to be sold. You know on on the shelf. Uh and and that you know fulfills. The retailers obligation you. 00:39:00.500 --> 00:39:18.090 I've got certificates of compliance or statements from, you know, 1000 of my suppliers that they are complying with Maine's and I sell and in Maine on based in Maine and playing with complying with main EPR law and it it keeps the responsibility where it should be with the producer. 00:39:18.460 --> 00:39:32.450 Obviously it's a little different if the producer or if the retailer has their own brand name and are the producer of the the item, but you know for the for just the sole retailer that doesn't assume the responsibility of a producer. 00:39:33.700 --> 00:39:40.060 You know, but that's probably the easiest way for them to ensure what they're selling is in compliance with this law. 00:39:42.640 --> 00:39:43.010 Umm. 00:39:43.600 --> 00:39:50.640 And that's and like I said, that's happening, you know, for recycled content and and other laws that are a little bit earlier on implementation cycle. 00:39:53.880 --> 00:39:54.890 So I think that makes sense. 00:39:54.900 --> 00:40:05.430 The list that list the department has to put out is a relic of there used to be a piece that required retailers to not sell, and that piece was removed from the law. 00:40:05.660 --> 00:40:07.250 And so it's kind of just like a relic. 00:40:18.770 --> 00:40:18.890 Yeah. 00:40:07.260 --> 00:40:20.360 But you're I think, Andy, you might plan to something in terms of like the best use for that list is a way for someone to easily check for free riders and that would be at the brand level, which I believe is what Curtis was suggesting as well. 00:40:21.430 --> 00:40:22.710 Yeah, that makes sense. 00:40:24.650 --> 00:40:28.010 And that's different than obviously very distinct from whatever producer. 00:40:28.070 --> 00:40:32.430 Of course, yeah. 00:40:32.480 --> 00:40:33.160 Good, great. 00:40:33.900 --> 00:40:34.230 Thank you. 00:40:41.040 --> 00:40:44.570 OK, just great. 00:40:44.580 --> 00:40:45.050 Well, thank you. 00:40:45.060 --> 00:40:45.430 I'm gonna. 00:40:45.440 --> 00:40:45.670 Yeah. 00:40:45.680 --> 00:40:46.530 Thank you so much. 00:40:46.540 --> 00:40:47.220 Thank you very much. 00:40:47.230 --> 00:40:47.950 That was great. 00:40:48.040 --> 00:40:50.680 I'll move you all to just attendees for now. 00:40:54.470 --> 00:40:55.010 Pretty sure. 00:40:52.110 --> 00:40:55.680 I I had one last comment make that real quick. 00:40:56.740 --> 00:40:57.000 Yeah. 00:40:57.010 --> 00:41:12.240 I I just wanted to put the idea out there that as we're going through this process not to be too constrained by the tools that were familiar with, like everybody uses Excel and so a lot of people use that to view data. 00:41:12.320 --> 00:41:25.430 So they assume that that's what I would be using and if you know that something has more than 33,000 rows, you know that you won't be able to use Excel, so you automatically shy away from large data sets. 00:41:25.440 --> 00:41:36.830 And so I'm just saying don't allow the constraint of the present tools that we have to influence, like doing the right thing and and getting the the right data. 00:41:39.670 --> 00:41:40.140 Yeah. 00:41:40.250 --> 00:41:44.730 So just just keep that in mind because we can, we can always build new tools. 00:41:47.090 --> 00:41:47.760 Thank you. 00:41:47.890 --> 00:41:48.450 Thanks, Neal. 00:41:55.190 --> 00:41:57.360 Just stay in, no. 00:42:08.670 --> 00:42:08.910 Yeah. 00:42:15.100 --> 00:42:20.130 OK, so that first conversation kind of put us in producer reporting. 00:42:20.140 --> 00:42:21.560 So we're going to stick there. 00:42:21.570 --> 00:42:26.020 We have some additional discussion topics to add. 00:42:26.920 --> 00:42:27.260 Umm. 00:42:29.070 --> 00:42:31.430 Unless someone else wants to. 00:42:33.080 --> 00:42:33.500 Uh. 00:42:33.800 --> 00:42:41.430 To a topic that they had in mind from the comment sharing meeting, I'm gonna put a hand up. 00:42:42.020 --> 00:42:42.410 No. 00:42:42.990 --> 00:42:43.990 OK, cool. 00:42:45.000 --> 00:42:49.960 Susan Bush has her hand up, so I will make you a presenter. 00:43:04.300 --> 00:43:10.190 Hey Susan, we made sure presenter you should be able to speak to us. 00:43:10.850 --> 00:43:19.340 Hi there I was trying to weigh in a little bit earlier and my mouse is on its last leg so I think it needs to be better so bear with me. 00:43:17.100 --> 00:43:20.120 OK, no problem. 00:43:20.050 --> 00:43:38.720 So you had asked, though, about in Canada, if they were reporting by specific product level and so on and not necessarily, I mean they do have the opportunity to collapse product learning data and report on take a reasonable cereal. 00:43:39.210 --> 00:43:40.600 You know, like the potato chip example, but. 00:43:43.030 --> 00:43:47.820 There are guidance document that they put out there that I gave the link to use a cereal boxes that was an example. 00:43:47.830 --> 00:43:56.090 Pretty basic packaging similar, so they're just report on like product types with basically the same types of packaging and same sizes. 00:43:56.100 --> 00:44:01.570 So they can collapse those and they're reporting to the PRO. 00:44:02.120 --> 00:44:08.910 The total weight of the packaging essentially, so the numbers of units and the total weight just sort of rolling up that data as it makes sense. 00:44:08.920 --> 00:44:17.740 So no need to get in, you know, to get into that really detailed SKU level data, they're simply reporting the weights, the numbers and the weights of the packaging. 00:44:20.120 --> 00:44:20.530 That makes. 00:44:20.300 --> 00:44:25.630 So, Susan, I was wondering if that we've been calling it ABOM. 00:44:26.280 --> 00:44:28.580 Umm yeah. 00:44:30.830 --> 00:44:31.050 Umm. 00:44:39.490 --> 00:44:40.340 It does seem like it. 00:44:41.500 --> 00:44:43.330 Umm, no, I agree. 00:44:28.270 --> 00:44:43.700 Uh, average bill of materials with as it relates to the brick code, it seems like that is their potentially multiple brick codes wrapped up in that I don't know how familiar you are with the the brick codes, but there are multiple. 00:44:44.950 --> 00:44:51.600 Umm, it does seem like it would be a a higher level of data for like types of packaging products and like packaging, yes. 00:44:55.020 --> 00:44:56.690 Including right, like different sizes. 00:44:57.330 --> 00:44:57.630 Right. 00:44:59.000 --> 00:44:59.420 Umm. 00:44:59.020 --> 00:45:07.610 They they would provide different sizes in a different, let's say lower data, for example a different category, just because it's a different weight of a package for example. 00:45:06.310 --> 00:45:07.690 Subgroup, yeah. 00:45:07.620 --> 00:45:11.980 So they would collapse based on those logical parameters, yeah. 00:45:12.920 --> 00:45:13.600 Sizes, yeah. 00:45:15.780 --> 00:45:27.030 Because essentially it's all weight based by material type, and there's plenty of products that some of these producers are selling that they can just collapse because they're so similar. 00:45:31.590 --> 00:45:37.720 So I I do notice your law does say specify UPC correct and I don't know if that what that means. 00:45:37.710 --> 00:45:38.340 It does. 00:45:40.540 --> 00:45:41.650 You could say sorry. 00:45:38.350 --> 00:45:43.170 You be it does specify UPC, but I think we could probably we could probably. 00:45:44.710 --> 00:45:48.640 Since I'm sure we could, I think there's probably some space for the. 00:45:49.400 --> 00:45:49.750 Umm. 00:45:51.060 --> 00:45:53.600 Particularly if it's so logical that nobody has a problem with it. 00:45:54.450 --> 00:45:55.410 OK, right. 00:45:58.530 --> 00:45:58.910 Umm. 00:46:02.650 --> 00:46:03.860 I don't want to cut you off, Susan. 00:46:05.050 --> 00:46:05.440 You had to. 00:46:05.040 --> 00:46:06.230 No, no, that's all. 00:46:06.270 --> 00:46:07.640 That's where all kind of just say. 00:46:12.150 --> 00:46:15.610 We did have one other question sort of in that area that seemed like. 00:46:15.620 --> 00:46:20.870 So one of the things that the rules need to do is allow for producers to. 00:46:22.190 --> 00:46:24.570 Report units instead of weight? 00:46:25.900 --> 00:46:26.300 Umm. 00:46:27.430 --> 00:46:29.140 And one of the thoughts that we had is. 00:46:31.710 --> 00:46:34.320 Is that ABOM method? 00:46:34.410 --> 00:46:39.320 You know an acceptable way of reporting units. 00:46:43.680 --> 00:46:43.980 Or. 00:46:47.660 --> 00:46:48.200 Or is that? 00:46:47.570 --> 00:46:48.450 No, I see that. 00:46:48.920 --> 00:46:51.830 I think each unit is associated with weights of different. 00:46:51.920 --> 00:46:52.570 You know, whatever. 00:46:52.860 --> 00:47:04.030 Whatever materials are in the packaging type, so it's collapsed by SKU or you know product but it's, but it's still would include weights. 00:47:05.770 --> 00:47:06.720 Right, right. 00:47:06.730 --> 00:47:08.800 It it, it still provides an accurate weight. 00:47:10.010 --> 00:47:10.150 Yes. 00:47:15.550 --> 00:47:17.110 And then it's hard for me to understand. 00:47:17.120 --> 00:47:28.730 I guess it's a little hard for me to understand, so this this need to be able to provide units instead of weight requirements a little bit hard for me to understand where that came from and what in what situation. 00:47:27.780 --> 00:47:29.550 Seems like you need both, yeah. 00:47:28.740 --> 00:47:41.130 See in the producers would know their units, but not be able to get their weights, particularly not using a system like that where you say, well, I have all these products in this same packaging and this is what that packaging is. 00:47:43.650 --> 00:47:44.060 Exactly. 00:47:41.140 --> 00:47:47.720 And I multiply it by the units and that's what I get like I I have a little bit of trouble understanding the need to report units. 00:47:50.370 --> 00:47:52.250 And as a result of that, I think I don't. 00:47:53.440 --> 00:47:58.950 I'm not very clear on how we would allow for reporting of units and not weight. 00:47:58.960 --> 00:48:04.890 I mean, I assume they would know the basic packaging type of those units. Umm. 00:48:07.680 --> 00:48:08.030 Right. 00:48:08.040 --> 00:48:11.300 That would definitely be necessary data for sure. 00:48:12.210 --> 00:48:12.350 Yeah. 00:48:18.120 --> 00:48:28.220 So are there any producers that that maybe could speak to a need to just stick to just pure unit numbers? 00:48:28.500 --> 00:48:31.490 In their reporting stance. 00:48:36.970 --> 00:48:43.680 That might be aware of, you know, what discussion happened to put that requirement in the law. 00:48:49.380 --> 00:48:50.290 OK. 00:48:50.580 --> 00:48:51.130 Thanks. 00:48:51.560 --> 00:48:52.140 Thanks, Susan. 00:48:52.150 --> 00:48:52.480 Thanks Susan. 00:49:03.900 --> 00:49:04.160 OK. 00:49:11.640 --> 00:49:11.980 OK. 00:49:12.030 --> 00:49:16.190 So we're kind of in, yeah, estimating the amount of packaging. 00:49:18.070 --> 00:49:41.660 So we also explored the Canadian PROs and they they allow for simplified reporting and packaging with some components and we pull those components we wanted to share them with you to get your thoughts about whether to use these rules and why or why not. 00:49:42.600 --> 00:49:43.110 Umm. 00:49:44.640 --> 00:50:06.850 So these rules allow for simplified reporting from the producers, and one of the rules is if a packaging component weighs less than 5% of the overall weight of a product's total packaging, then the steward may report the weight of the component under the material category that represents most of the packages weight. 00:50:09.730 --> 00:50:18.110 So in general, right now we're talking about packages that are not just a potato chip bag, but that have multiple layers. 00:50:18.120 --> 00:50:19.470 And like your cereal. 00:50:19.480 --> 00:50:22.710 And so these smaller pieces, how do you deal with those in the reporting? 00:50:23.440 --> 00:50:24.280 Sorry didn't. 00:50:24.290 --> 00:50:32.400 Yeah, I think there's also referred to as an ancillary, some some correct, that's not quite well. 00:50:32.460 --> 00:50:33.950 To compound a component of. 00:50:34.180 --> 00:50:35.200 So that's one rule. 00:50:37.120 --> 00:50:54.000 Umm, if the packaging component this is another one weighs more than 5% and remains attached to the packaging when the consumer discards the packaging, then the steward is required to report the packaging component under the material category that represents most of the packages weight. 00:51:03.050 --> 00:51:04.580 These are, yeah, just rules. 00:51:04.830 --> 00:51:11.060 And there's one more, but it doesn't seem like we have any producer perspective on the call today. 00:51:11.070 --> 00:51:29.610 So I might not get too far with this, but the third rule is if the packaging component weighs more than 5%, it will not remain connected to the packaging when the consumer disposes of it, then the steward would be required to report the packaging component under the material category associated with the packaging component. 00:51:31.860 --> 00:51:34.590 Are there any objections to using these rules? 00:51:38.580 --> 00:51:43.190 Any hesitancies, any opinion? 00:51:48.620 --> 00:51:49.110 There's Andy. 00:51:54.340 --> 00:51:55.610 Making Andy a presenter. 00:52:06.160 --> 00:52:06.950 Should be good, Andy. 00:52:07.280 --> 00:52:07.700 There we go. 00:52:07.710 --> 00:52:09.570 Not not an objection. 00:52:09.960 --> 00:52:12.190 You rattle those off with the I'm trying to. 00:52:12.330 --> 00:52:15.460 It's been 2 weeks since I read through the background document again. 00:52:15.530 --> 00:52:17.580 Was that in the background document or these? 00:52:18.200 --> 00:52:20.010 No, they're not in the background document. 00:52:20.020 --> 00:52:20.350 So. 00:52:20.360 --> 00:52:31.160 So these are from Susan shared the data call the guidance for reporting guidance used by a number of the Canadian PRO's. 00:52:31.790 --> 00:52:31.990 Yeah. 00:52:36.880 --> 00:52:37.810 Yeah, got. 00:52:44.790 --> 00:52:45.010 Yep. 00:52:31.670 --> 00:52:46.400 And their way of dealing with these component packaging parts is first put it into under 5% of packaging, waiter over 5% and if it's under 5%, they say just report it with the main packaging reported. 00:52:46.410 --> 00:52:51.380 And if it's over that 5%, they say, well, does it go with the package when you throw it away? 00:52:51.390 --> 00:52:53.720 If so, reported under the main component. 00:52:53.730 --> 00:52:57.850 If or does it go by itself, and if not, if it goes by itself reported separately? 00:52:58.680 --> 00:52:58.900 Yep. 00:52:58.510 --> 00:53:04.730 Umm, we obviously have to have a way of dealing with that and we're wondering if this is the way or if there's better way. 00:53:07.700 --> 00:53:13.660 And if it did, I would just say generally, I mean be good for us to review that with with folks. 00:53:14.070 --> 00:53:20.700 Susan's plugged into a number of the same folks that we'd be plugged into, so I've got some trust and faith there that that it lines up. 00:53:21.090 --> 00:53:32.530 I would say generally without vetting it through any of our producers, that if it's consistent with the Canadian approach, that's obviously you know what we're looking to replicate here. 00:53:34.940 --> 00:53:47.970 I if I personally understand the consistency, I think that those particular rules set up some not awesome incentives. 00:53:49.010 --> 00:53:49.250 OK. 00:53:48.800 --> 00:53:50.210 I mean, I'm just imagining. 00:53:50.220 --> 00:54:02.700 So, for instance, that would mean that a unless we do something slightly different, that would mean that a pasta box that has a plastic window in it. 00:54:03.680 --> 00:54:07.480 Umm is treated the same as a plastic pasta box that doesn't have a plastic window. 00:54:08.900 --> 00:54:09.850 One of them is obviously. 00:54:11.240 --> 00:54:19.350 Preferable in terms of the materials management standpoint, UMM for example. 00:54:21.980 --> 00:54:25.710 I feel like there should be a difference between those two. 00:54:28.500 --> 00:54:28.820 Umm. 00:54:32.170 --> 00:54:42.760 I guess another example would be the the full sleeve labels on a bottle. Umm. 00:54:46.020 --> 00:54:46.550 There's Susan. 00:54:47.880 --> 00:54:49.310 I'm just sort of talking. 00:54:49.320 --> 00:54:58.640 I I have a bit of a problem with these I guess is my and I'm and I'm wondering how we can sort of be consistent to the extent possible, but also maybe. 00:55:03.370 --> 00:55:11.640 Acknowledge the fact that these multimaterial these component parts are actually some of the more problematic pieces and things that we do want to yeah. 00:55:11.650 --> 00:55:12.710 Add contamination. 00:55:12.760 --> 00:55:13.460 Right, that's what. 00:55:13.470 --> 00:55:14.260 Yeah, right. 00:55:17.710 --> 00:55:19.710 And to them even made a presenter too. 00:55:21.270 --> 00:55:21.830 Well, I mean. 00:55:21.550 --> 00:55:24.030 Yeah, I I've just talking off my head. 00:55:24.040 --> 00:55:25.640 I'm not not representing anybody. 00:55:25.650 --> 00:55:31.310 These are my own thoughts, but I don't know if you all are very familiar with the California, California's law. 00:55:31.580 --> 00:55:37.070 It's quite complex because it's obviously it makes a distinction between plastic. 00:55:37.120 --> 00:55:43.550 It's got several benchmarks and targets that that pertain to plastics only, including plastic components. 00:55:43.740 --> 00:55:58.740 So the data reporting for California is going to be way, way, way more complex because they require separate reporting for four components of packaging and whether they're plastic or not. 00:55:58.750 --> 00:56:10.790 And then they've got it for some reason separated into less than two inches and over 2 inches, and it just different size categories and it makes for a very complex reporting system. 00:56:10.940 --> 00:56:25.340 And I'm not a database expert, so this is just my my gut feeling super complex and some of those concerns that you were mentioning are valid like the those P values with the full plastic shrink wrap and those. 00:56:26.050 --> 00:56:32.570 But I feel like some of those concerns can be addressed later through some eco modulation. 00:56:33.830 --> 00:56:34.270 Umm. 00:56:34.500 --> 00:56:39.760 Or for which could be in the form of no disruptors. 00:56:39.770 --> 00:56:43.950 Recycling disruptors or yields, you know. 00:56:44.350 --> 00:56:58.910 So if they know that that portion of that little plastic film portions not actually getting recycled, you know that could be something that's considered later on after there's the base basic data is known in the basic fees are are are understood. 00:57:01.390 --> 00:57:01.970 There's also. 00:57:01.380 --> 00:57:04.370 Uh as a whole level of complexity starting you've got home. 00:57:05.990 --> 00:57:07.660 I'm just gonna offer two. 00:57:07.720 --> 00:57:22.510 I mean there, there, there's probably gonna be the need within, you know, big volumes of data to to seasons point of of drawing some lines somewhere because in some cases, right like that shrink Lapsley, most of the labeling. 00:57:22.520 --> 00:57:37.440 And I've seen lately says remove shrink wrap for the consumer, then recycle right and so some of the issues related to more complex packaging could get addressed in, in, in different outcomes in the system, right. 00:57:37.450 --> 00:57:57.640 Either consumer action through labeling, you know, some mechanical action within the system that might be supported, but from a reporting perspective I I get your motivation around wanting to use eco modulation of fees to drive folks towards the full cardboard box versus the plastic window. 00:57:57.710 --> 00:58:25.650 I get that there were probably be, I mean that obviously is A and aspect of consumers wanting to see the product that they're buying and that's an aspect, but they're gonna be other occasions where you know, obviously there's there's certain materials that are used within, you know, certain other material multimaterial are gonna be used to preserve a, you know, a product for food stabilization and to prevent food waste. 00:58:25.660 --> 00:58:38.130 And so it's gonna get real tricky to say unless we start getting into eco modulation around it. 00:58:38.360 --> 00:59:00.680 You know certain exact packaging types or writing exemptions or sort of exemption type language into mega modulation that says, you know, you're gonna have higher fees on multi material products unless it's to, you know, preserve food safety, you start getting into very specific examples. 00:59:01.290 --> 00:59:21.890 And if you're gonna drive in a system that's gonna, you know, deal with though several thousand category levels, we're not, you know, so that's that's just where I think it's gonna be challenging to to write a if we don't have some thresholds like Susan suggested. 00:59:21.900 --> 00:59:39.370 And you know, it's gonna be challenging to write the ability into regulation into or into eco modulation factors to absolutely in every case discourage the right, you know, outcome in the right way. 00:59:39.380 --> 00:59:41.480 So that's just my perspective on. 00:59:42.320 --> 00:59:43.320 Victor has his hand up. 00:59:49.920 --> 00:59:50.160 Oops. 00:59:53.100 --> 01:00:01.950 I see Victor has his hand up too, so I'm gonna make press enter and also. 01:00:02.930 --> 01:00:09.910 Ohm, I'll add that a couple people have put something in the chat. 01:00:13.720 --> 01:00:15.630 Is the child's people chat? 01:00:15.640 --> 01:00:17.140 Chat. Uh. 01:00:17.340 --> 01:00:19.290 I will, Alicia. 01:00:19.300 --> 01:00:21.660 I'll I'll make you a presenter after Victor. 01:00:24.130 --> 01:00:24.680 OK. 01:00:24.730 --> 01:00:25.700 You're on, Victor. 01:00:25.750 --> 01:00:26.140 Hey, Victor. 01:00:27.350 --> 01:00:28.680 Oh, we can't hear you. 01:00:31.060 --> 01:00:31.790 How about that? 01:00:28.830 --> 01:00:31.820 I'm you did. OK. 01:00:31.800 --> 01:00:32.000 Better. 01:00:32.620 --> 01:00:33.110 Much better. 01:00:33.180 --> 01:00:33.360 Correct. 01:00:33.160 --> 01:00:35.560 Thanks for having me blow and all that good stuff. 01:00:35.870 --> 01:00:39.420 So I just want to talk about the pasta boxes. 01:00:39.940 --> 01:00:45.920 We've shipped roughly 1200 truckloads of mixed paper, and that's seemingly where that would end up. 01:00:46.640 --> 01:00:50.770 And I've never heard one complaint about the windows on those boxes. 01:00:52.810 --> 01:00:58.880 Most of that material goes to India, so feedback would be ohh pretty quick. 01:00:58.890 --> 01:01:00.690 I think it it was terrible thing. 01:01:02.290 --> 01:01:09.120 Yeah, it's probably gonna add a little bit to their waist, but none of the mills that we've ever sold to have ever said, hey, that's a bad idea. 01:01:09.130 --> 01:01:12.850 Don't put those in and the other one was the belly bands. 01:01:14.630 --> 01:01:24.660 I can't speak this exact minute, but they were always desirable to be on the milk jugs because they're provided lubrication in the system when they're going up the conveyors. 01:01:25.650 --> 01:01:28.460 So they were never afraid of the belly bands. 01:01:28.810 --> 01:01:32.760 You know the the rat, but what happens if the other end? 01:01:32.770 --> 01:01:33.340 I couldn't tell you. 01:01:34.220 --> 01:01:34.670 Right, that's. 01:01:35.460 --> 01:01:36.020 That's about it. 01:01:38.620 --> 01:01:39.250 Thanks, Victor. 01:01:39.260 --> 01:01:39.550 OK. 01:01:40.260 --> 01:01:41.400 Sure. Thanks. 01:01:39.560 --> 01:01:41.580 Thanks, victor. Well. 01:01:43.710 --> 01:01:43.960 Right. 01:01:43.970 --> 01:01:47.710 So it may not be as much an issue of problematic contamination as. 01:01:50.420 --> 01:01:53.380 The piece of the package that's destined for disposal right? 01:01:53.750 --> 01:02:03.870 At least in some cases really recyclable, even though it can go through the process, it's a residue at the end that's slightly less problematic, right? 01:02:03.920 --> 01:02:04.660 Yeah, right. 01:02:07.060 --> 01:02:07.800 It sounds good. 01:02:14.180 --> 01:02:14.960 Hi, good afternoon. 01:02:08.160 --> 01:02:15.470 OK, Alicia, I've just made you a presenter and then I'll follow up. 01:02:15.760 --> 01:02:18.050 I never follow Peter after you. 01:02:18.140 --> 01:02:20.090 Just like let people know where they are in the queue. 01:02:21.410 --> 01:02:22.020 Sure, I'd. 01:02:22.030 --> 01:02:29.840 I'd written in the chat that I could maybe offer a a narrow perspective on the topic you were discussing a few minutes ago about weights and units. 01:02:30.790 --> 01:02:40.280 So obviously the weights makes sense because as you're moving material over to your processors, they go by weights, not by units. 01:02:40.610 --> 01:02:43.760 So then it comes into question or where did units come from? 01:02:43.910 --> 01:02:59.020 And I don't know about Maine specifically, but in EPR programs in general, it's an effort to prevent bad actors in a bad actors being the manufacturers cheating, if you will. 01:02:59.030 --> 01:03:03.380 So OK, let's try and do a an, A an example. 01:03:03.390 --> 01:03:13.030 So if you have a dishwasher and it's shipping and on each corner of the top of that dishwasher, there's a piece of Styrofoam hard molded Styrofoam. 01:03:14.610 --> 01:03:23.160 For the you know the shipping process to absorb, umm, the shock and abrasion that that dishwasher is going through. 01:03:23.200 --> 01:03:31.100 So on each of those four corners, you have those four pieces, so using units and preventing bad actors. 01:03:31.110 --> 01:03:35.900 What they don't want manufacturers to do is to go from 4 pieces. 01:03:37.070 --> 01:03:38.840 Down to one piece. 01:03:39.170 --> 01:03:49.930 And so now they're the manufacturer would be reducing their units, but their weight would go up because if I reduced the four pieces and just made one piece, it now covers the whole top of the dishwasher. 01:03:50.250 --> 01:04:01.980 So it's just a way that I think they introduced both weights and units so that you weren't playing with how you were shifting your materials. 01:04:01.990 --> 01:04:12.050 And like I said, preventing bad actors from sort of cheating the system, if you will, and actually introducing more plastic, not actually reducing it. 01:04:12.060 --> 01:04:16.100 So it's just a way to try and measure both ends if you will. 01:04:19.150 --> 01:04:19.660 Thank you. 01:04:19.770 --> 01:04:20.170 Thank you. 01:04:20.840 --> 01:04:20.930 Yes. 01:04:23.130 --> 01:04:36.180 Yeah, I think I think I would just note that if there's a way to account for both in the system, then that might be ideal because for example, I mean plastics might be later weight than paper if depending on what you're what you're using it for. 01:04:36.230 --> 01:04:38.880 So and Peter, you should be on. 01:04:43.540 --> 01:04:44.270 Thank you. 01:04:44.320 --> 01:04:44.850 Yeah. 01:04:44.920 --> 01:04:47.350 Yes, I just wanted to share. 01:04:47.440 --> 01:04:49.940 I I I've recognized the concern. 01:04:51.980 --> 01:04:54.810 You're raising and I. 01:04:54.900 --> 01:05:00.970 I do think Susan's, Umm, proposal makes a lot of sense in terms of. 01:05:02.200 --> 01:05:03.250 Not trying to. 01:05:04.680 --> 01:05:29.470 Uh, identify it up front in the reporting at aspects as as a separate category, just as an example, when you look at the California rule, what they have proposed as categories is anything with plastic on it would be a category of plastic. 01:05:29.620 --> 01:05:50.160 So for example, the case you raised with a pasta with window would be identified as paper fiber and a subcategory plastic, meaning it has to follow all the rules in in California associated with plastic, including source reduction. 01:05:51.610 --> 01:05:54.650 Those types of of additional requirements. 01:05:56.270 --> 01:06:01.940 I think that it it becomes an unworkable rule from that standpoint. 01:06:01.950 --> 01:06:08.500 And what makes much more sense is understanding how it is impacting the recycling process. 01:06:08.790 --> 01:06:16.860 So it as Victor pointed out, if it's if it is going through the paper process, how is it ending up in the paper process? 01:06:16.870 --> 01:06:18.920 Is it ending up contamination? 01:06:19.390 --> 01:06:27.320 Is there a more significant cost with the plastic window in a plastic and the pasta box? 01:06:28.980 --> 01:06:38.050 To me, that makes more logical sense than than trying to subcategorize it for a particular category. 01:06:38.280 --> 01:06:41.370 So 2 sounds just to share. 01:06:41.380 --> 01:06:41.720 What? 01:06:41.800 --> 01:06:46.680 What California was doing and and support the ideas I've heard so far. 01:06:48.770 --> 01:06:50.030 And later Peter, Peter. 01:07:03.550 --> 01:07:04.160 OK. 01:07:04.200 --> 01:07:07.710 OK, we're still in. 01:07:10.020 --> 01:07:11.020 Producer reporting. 01:07:14.410 --> 01:07:17.760 Any more comments regarding those rules? 01:07:30.300 --> 01:07:31.890 OK, so now so yeah. 01:07:33.210 --> 01:07:35.850 And sort of like, well, Susan was saying about. 01:07:39.120 --> 01:07:43.210 I think you made a useful point that there's the initial. 01:07:43.620 --> 01:07:48.610 Let's define the weight and basic package and then there's eco modulation on top. 01:07:48.620 --> 01:08:30.470 So you could use these component rules in, define the package and then you could even say in your eco modulation potentially each component if you have multiple components, there's a there's a Ding for that or or maybe it depends on the type of component right and and and maybe it depends on the on how that component browser doesn't affect the recycling process and maybe we can keep those component rules that that they're using in in Canada, but it triggered I mean I guess the other question I have on that before we move on is I'm not very clear on how firm those are, right? 01:08:30.480 --> 01:08:32.850 That's a guidance document put out by the PRO. 01:08:33.240 --> 01:08:34.890 They obviously been doing this for a while. 01:08:34.900 --> 01:08:40.380 Maybe that's something that they're pretty, umm, set on, and that's something they're going to do. 01:08:40.650 --> 01:08:42.140 Or maybe it's something that's new. 01:08:42.150 --> 01:08:43.500 I have no idea. 01:08:44.050 --> 01:08:52.810 Maybe we should talk to them directly about it, or or maybe someone knows, you know, the extent of time that those have been in place. 01:08:52.820 --> 01:09:03.900 Like, is that something that that people have sort of rallied around and they and they, they like that way of reporting or is that something that we're going to follow and put this in Rule and then they're gonna decide they want to do something different? Umm. 01:09:06.270 --> 01:09:08.580 I guess that we could talk to them directly. Probably. 01:09:08.590 --> 01:09:08.710 Yeah. 01:09:10.610 --> 01:09:13.930 Is anyone got any other unless someone else. 01:09:19.380 --> 01:09:22.510 Seeing no hands, seeing no hands, seeing no hands. 01:09:35.480 --> 01:09:37.150 She won't go into documentation. 01:09:40.130 --> 01:09:41.270 We're gonna estimate of sales. 01:09:45.040 --> 01:09:45.320 OK. 01:09:45.330 --> 01:09:49.410 Well, let's go to estimate of sales. 01:09:51.420 --> 01:10:09.170 So, right, we were talking about how, you know, there's, it appears that producers don't always have the number of sales into the state and the statute does allow for estimates. 01:10:09.180 --> 01:10:20.430 So we need to figure out the methodology for estimating sales and we have a we have a an instance to propose. 01:10:21.450 --> 01:10:22.480 So our question is how? 01:10:22.490 --> 01:10:25.580 How could producers estimate their sales and we? 01:10:28.710 --> 01:10:30.000 Have an instance. 01:10:30.190 --> 01:10:51.490 Could we require that producers who are retailers use the model that estimates sales by first figuring the percentage of the companies total retail sales and dollars that occur in Maine and then multiplying that percentage by national sales data for each unit sold? 01:10:51.540 --> 01:10:51.730 Old. 01:10:55.220 --> 01:10:56.830 Yeah, they came back up a second. Yes. 01:10:58.500 --> 01:11:02.650 So when we're, we're looking at estimates of sales. 01:11:03.040 --> 01:11:14.660 I mean, I think that we all realized that ideally you're getting the information from your distributor, as Andy mentioned and you know where it goes, you don't have that. 01:11:14.960 --> 01:11:17.560 You have to make allowances for that, umm. 01:11:20.380 --> 01:11:23.660 One way that I've that we've seen this done? 01:11:25.160 --> 01:11:30.930 Umm is that for retailers? So. 01:11:30.940 --> 01:11:42.850 So then the issue is, you know, everyone's first thought seems to be well, you take national sales data and you use the percentage of the national population that lives in Maine, and you multiply the two. 01:11:42.860 --> 01:11:56.270 And then your your issue there is is that products some products are very regional other products other products that would provide a very accurate estimate of what goes into Maine and other products that would be completely unreasonable. 01:11:57.620 --> 01:11:58.690 So how do we deal with that? 01:11:58.700 --> 01:12:01.480 Regionality is is I guess the real question here. 01:12:02.820 --> 01:12:03.170 Umm. 01:12:04.730 --> 01:12:07.400 And we're very open to ideas on that. 01:12:09.480 --> 01:12:09.910 Umm. 01:12:11.010 --> 01:12:20.640 And then we have a couple ideas that we want to just throw out after hearing any of your ideas and maybe we can hear from Andy first, OK. Yep. 01:12:31.600 --> 01:13:10.090 And so it not to be a broken record on on the theme, but I think you could place that requirement upon the successful stewardship organization to appropriately articulate how they will work with producers to account for regional differences, sales etcetera, because the the SO is gonna gonna receive you sort of an initial registration paperwork from producers and you would conceive that that paperwork might say we distributed all 50 states, we only distribute in the Northeast. 01:13:10.500 --> 01:13:13.830 You know our general size, et cetera. 01:13:14.560 --> 01:13:19.040 And so you're going to get an idea of each one of the members of the. 01:13:19.050 --> 01:13:37.800 SO through that process and it could be by using that tiering it in essence or, you know, categorizing certain companies in different ways like their regional, but their regional to the northwest and they might have very small distribution in Maine. 01:13:38.030 --> 01:14:03.150 You know the regional, but they're regional in Maine, so there would be a higher distribution of their products and maybe you would think I I would think that the SO could potentially propose or provide clear indication to the department on how they are accounting for regional differences within the producer group versus trying to put in the rule. 01:14:03.840 --> 01:14:07.550 You know the the the producers must. 01:14:10.060 --> 01:14:19.740 I'm just trying to think how you structure this and and you try to structure it a rulemaking that you're puts the obligation on the SO or puts the obligation on the producers themselves to. 01:14:20.920 --> 01:14:25.270 So the identify or, you know, categorize themselves. 01:14:25.280 --> 01:14:26.800 I think there's a way to do it within. 01:14:28.170 --> 01:14:32.880 Perhaps the plan requirements for the SO to articulate that. 01:14:35.320 --> 01:14:45.670 Maybe in in sort of it, there's no, there's no requirement within the law and it says the department will dictate how producers register with the SO. 01:14:46.630 --> 01:15:13.760 And they said I can right off top my head, remember, but it would be in that sort of it may not be registration, right, it may just be in your annual report as a producer did the SO hey, we've gone from being just a Northwest regional company to we found a distributor that's based in New Jersey and they're now distributing our product throughout the Northeast like that's gonna change too like you're it will change. 01:15:14.050 --> 01:15:23.370 So I do think there is the ability to to not so much put the onus, cause Susan will probably throw a brick at me through the screen. 01:15:23.380 --> 01:15:40.300 But like work with the SO to make sure that they are categorizing producers based upon distribution of their products, that's then reflective of the mix that's going to show up in Maine as a way of getting to that approximate. 01:15:40.310 --> 01:15:52.540 I mean it's it's it's all you know potential approximates, but it's there's ability to collect some of that information you know through your annual reporting from a producer to the to the SO. 01:16:02.950 --> 01:16:03.320 Yeah. 01:16:03.160 --> 01:16:03.470 We. 01:16:03.470 --> 01:16:05.130 And do we get to hear your idea, Elena? 01:16:06.110 --> 01:16:07.700 Repeat it after Peter. 01:16:07.710 --> 01:16:10.540 That would make make Peter can shoot it down. 01:16:10.550 --> 01:16:11.220 We'll leave you up there. 01:16:11.530 --> 01:16:13.040 It will be ready to go. 01:16:17.680 --> 01:16:18.870 Hey Peter, you should be sad. 01:16:20.470 --> 01:16:29.250 And and just wanted to share a concept that's been used effectively in other regulatory formats. 01:16:29.630 --> 01:16:33.890 And that's the idea of best readily available information. 01:16:35.130 --> 01:16:51.400 I I support the idea of not pinning it down in in the actual regulation, but you can lay out the framework by by publishing a a guideline, maybe on an annual basis or updating it on an annual basis. 01:16:51.810 --> 01:16:59.770 That or rely on the stewardship organization to publish that guideline to very similar to. 01:17:01.450 --> 01:17:15.380 That the guidance that was provided by Susan saying, here's a here's the way you go about presenting your data, estimating your information to give you an example of where that's used. 01:17:15.390 --> 01:17:38.020 If you look at toxic inventory reporting, what EPA does and what states do is they publish a guidance to all the regulated entities on how to do that reporting and indicate you have to use your your best readily available information to do that reporting. 01:17:39.380 --> 01:17:51.580 Now if you have if if the only best readily available information is nationwide information or regional information, then then that's what you would use. 01:17:52.410 --> 01:18:04.450 But a year or two years down the road, as you gather data that may change so that your guidance says, well, here's the numbers you have to use for reporting. 01:18:04.460 --> 01:18:11.930 Because here's the here's the best readily available information, this regional information. 01:18:12.870 --> 01:18:38.040 What that does is it a allow ohm entities that have to comply to to rely on a good guide document that they can use if they happen to have better information then they can use that information to be more focused with regards to their own individual reporting. 01:18:38.610 --> 01:18:46.640 So that's just a a general concept and and again the community right to look to, to no law. 01:18:47.530 --> 01:18:50.830 Toxic release Reporting is A is a good example of that. 01:18:52.890 --> 01:18:53.720 So that makes sense. 01:18:55.050 --> 01:18:55.310 Yeah. 01:18:55.320 --> 01:18:55.620 Yes. 01:18:55.630 --> 01:18:56.070 Thanks Peter. 01:18:55.980 --> 01:18:56.670 OK, sure. 01:18:58.140 --> 01:19:02.510 Umm Neal's number. 01:19:02.920 --> 01:19:05.390 Next up on the list, let me make you a presenter, Neal. 01:19:10.270 --> 01:19:16.120 And I'm gonna go ahead and make Alicia presenter as well and. 01:19:17.500 --> 01:19:17.780 Alright. 01:19:17.790 --> 01:19:18.230 Can you hear me? 01:19:21.600 --> 01:19:22.880 Uh, yeah, so I was. 01:19:23.580 --> 01:19:32.170 Wondering about this idea of estimating and Peter had suggested best readily available information as a as a guide. 01:19:33.140 --> 01:19:53.950 Uh, I was wanting to put the idea out there that using a higher level of estimation should perhaps Harry some sort of a penalty in order to disincentivize people from using the the the vaguer information sources. 01:19:54.660 --> 01:19:55.070 Umm. 01:19:55.530 --> 01:20:12.450 And for instance I I could see that if if we don't, uh disincentivize this, that people would perhaps choose to use the whatever estimation guide would give them the the best advantage. 01:20:13.620 --> 01:20:26.570 Uh, and assuming that you don't have clear, concise information, I don't like, you know, you wouldn't really be able to ultimately tell in an in an audit. 01:20:27.490 --> 01:20:36.180 So I just think that pushing people to kind of use the the pure, more accurate information should be incentivized. 01:20:38.350 --> 01:20:41.260 We actually have that as one of our questions. 01:20:41.570 --> 01:20:49.020 Should there be incentive provided to encourage the provision of more of the more accurate sales data, and if so, how might that be structured? 01:20:49.250 --> 01:20:56.190 So if anyone has thoughts on that, what that incentive might look like that would be helpful too. 01:20:56.260 --> 01:20:56.360 No. 01:21:01.760 --> 01:21:02.110 Please. 01:20:59.860 --> 01:21:02.470 Could I respond? 01:21:02.860 --> 01:21:03.270 Sure. 01:21:03.110 --> 01:21:03.380 Please. 01:21:03.280 --> 01:21:06.190 Because I I think that's a very valid point. 01:21:06.600 --> 01:21:08.020 You know, I, I. 01:21:08.240 --> 01:21:41.530 And when I've looked at toxic realism, atory reporting that is kind of how it's structured, you're the default levels are based on tend to be conservative values of reporting, meaning that you're you're penalized a little bit if you're using that, that data, and you're incentivized to be able to provide, uh, your own companies data, your your, uh, next level of data. 01:21:42.520 --> 01:21:42.820 OK. 01:21:41.910 --> 01:21:47.620 But it doesn't require you to do is to go out and do a lot of additional testing or. 01:21:51.070 --> 01:22:07.250 Uh data gathering that you may not have readily available, and that's the balance that a company is is thinking about is do I wanna go with his default numbers that are gonna frankly cost me more because they're conservative? 01:22:07.630 --> 01:22:18.700 Is it worthwhile to go out and spend the money to do the testing to figure out how much my plastic window in my pasta box weighs compared to the whole box on? 01:22:18.750 --> 01:22:26.510 Is that worth it or should I use national data or regional data that is provided in the guidance? 01:22:27.330 --> 01:22:36.330 But I I think it's a very good point too, to try to incentivize for better data gathering, but leave the option. 01:22:38.530 --> 01:22:41.170 Actually, the the Statute requires us to. 01:22:42.520 --> 01:22:44.510 Incentivize better data. 01:22:45.090 --> 01:22:47.100 Uh, in the area of what? 01:22:47.110 --> 01:23:02.070 The package looks like a lot, doesn't require us to provide incentive for actual sales in Maine versus estimates of sales in Maine. 01:23:02.120 --> 01:23:10.480 So that's what we're wondering is if we should extend that requirement that incentive, uh, for better data to the sales in Maine? 01:23:14.760 --> 01:23:19.190 But yeah, that, that, that idea of making the default conservative is useful. 01:23:19.200 --> 01:23:24.300 I'm not quite sure what that would look like in the, but I'm sure we'd thinking about it. 01:23:24.310 --> 01:23:25.720 That's that's the principle, right? 01:23:25.730 --> 01:23:26.940 You just make that default. 01:23:27.600 --> 01:23:30.560 I'm likely to be more burdensome. 01:23:36.000 --> 01:23:39.170 Yeah, that that can drive the correct incentives. 01:23:39.180 --> 01:23:40.060 I think you're looking for. 01:23:43.740 --> 01:23:46.860 Alicia, if you have anything to add, we've made you a presenter. 01:23:48.300 --> 01:23:49.130 Hi, thank you. 01:23:49.140 --> 01:23:50.030 Good afternoon again. 01:23:50.540 --> 01:24:17.430 I'm sure I just wanted to weigh in, probably aligning or agreeing with the things that Peter and Neal have brought forward, but also to add that while you want to incentivize best data, you also don't necessarily want to penalize because in providing the best available information that may be percentage of population. 01:24:17.840 --> 01:24:34.080 Because across Canada, that's actually what we're doing because our industry cannot track to the state level where the shipments are going, nor is there a ruling that obligates retailers to report back to us. 01:24:34.600 --> 01:24:47.280 You know, retailers or you could include in that buying groups or distributors, there's no rule that obligates them to tell us where they've sent which end consumer they've shipped our product too. 01:24:47.840 --> 01:24:59.990 And because that infrastructure that reporting process between the you know the end consumer and where they bought from to us, we cannot provide that information. 01:25:00.000 --> 01:25:10.750 So even if you were to incentivize us, the process does not exist between us and and retailer to give you that data. 01:25:10.900 --> 01:25:27.040 So we're using percentage of population across Canada and because there's an EPR program either in existence or beginning to be coming into existence, essentially the all of Canada is then reported on. 01:25:28.950 --> 01:25:44.930 Is there so we've sort of been assuming that the way this would work is that over time, Umm brand owners would include parts in their contract that say you distributor tell me where you send this stuff. 01:25:45.500 --> 01:25:47.800 Are you saying that that's not happening for whatever reason? 01:25:49.100 --> 01:25:50.380 Why might that not be happening? 01:25:50.030 --> 01:25:51.440 We it does. 01:25:51.450 --> 01:25:53.780 It does not happen for our industry. 01:25:53.790 --> 01:26:05.160 There's a select, there's a select small amount of retailers that provide information to us, but it's a a very small percentage. 01:26:05.330 --> 01:26:15.820 And so that process would have to be set up with the big boxes with all the independence, all the mom and pops across the country that sell our product. 01:26:16.070 --> 01:26:35.090 So it does not exist and that's something that we would have to a conversation, we would have to start with our retail partners, both contractually and also on their end, umm A to be able to support that requirement that you know and some of these mom and pops are still using paper invoices. 01:26:35.100 --> 01:26:44.120 They're not even computerized, so it's it would be a big step, you know, that would be impacting a lot of businesses, not just us as manufacturers. 01:26:45.510 --> 01:26:48.460 But the sorry, I just don't understand the mom and pops. 01:26:48.530 --> 01:26:52.920 You know where they're located, so if you know if you send it, you know if you send it to a it's. 01:26:53.050 --> 01:26:55.770 I would think that you really only dealing with your big distributors, right? 01:26:55.960 --> 01:27:09.150 You know, if you sent it to a 1 store location that that's where it's going to be sold versus like you send it to a distributor in New Hampshire and then from there they're going or you send it to a big box in wherever. 01:27:10.120 --> 01:27:10.640 Sure. 01:27:09.160 --> 01:27:10.710 And from there it's going everywhere. 01:27:11.400 --> 01:27:11.640 Yeah. 01:27:11.650 --> 01:27:19.170 And I think that's, you know, you're probably that's probably true, but then you've got those that are sitting on the borders and out. 01:27:19.180 --> 01:27:21.670 Is that customer actually located in Canada? 01:27:22.000 --> 01:27:23.930 Are they located on the border? 01:27:23.940 --> 01:27:25.660 States. Umm. 01:27:26.250 --> 01:27:33.190 So I I I think largely you're correct for the mom and pops, but I don't. 01:27:33.200 --> 01:27:34.630 I wouldn't say it's 100%. 01:27:38.920 --> 01:27:45.740 I made the other Neil Menezes a presenter. 01:27:45.750 --> 01:27:47.970 You're welcome to add your comment. 01:27:48.340 --> 01:27:51.910 Thank you, Alicia, and tell us how to say your name, perhaps. 01:27:53.080 --> 01:27:54.130 You said it correctly. 01:27:54.140 --> 01:27:54.500 Thank you. 01:27:57.830 --> 01:27:58.220 Hi there. 01:27:58.230 --> 01:27:58.520 It's. 01:27:58.620 --> 01:28:00.040 It's Neil from General Mills. 01:28:00.130 --> 01:28:04.210 So Alicia kind of hit some of the key points I wanted to highlight. 01:28:04.870 --> 01:28:05.560 Umm. 01:28:05.990 --> 01:28:15.270 In the sense that we don't get that information from the retailers and while we may try to include some of that, the retailers are the customers. 01:28:15.390 --> 01:28:22.660 So we as brands don't have as much leverage to dictate what goes in the contracts with the retailers. 01:28:23.550 --> 01:28:42.510 It is a discussion and depending on the relationship, we may be able to get some of the information, but there are challenges in getting specific data because in most cases the leverage and the power still remains with the retailers from the perspective because we need them to sell our product, stock their shelves with our products. 01:28:43.340 --> 01:28:44.070 So it will. 01:28:44.080 --> 01:28:54.930 It will take time to kind of get a better understanding of what information the retailers are willing and able to share back because it it also creates a burden on them in terms of how it's moving. 01:28:55.520 --> 01:29:04.770 The other comment I wanted to highlight, I think you want to incentivize more accurate data and the only tradeoff with it and I think. 01:29:05.490 --> 01:29:05.820 Uh. 01:29:07.660 --> 01:29:09.870 The preview Peter might have mentioned this earlier. 01:29:09.980 --> 01:29:16.370 Is it does take resources to track that low information or get a better understanding of where that material is flowing. 01:29:16.610 --> 01:29:30.050 So some of the larger brands like as we commit quite a bit of resources to get a better understanding of our weight and it's still not always perfect because we constantly change packaging formats, introduce new products. 01:29:30.800 --> 01:29:32.600 So it does commit a lot of Resources. 01:29:32.610 --> 01:29:48.020 So if you put too much of a incentive on and then accurate data, you may be disadvantaging some of your more mid to smaller size companies that don't have the resources to potentially keep up to date with changes in packaging. 01:29:48.030 --> 01:29:49.400 So you'll need to find that balance. 01:29:49.410 --> 01:29:57.240 I don't have a solution in terms of what's that right balance in terms of how much incentive because ultimately you want accurate data because we're making decisions on it. 01:29:57.490 --> 01:30:06.080 If someone's uh data is gonna have a negligible impact on the overall system, you don't wanna put an undue burden in them for any company. 01:30:06.090 --> 01:30:13.130 Even the larger organizations to get that .001 accuracy, and it may just be a rounding error in the fees. 01:30:13.140 --> 01:30:17.100 So it's a matter of finding that balance and seeing what's realistic. 01:30:17.270 --> 01:30:22.040 And The thing is, the other part is because EPR is being implemented across various US states. 01:30:22.630 --> 01:30:25.580 It's going to take some time to get to that level of accuracy. 01:30:25.590 --> 01:30:41.130 So you don't need to determine constantly use it on the Canadian side, so you don't need to boil the ocean with EPR it can be a progressive, so you can get to a starting point that gives you the necessary data you need to get fees to get reporting done. 01:30:41.360 --> 01:30:51.820 And then if you notice that there's too many variations in the data, then look like how do we further refine it or how do we provide tools for other companies to make sure that they're reporting as accurately as possible. 01:30:55.900 --> 01:30:56.450 Thank you. 01:30:56.520 --> 01:30:57.000 Thank you. 01:30:57.790 --> 01:30:58.110 Thank you. 01:31:03.070 --> 01:31:08.900 I I I agree with Neil's point about it's gonna be really hard to to get this estimation right. 01:31:09.870 --> 01:31:11.750 As far as the level of the incentives? 01:31:13.870 --> 01:31:24.980 Perhaps we could consider adding this to the the agenda of the the yearly yeah, a meeting of the stewardship organization, producers, municipalities getting together. 01:31:24.990 --> 01:31:31.300 And I know that there's a few few levers that we're gonna need to tweak as we go through the process through the years. 01:31:31.510 --> 01:31:43.540 So maybe this is one of those things that we I would try to establish the best guess we can, but we also leave it open so that the the process can pull the levers as we go along. 01:31:46.380 --> 01:31:46.820 Thank you. 01:31:47.340 --> 01:31:47.640 Yeah. 01:31:47.650 --> 01:31:49.110 Sorry, just a quick add to that. 01:31:49.120 --> 01:31:53.770 One of the starting points we've seen on the Canadian side is you asked the producer on their data source. 01:31:53.880 --> 01:31:57.570 If it's actual, then you have a pretty good sample in the first few years. 01:31:57.580 --> 01:32:01.050 How many are using actual data and then the ones that are not? 01:32:01.100 --> 01:32:03.310 Then you can get a sense of what they represent. 01:32:03.380 --> 01:32:17.890 If it's less than 5%, that may be an acceptable margin of error, but if you're 40% are using estimated data, then you may need to look at ways of refining it and that's getting them to use more actuals versus estimated data. 01:32:20.590 --> 01:32:21.060 Great point. 01:32:20.840 --> 01:32:21.470 That was helpful. 01:32:21.480 --> 01:32:21.850 Thank you. 01:32:27.700 --> 01:32:29.890 So so one way that. 01:32:33.200 --> 01:32:37.970 I know that there is a large retailer. 01:32:39.140 --> 01:32:52.900 Uh in the United States that uses, it seems like a number that retailers have is, umm, their sales at a retail location. 01:32:53.830 --> 01:33:22.010 So at the Rockland, Maine location, we sell $100,000 worth of stuff at the Portland, ME location, we sell $500,000 worth of stuff that seems to be a number that retailers have and I'm aware of at least one large retailer using that number to then estimate the amount of business you know more more specifically that that a location does say so. 01:33:22.020 --> 01:33:24.350 That a location does say so. 01:33:24.400 --> 01:33:37.380 So you would you would say well my, I know that I'm a retailer and I work in the Northeast or on the East Coast and I know that 20% of my sales go into Maine. 01:33:37.390 --> 01:33:41.260 And so I'll assume that 20% of my products went into me. 01:33:43.530 --> 01:33:43.780 What? 01:33:43.790 --> 01:33:47.450 That was one way that we thought that retailers might be able to deal with this. 01:33:48.150 --> 01:33:48.620 Umm. 01:33:48.950 --> 01:34:08.990 And I guess it's it's sort of similar and maybe different a little bit but but if if a company that's not a retailer producer that's not a retailer sells to certain distributors and and knows that those distributors sell into a set of states, then they could just and this is maybe closer to what Andy was saying earlier. 01:34:09.340 --> 01:34:23.250 I know that I have a distributor that sells into Maine, New Hampshire and Massachusetts, and so I know, and I know that I sold 100 units to that entity and Maine has. 01:34:24.960 --> 01:34:32.560 I don't know 20% of the population of, you know, combined Maine, New Hampshire, Massachusetts. 01:34:32.570 --> 01:34:34.900 So I'm going to assume that 20 of those units went to Maine. 01:34:39.570 --> 01:34:40.260 Neil, please. 01:34:42.950 --> 01:34:43.370 Yes. 01:34:43.960 --> 01:34:46.410 Sorry, just wanted to clarify 1 component. 01:34:46.520 --> 01:34:52.650 While that that might be true, the retailer is only been reporting on their private label products. 01:34:53.110 --> 01:34:53.370 Right. 01:34:52.760 --> 01:34:56.740 So even though 20% of their total sales may move into that. 01:34:57.460 --> 01:34:59.200 UM, say it's cereal. 01:34:59.900 --> 01:35:00.560 Uh. 01:35:00.810 --> 01:35:10.690 Cheerios maybe the more dominant one, and I'm saying there's obviously from General Mills might be the more dominant sale in Maine. 01:35:10.740 --> 01:35:15.370 But there are in the retail brand, may be a smaller fraction of it. 01:35:15.380 --> 01:35:22.570 So your total sales may be 20% of serial into that state, but their portion of what they would report on is small. 01:35:22.630 --> 01:35:29.620 So the retailers have no responsibility for reporting anything other than their own private label brand. 01:35:29.630 --> 01:35:38.860 So that's where even for them it gets complex because they need to really isolate their private label products away from total sales and further slice and dice. 01:35:38.940 --> 01:35:48.100 And then for all those cerals, they would need to give us our information in terms of Cheerios, Kellogg 0 information and Kellogs and go down. 01:35:48.210 --> 01:35:53.510 All of these different rabbit holes, and depending on the market share and each one of those states, it can vary quite a bit. 01:35:55.180 --> 01:36:10.980 So that's where he gets that's why they do use some of these estimates and that might be a way that they say each each brand, including the retail, all have equal proportions into a specific state as a way of managing that risk. 01:36:10.990 --> 01:36:17.930 But there's gonna be a lot of learnings that's gonna have to happen over the years, especially they haven't been tracking it to that level of detail. 01:36:20.180 --> 01:36:20.810 Right. 01:36:20.870 --> 01:36:21.580 No, we did. 01:36:21.640 --> 01:36:24.960 We did think about that too, actually that, yes. 01:36:25.340 --> 01:36:32.500 And it might actually be very different in terms of like you may have, umm, lower sales in. 01:36:35.060 --> 01:36:38.840 It's they may have have lower sales in Rockland than in Portland. 01:36:59.700 --> 01:37:00.290 Exactly. 01:36:41.750 --> 01:37:00.320 Because, well, one because Portland's bigger, but maybe because Portland is is wealthier and then and then as a result of that, there may be an effort may have actually less sales in Portland because fewer people are using the brand or the the store brand in Portland in the wealthier area than than anyway, yeah, problems with. 01:37:00.300 --> 01:37:04.810 So all of those scenarios could potentially play out and until you first get. 01:37:05.060 --> 01:37:16.070 That's why it's good to get some data in and then further refined to say what's the ideal state rather than trying to be perfect cuz you so hard to kind of predict all those different scenarios right from the beginning. 01:37:16.570 --> 01:37:25.240 And if you try to solve for every single scenario, there's always going to be an unintended consequence that will just make it harder to address down the line. 01:37:26.510 --> 01:37:26.920 Right. 01:37:27.250 --> 01:37:27.560 Yep. 01:37:27.570 --> 01:37:27.890 Thank you. 01:37:29.110 --> 01:37:32.210 And Alicia, Alicia's next. 01:37:33.090 --> 01:37:33.420 Sure. 01:37:33.430 --> 01:37:33.790 Thank you. 01:37:33.800 --> 01:37:44.630 Again, I appreciate Neil's comments and you know, really agree with with that in my industry, it's not about private label, it's actually about our products. 01:37:44.640 --> 01:37:54.320 And I liked what your comment earlier about you were suggesting, talking about the talking to the pro offline about how they might approach this. 01:37:54.890 --> 01:38:04.880 I think that's a good idea, but please do appreciate that you're the first of five states to start introducing this. 01:38:04.930 --> 01:38:15.060 And so it's really in its infancy our ability and like I said earlier, there's no ruling that obligates the retailers to give that information back to us. 01:38:15.070 --> 01:38:23.080 So it's like Neil said, this is the start of a conversation for a lot of retailers and this would be a burden to them. 01:38:23.090 --> 01:38:31.540 And also your idea about if if there's a distributor that reports or that cells to the region. 01:38:31.910 --> 01:38:32.210 OK. 01:38:32.220 --> 01:38:38.010 Well, then you know, as a manufacturer, I have to recognize in my reporting to you. 01:38:38.430 --> 01:38:46.650 OK, that piece of data was a regional piece of data that included these dates and all this distributor was regional for these states. 01:38:46.660 --> 01:38:50.620 And so it's I you know, I have to take it in context. 01:38:50.630 --> 01:38:59.290 What they're giving me, but yet fitting into my whole slice, and that's a lot of burden to try and figure out who's giving me what cause. 01:38:59.300 --> 01:39:08.600 Ultimately, I'm trying to give you the state of Maine or I'm giving the state of California or Colorado or Oregon or or Maryland, so it's. 01:39:11.920 --> 01:39:18.410 When I'm not getting retail specific it, it's a lot of reporting burden on our end that we have to figure out. 01:39:19.040 --> 01:39:22.960 You know, in this infancy state that we're in of the of the life cycle here. 01:39:25.500 --> 01:39:25.870 Yeah. 01:39:25.920 --> 01:39:26.520 Thank you. 01:39:36.730 --> 01:39:38.520 Tell Yep. 01:39:43.350 --> 01:39:46.410 So I think we should move into documentation and auditing. 01:39:58.610 --> 01:40:02.400 And have a few questions under under that. 01:40:09.580 --> 01:40:12.110 Uh, we're curious. 01:40:12.420 --> 01:40:17.280 Should producer documentation let's give that person. 01:40:17.330 --> 01:40:17.860 OK. 01:40:17.870 --> 01:40:18.770 You talked about that one. 01:40:19.600 --> 01:40:49.790 It would circle that we said that the second one we talked about what granularity should therefore this out, OK, so after a producer has reported, we're curious, are there any parts of the information producers are reporting that should be saved by the SO to facilitate to facilitate simpler reporting in years that follow? 01:40:57.840 --> 01:40:58.110 What the? 01:40:59.690 --> 01:41:00.040 Umm. 01:41:00.100 --> 01:41:07.350 I guess another way of saying that is it could be you know is there a downside of say some information was saved? 01:41:07.890 --> 01:41:18.590 Uh by a system like we're gonna save, we know that last year you're like packaging of cereal boxes and bags. 01:41:19.060 --> 01:41:20.570 Was had this weight. 01:41:20.580 --> 01:41:25.230 And so we're gonna save that in the system and you just have to enter your new unit number. 01:41:28.240 --> 01:41:30.850 That's something that we should promote. 01:41:30.900 --> 01:41:34.010 Or is that something that can potentially lead to inaccurate reporting? 01:41:38.370 --> 01:41:45.020 That's obviously a level of detail that may be, I mean Neil did address how frequently packaging is changing. 01:41:45.030 --> 01:41:47.830 He does have a comment to add to her question, no. 01:41:55.340 --> 01:41:56.440 OK, I'll send you. 01:41:58.230 --> 01:41:58.910 And I'm sorry. 01:41:58.920 --> 01:41:59.840 You read my mind. 01:41:59.850 --> 01:42:24.300 It the the pace that we change packaging is pretty rapid and if there is a mechanism where every time we need to make a change, we need to report that into an organization that's going to create burdens on both the companies that are making the change as well as the organization because it may be a split that happens mid year or UMM and it could happen two or three times in a year. 01:42:25.220 --> 01:42:35.250 And historically, in the Canadian side, they used to provide the pros used to provide a calculator for companies who didn't have their own data to use. 01:42:35.940 --> 01:42:36.720 Umm. 01:42:36.890 --> 01:42:51.360 As you unit weights and they can update it and where you found an overtime they lose accuracy because of how quickly packaging formats change and how constantly people are lightweighting or moving from different formats. 01:42:51.490 --> 01:42:53.560 So there's classification errors that could happen. 01:42:54.460 --> 01:42:55.280 Umm. 01:42:56.020 --> 01:42:58.270 So yeah, I would say it's. 01:42:59.720 --> 01:43:08.450 It would be a risky to save those weights and something that organization that are better off updating on an annual basis. 01:43:08.460 --> 01:43:16.850 There's gonna be some rounding issues depending on when the updates happen, but I wouldn't recommend saving that level of information. 01:43:19.160 --> 01:43:19.580 Thank. 01:43:19.680 --> 01:43:20.120 Thank you. 01:43:32.120 --> 01:43:32.530 OK. 01:43:32.540 --> 01:43:48.800 And we also are curious, should the SO conduct a certain amount of auditing and if so, how should the SO choose which producer to audit or should there be certain conditions that trigger an audit regardless of the number of audits that would entail? 01:43:58.790 --> 01:44:25.700 So in terms of last meeting a number of times people suggested well in the in the PRO can audit a producers reporting and ask for I think I think it was said five years or maybe that's what we were in the guidelines producers need to keep records for five years of the support documents that support their reporting. 01:44:26.070 --> 01:44:27.860 This is, I believe, what was in the guidance. 01:44:28.340 --> 01:44:31.500 And so our question is, should there be? 01:44:31.610 --> 01:44:34.850 To what degree do we want so to be auditing? 01:44:34.860 --> 01:44:47.920 These producer reports, should there be certain certain things that trigger an audit, maybe the packaging weights don't change from year to year, and it seems like no ones doing. 01:44:47.930 --> 01:44:55.160 No ones really doing this, or maybe the numbers are just off by, you know, more than off by an order of magnitude. 01:44:55.200 --> 01:45:00.620 Or maybe the SO does you know 10 random audits a year? 01:45:00.630 --> 01:45:01.320 I I don't know. 01:45:01.330 --> 01:45:04.150 That's our question is what the what degree did? 01:45:04.200 --> 01:45:09.010 Should auditing be part of this and SO auditing and check? 01:45:14.570 --> 01:45:15.980 I thought people would have an opinion on this. 01:45:31.190 --> 01:45:31.980 OK, Neil. 01:45:34.240 --> 01:45:34.550 Thanks. 01:45:34.560 --> 01:45:38.210 I don't want to dominate the conversation, raise my hand as needed. 01:45:40.670 --> 01:45:57.580 Be honest is typically on the pro or the SO to do the number of audits, because if there are companies that are not reporting accurately, it creates a bit of a free rider situation, so they're consistently underreporting and that means the other companies are bearing the cost. 01:45:57.690 --> 01:46:09.580 And then at the same time, because the PRO should be a service provider, if a company's overreporting, they should also work with the pro to get accurate data because the most critical thing will be to get accurate data. 01:46:10.630 --> 01:46:16.960 And I think what the question will come is how do you define an audit in the Canadian context? 01:46:16.970 --> 01:46:28.900 If there's a change in weight for a certain packaging category, I think 20 or 25%, it automatically triggers the company has to explain why that shift has happened. 01:46:28.950 --> 01:46:31.590 So was it a change from one format to another? 01:46:31.600 --> 01:46:34.460 Because you will see people change from 1 packaging to another. 01:46:34.830 --> 01:46:37.200 Do they classify into wrong category? 01:46:37.490 --> 01:46:56.510 So it's not an audit per say, it's more of a view that's automatically triggered if your weight shift by 2220 or 25% in either direction to get confirmation on whether, UM, that was whether the previous year was incorrect or the current year is incorrect. 01:46:57.220 --> 01:47:13.010 So that's one way of hiring, triggering it and the other part is because this is still early stages and there are gonna be errors in people's reports and in the past people would report, companies would report product weight along with the packaging weight. 01:47:13.020 --> 01:47:19.550 So you can automatically say there's something water ball shouldn't be weighing 2 pounds. 01:47:20.330 --> 01:47:21.090 Umm. 01:47:21.100 --> 01:47:22.320 Which is the packaging component. 01:47:22.330 --> 01:47:29.860 So there are some triggers that the Pro will look at to say something doesn't seem right and they can do that as part of a random number of audits. 01:47:29.990 --> 01:47:36.050 I wouldn't recommend identifying the number of audits in statute or in the rule. 01:47:36.300 --> 01:47:46.500 It's just more so to get the PRO to come up with a plan to say how will you identify whether or anomalies in the data, the outliers and how do you ensure that that's accurate. 01:47:46.660 --> 01:48:08.290 And then for some of the mid to larger organization where the fees could be in the hundreds of thousands of dollars, identify a way of randomly auditing some of those companies, because if there are five or 10% variance, it can still down to no tangent, maybe even $100,000 in that process. 01:48:10.020 --> 01:48:21.510 So you're saying both some random audits to sort of ensure a level playing field and then some targeted audits that are, or maybe a lesser so like check in. 01:48:21.580 --> 01:48:23.560 This is something strange is going on with your data. 01:48:24.290 --> 01:48:24.710 Exactly. 01:48:26.490 --> 01:48:38.420 And it really comes down to how you define audits, because I think a lot of organizations, when the hear audits understand to be a very onerous process, because that will create a lot of costs on both the company side as well as the PRO. 01:48:38.470 --> 01:48:49.930 Whoever has to do the audit, cuz really opening up books, so it really comes down to how you define maybe a review versus an audit and what constitutes an audit doesn't need to be a third party. 01:48:51.500 --> 01:48:59.710 So that's where it gets really complex and and can be quite burdensome if every audit needs to be a third party audit. 01:48:59.980 --> 01:49:05.910 But there is a way of saying we will do checks that PRO will do checks and will demonstrate and dot provide documentation. 01:49:06.180 --> 01:49:09.830 It at least internally, that would be a good balance of. 01:49:11.120 --> 01:49:13.310 Accuracy versus administrative burden? 01:49:15.410 --> 01:49:15.690 Right. 01:49:15.700 --> 01:49:22.430 So there might be a random audit process that's a random fuller audit to make sure people aren't cheating. 01:49:22.490 --> 01:49:33.370 And then a just check in is a review that says, OK, your data raised this flag in this flag. 01:49:33.380 --> 01:49:34.140 Please explain. 01:49:34.960 --> 01:49:35.380 Exactly. 01:49:38.020 --> 01:49:38.360 Thank you. 01:49:39.050 --> 01:49:39.350 Thanks. 01:49:40.190 --> 01:49:42.440 Susan, I'm making you a presenter. 01:49:42.890 --> 01:49:44.800 And please don't be shy to tal, Neil. 01:49:44.810 --> 01:49:45.480 This is very helpful. 01:49:46.370 --> 01:49:48.100 Uh, don't anyone be shy to talk? 01:49:48.110 --> 01:49:48.810 Yeah, right. 01:49:50.740 --> 01:50:10.110 I I think one way of of getting at this might be to to be a little less prescriptive and and ask the stewardship organization to report, uh, what activities they put in place to ensure accuracy of the data and to report. 01:50:10.400 --> 01:50:17.890 I know I think in the Oregon rules they they asked to report all the audits that were conducted, for example. 01:50:17.900 --> 01:50:21.430 But you know, I I think I would put it in the hands of the stewardship organization. 01:50:23.320 --> 01:50:25.770 I wouldn't be overly prescriptive in the in the regulations. 01:50:29.040 --> 01:50:33.070 And my leg here is that her too. 01:50:37.220 --> 01:50:39.290 So just one additional thought to add. 01:50:41.680 --> 01:50:51.410 I do think that there is an incentive within the producer errors that are active in the stewardship organization to make sure information is correct. 01:50:51.420 --> 01:51:10.370 So I I do think that's a good place for it and initially one thing that may be that may require additional checks and auditing is whether a company is in the is part of a stewardship organization or not. 01:51:11.710 --> 01:51:14.760 And I don't know if that's considered. 01:51:15.090 --> 01:51:31.520 I understand the data reporting being at audited, but there's also clearly in need, especially at the front to make sure uh, there's an accurate analysis of whether you need to be part of a stewardship organization. 01:51:38.650 --> 01:51:38.840 Like. 01:51:39.550 --> 01:51:42.480 Ohh and and one other thing that could potentially trigger audits. 01:51:42.490 --> 01:51:51.380 Its is similar industries with reporting with very different categories or or or numbers of information. 01:51:51.390 --> 01:51:55.890 So I know like for toxic release inventory reporting, that's one thing. 01:51:56.980 --> 01:52:13.580 The Environmental Protection Agency does is looks across similar industries to see if there's consistency or or obvious differences that aren't due to the size of the company or other reasons where they should be more party. 01:52:18.140 --> 01:52:18.790 OK. 01:52:18.840 --> 01:52:19.180 Thank you. 01:52:20.790 --> 01:52:21.000 Yeah. 01:52:21.010 --> 01:52:23.970 You touch a little bit on our next question, which was. 01:52:28.310 --> 01:52:38.740 When, when should the department request information from low-volume producers or producers that are exempt to verify their status as such? 01:52:46.650 --> 01:52:47.820 There's a lot of finds. 01:52:47.890 --> 01:53:00.810 You know the low volume producers that are exempt and then also defines a set of, I mean a set of producers that are exempt that are very low volumes and also defines a set of producers that are low volume and have sort of lesser requirements. 01:53:00.820 --> 01:53:10.620 And it says these entities must be ready to provide into information to the department to verify their status. 01:53:11.310 --> 01:53:17.410 If the department asks, and So what we're wondering is to what extent should the department be asking? 01:53:20.080 --> 01:53:21.340 And what might trigger an ask? 01:53:34.440 --> 01:53:36.250 I guess an obvious is Susan as your hand. 01:53:36.260 --> 01:53:38.210 I don't know if your hands still up person up again. 01:53:39.620 --> 01:53:41.010 They're just put his hand up, too. 01:53:41.120 --> 01:53:41.350 Yeah. 01:53:41.360 --> 01:53:42.090 Put his hand up again. 01:53:42.100 --> 01:53:42.340 Yeah. 01:53:42.350 --> 01:53:44.780 So I'll put Peter up please. 01:53:44.290 --> 01:53:53.690 Yep, I I'll just share my thoughts again, I I do think that's a a critical aspect to developing. 01:53:54.890 --> 01:53:57.520 Credibility or early on in the program. 01:53:57.530 --> 01:53:59.290 So I I do think. 01:53:59.760 --> 01:54:14.840 Uh, that there should be an expectation that if you're not part of the program that you have clear documentation of that, that you maintain that documentation and that's available upon upon the request. 01:54:15.640 --> 01:54:18.230 What's the frequency of? 01:54:18.840 --> 01:54:22.310 Again, I yeah, that is a that is a tough one. 01:54:22.580 --> 01:54:35.710 I think by by starting out by just setting the expectation, uh, that that is something that is available for you to look at upon request is is important. 01:54:37.880 --> 01:54:42.520 And you think that's more important towards the beginning of the program, I understand you to say, is that correct? 01:54:43.370 --> 01:54:43.840 Yeah. 01:54:49.050 --> 01:54:49.750 Need to do it less. 01:54:43.930 --> 01:54:57.110 Yes, I I think as the program proceeds, you'll have greater awareness from the producer from the regulated communities side that ohh. 01:54:57.120 --> 01:55:00.070 This is why I need to participate in those. 01:55:00.580 --> 01:55:02.110 Oh, I thought this was exempt. 01:55:02.120 --> 01:55:04.490 That's that doesn't appear to be the case. 01:55:04.840 --> 01:55:07.390 That will work itself out as you go forward. 01:55:08.050 --> 01:55:11.840 Uh, but initially I think that's where there. 01:55:11.890 --> 01:55:13.260 There will be confusion. 01:55:13.270 --> 01:55:20.110 Is is what exactly has to be counted and am I potentially exempt or not? 01:55:23.660 --> 01:55:24.640 Yes, thank you. 01:55:27.030 --> 01:55:29.330 So and Neil go right ahead. 01:55:31.250 --> 01:55:41.700 Turning just just a quick add to that, I think if you set the diminimus threshold for the low volume at a revenue threshold, then that could be annual from tax records. 01:55:41.710 --> 01:55:58.810 They just need to prove that they're below that revenue source and the ones that are slightly above it and then maybe getting to the point where they may have significant volumes and then you can consider getting them to provide some of their sales, packaging data. 01:55:59.680 --> 01:56:14.470 And but if you keep out just the annual revenue source, you will reduce the burden because people will those companies will need to report your taxes regularly and it will be an easy check to say, yeah, you're below below this revenue threshold. 01:56:14.520 --> 01:56:32.090 No, there's no reporting as required or you just for simplicity you can just set a flat fee for the organizations and that way they're not going through a massive administrative burden, spending hundreds of hours to realize that their total fee is $100 to the pro. 01:56:44.430 --> 01:56:53.630 And so the law does have, I think it has two there are two ways you can qualify as being exempt because you're so small. 01:56:53.640 --> 01:57:01.680 One of them is revenue and the other one is a ton of packaging material, which is I guess the much harder thing to quantify. 01:57:04.430 --> 01:57:08.230 And then the low volume producers is based on packaging material too. 01:57:12.000 --> 01:57:16.220 But that's good to keep in mind the fact that revenue piece is really easy. 01:57:29.570 --> 01:57:35.330 Any other thoughts on auditing generally level playing field? 01:57:41.190 --> 01:57:41.430 OK. 01:57:45.450 --> 01:57:47.310 We have one question on timing. 01:57:49.340 --> 01:57:52.850 When should producers be expected to report? 01:57:52.860 --> 01:57:56.960 When, when do participating municipalities wanna receive their reimbursement? 01:57:59.460 --> 01:57:59.710 Yeah. 01:57:59.720 --> 01:58:00.790 So those are related, right? 01:58:00.800 --> 01:58:05.170 Because producers need to report before municipality need to receive their reimbursement. 01:58:11.500 --> 01:58:22.950 We noticed that the Canadian reporting deadline for the, at least for the programs that we were looking at, umm, I think those are the Canadian Stewardship Alliance. 01:58:24.170 --> 01:58:24.600 Thank you, miss. 01:58:24.610 --> 01:58:29.520 Them was May 31st, which I think would be too late for municipalities. 01:58:29.830 --> 01:58:30.470 Neil, please. 01:58:32.630 --> 01:58:42.600 Yeah, because I was just gonna mention that on the Canadian side, it's mostly May 31st because typically you were asking companies to report your calendar year data. 01:58:42.650 --> 01:58:43.920 So January to December. 01:58:44.390 --> 01:58:55.040 So it does take a couple of months for them to pull the packaging weight information to report into the system in the midst of potentially other year end and budgeting needs. 01:58:55.050 --> 01:59:11.810 So the May 31st has been that balance of it's far enough away from people's year end and all of their other financial obligations and gives atleast ability to report on a full year basis in the Ontario context. 01:59:11.860 --> 01:59:21.810 And and it's typically A2 year leg, so municipalities would report their cost for say calendar year 2023. 01:59:21.820 --> 01:59:28.370 They would report that information in 2024, which would then need to be fed to the PRO. 01:59:28.600 --> 01:59:38.330 Who then has to take the sales information and the cost information to say how much do we need to pay to cover the municipal costs? 01:59:38.720 --> 01:59:42.270 And those invoices would go out in 2025. 01:59:42.580 --> 01:59:49.600 So the 2023 cost municipalities incur won't get paid until 2025. 01:59:49.610 --> 01:59:51.950 And that's for better or worse. 01:59:51.960 --> 02:00:03.270 That's the only way you can have, umm, actual cost being represented in case it takes time to verify information to go through a fee setting process to determine what producers owe. 02:00:03.280 --> 02:00:08.960 Because one is an input to the other, so by time you're actually collecting funds from companies. 02:00:09.950 --> 02:00:12.580 The first, our invoices don't go out until January. 02:00:12.850 --> 02:00:16.310 On this case, January 2025 for 2023 costs. 02:00:18.700 --> 02:00:54.110 So but if if municipalities abilities were able to provide their cost data in March, say, or in April, and producers were reporting their packaging at the end of May and and the the cost per ton that the producers paid was just direct results pretty much with a little bit of eco modulation of the cost per ton realized by municipalities. Umm. 02:00:56.430 --> 02:00:59.710 Producers could then pay right on May 31st, right? 02:00:59.720 --> 02:01:04.100 Like they know we already know what it costs because we already know the cost per ton. 02:01:04.110 --> 02:01:14.020 And so you producer produced 100 tons and so you just figured that out and you're reporting that on May 31st and you send a check with your report. 02:01:16.140 --> 02:01:39.490 If you could truly isolate the recycling costs, which becomes challenging when you look at like integrated waste management contracts because they'll have garbage costs and maybe organics, I'm not as familiar with the Maine waste system, but if you have like organics, composting, other programs all tied into one contract, you'll need a way of separating just the recycling portion of that to be paid by companies. 02:01:39.940 --> 02:01:50.860 And in the Ontario context that usually took about two months just to verify municipal cost to make sure that there was an overreporting or they didn't report their garbage cost as a recycling cost. 02:01:50.870 --> 02:02:16.580 And there was this overpayment for the system so that verification process usually took into till the middle of summer and then they had to tie those costs to get the PROs had to tie the verified municipal cost which in Ontario was done by the RFRA, the resource productivity and Recovery Authority, they would provide their verify information to store ship Ontario. 02:02:16.590 --> 02:02:18.150 Stewardship Ontario would take that information. 02:02:18.800 --> 02:02:27.850 Go through their fee setting equal modulation process and usually provide fee rates by September and that's where producers had an opportunity. 02:02:27.860 --> 02:02:37.530 If there was something that questions, concerns consulted on those fee rates by month or two to provide feedback, typically there weren't any major changes. 02:02:37.800 --> 02:02:49.480 And then, you know, October, November you would have final fee rates and then the producers would know for their upcoming year how to budget those prices into their overall budget. 02:02:55.600 --> 02:03:05.450 One thing to consider here too is that some municipalities might have an annual look back at the end of the fiscal year, which is in July or the end of June. 02:03:05.760 --> 02:03:16.750 So we might not know it like they could be paying into the system and then realize a a revenue returned, you know what I'm saying? 02:03:16.760 --> 02:03:20.180 If they're like looking at their monthly costs, that might not be accurate. 02:03:21.690 --> 02:03:21.980 Right. 02:03:20.190 --> 02:03:24.350 When they look at the end of the fiscal year, sorry, yeah. 02:03:26.860 --> 02:03:36.370 So municipalities might we were sort of assuming that municipalities would want to get paid before the start of the new fiscal year. 02:03:36.720 --> 02:03:41.830 You're saying that maybe municipalities wanna report likely would need to report on the fiscal year. 02:03:43.600 --> 02:03:44.280 Yeah. 02:03:44.400 --> 02:03:45.590 Yeah, they might have to. 02:03:45.920 --> 02:03:50.720 I I don't know if we have any municipalities on that call that might wanna share, but. 02:03:54.260 --> 02:03:59.830 That's one thing I would I guess I we wouldn't know necessarily the true costs until the end of the fiscal year. 02:04:00.300 --> 02:04:02.430 And there's a look back for some contracts. 02:04:15.060 --> 02:04:15.900 Which could delay it. 02:04:15.910 --> 02:04:19.820 I know that a lot of municipalities are I. 02:04:19.900 --> 02:04:21.780 They may waiting over a year for me. 02:04:26.280 --> 02:04:26.580 Right. 02:04:27.820 --> 02:04:28.980 Right, I'm getting started. 02:04:40.950 --> 02:04:52.880 But what Neil did definitely say is that May 31st, getting a calendar year's data from a producer before May 31st is pushing it correct. 02:04:55.160 --> 02:04:55.310 And. 02:04:55.100 --> 02:04:55.350 Correct. 02:05:05.880 --> 02:05:06.780 Even else on timing. 02:05:17.780 --> 02:05:18.390 OK. 02:05:18.560 --> 02:05:35.620 So our last topic is you want and we'll do this one, OK, we we do have before we move out of producer reporting, OK, we have one more question to propose and that's a little bit of context for that question too, so. 02:05:40.220 --> 02:05:50.050 For the low-volume producers, we're allowed us to require information from low-volume producers. 02:05:50.500 --> 02:05:57.240 Last meeting, I think it was last meeting, we were talking about possibly. 02:06:00.500 --> 02:06:23.090 Allowing for volume for low-volume producers to voluntarily report more specific information on their packaging regarding whether it's readily recyclable or not, we've got some preliminary estimates on the cost per ton of managing packaging material types that suggest that $500.00 a ton. 02:06:24.310 --> 02:06:24.550 Uh. 02:06:24.550 --> 02:06:31.430 Is not sufficient to cover current municipal costs of managing some packaging types. 02:06:32.570 --> 02:06:41.420 However, that $500.00 a ton is the the maximum that a low producer, a low-volume producer could be charged. 02:06:41.470 --> 02:06:56.140 So given that as an incentive, would we want to charge less than $500.00 a ton if a low-volume producer voluntarily provides information about the types of packaging material that they put on to the market and Maine? 02:07:01.420 --> 02:07:14.770 Against the reason that we're interested in knowing that is that municipal reimbursement for packaging material, that is not readily recyclable, requires that we know the amount of packaging material that's not readily recycled. 02:07:14.780 --> 02:07:22.700 That's sold into me because they're not reimbursed on what they disposed, they're reimbursed on the amount that they're assumed to have had to handle. 02:07:22.930 --> 02:07:30.270 So producers sent this much 100 tons of readily recycled material into Maine or. 02:07:32.170 --> 02:07:49.140 1.3 million and so we assume that one pound went to each Maine resident and so municipalities that have 100 people get 100 pounds get reimbursed for managing 100 pounds of really recycled material of material that's not readily recyclable. 02:07:49.650 --> 02:07:56.000 If we don't have information from low-volume producers, that tells us how much material they put on the market. 02:07:56.010 --> 02:07:57.400 That's not readily recyclable. 02:07:57.570 --> 02:08:11.750 Municipalities can't get reimbursed for that, and so we're wondering about whether it's a good idea to make it incentive for those low-volume producers to provide that information. 02:08:12.900 --> 02:08:13.220 Umm. 02:08:13.420 --> 02:08:17.090 Even though by having to pay less, if they do so. 02:08:18.330 --> 02:08:18.670 Umm. 02:08:20.360 --> 02:08:27.690 Given the fact that they're already probably paying and might not be covering their costs with the max that we're allowed to charge them. 02:08:38.460 --> 02:08:39.020 It doesn't work. 02:08:42.140 --> 02:08:44.820 With them against kind of. 02:08:44.830 --> 02:08:45.650 I'm thinking about it. 02:08:47.780 --> 02:08:50.010 We pulled both. Perfect. 02:08:55.600 --> 02:08:57.370 Ohh, we got a live one. Peter. 02:09:01.080 --> 02:09:01.220 Yeah. 02:09:05.510 --> 02:09:05.820 I'll. 02:09:05.870 --> 02:09:08.940 I'll just say it does sound like a win win incentive. 02:09:09.050 --> 02:09:19.300 So if you if you're working with the low-volume producer that is wanting to get you more accurate information and some incentive with sounds like a win win to me. 02:09:24.090 --> 02:09:24.300 Right. 02:09:25.220 --> 02:09:25.530 Thank you. 02:09:33.080 --> 02:09:33.320 Yeah. 02:09:36.850 --> 02:09:51.900 This is the goal, Elena, to just come up with a number of of the pounds or tons of material that are not readily recyclable that are not covered under the program is that is that the ultimate goal? 02:09:52.330 --> 02:09:52.600 No. 02:09:52.610 --> 02:10:05.660 To just determine the tons of material that's not readily recyclable, that is covered under the program that's municipalities are supposed to get reimbursed for material that's not readily recyclable, right? 02:10:05.740 --> 02:10:10.710 That they have to manage, but we're not paying them based on what? 02:10:10.820 --> 02:10:11.780 The trash they produce. 02:10:13.670 --> 02:10:27.660 Instead of that there look you were using the number of tons of material that's not readily recyclable, that everyone all producers other than those low volume producers are gonna be telling us how much not readily recyclable material they produce. 02:10:27.910 --> 02:10:36.970 And so with that number of how much not readily recyclable available there is out there, you just give that per capita to the municipalities and assume they had to manage that much. 02:10:37.990 --> 02:10:39.580 But we don't know how much of that. 02:10:39.650 --> 02:10:45.520 We're not gonna know how much of that low-volume producer material is not readily recyclable versus readily recyclable. 02:10:47.500 --> 02:10:52.850 And so that's the issue, if that makes a little more sense. 02:10:55.290 --> 02:10:55.830 Maybe it doesn't. 02:10:57.130 --> 02:10:57.990 Sorry, there's. 02:10:58.000 --> 02:10:59.500 You're you're you're exempting. 02:10:59.610 --> 02:11:00.420 You're you're. 02:11:00.470 --> 02:11:02.920 I mean, I remember the law right there. 02:11:02.970 --> 02:11:06.780 You're exempting some producers from this because there are such a low volume. 02:11:06.790 --> 02:11:08.580 Yeah, those are so those folks. 02:11:08.590 --> 02:11:08.960 So. 02:11:09.000 --> 02:11:13.270 So you're not ever gonna reimburse the municipalities for everything that they're processing? 02:11:14.700 --> 02:11:15.260 No. 02:11:15.760 --> 02:11:16.130 Right. 02:11:16.260 --> 02:11:22.970 And so, so was the idea to try to try to figure out what the what the whole pie is of. 02:11:23.300 --> 02:11:28.710 So there's a low volume, there's an exempt producer, and then there's a low volume producer who's not exempt, right? 02:11:30.290 --> 02:11:41.950 Umm, municipalities are actually being reimbursed for packaging, which doesn't exclude packaging is put on the market by someone who's. 02:11:44.300 --> 02:11:51.240 Umm, but right, the idea is to to understand that whole pie of not readily recyclable packaging. 02:11:53.900 --> 02:11:54.340 Umm. 02:11:57.280 --> 02:11:58.710 In particular, what comes from? 02:11:58.720 --> 02:12:07.720 I think I think understanding what comes from producers that are exempt is probably 1 not worth our while and two. 02:12:09.900 --> 02:12:10.610 Impossible. 02:12:11.220 --> 02:12:21.870 But but the low volume producers are up to 15 tons of material and umm, are already reporting to us. 02:12:22.960 --> 02:12:32.230 So it would seem like we could potentially get that information little more granular from them to like complete the pie a little bit more. 02:12:33.520 --> 02:12:34.750 Umm of what? 02:12:34.760 --> 02:13:04.440 That that quantity of not really recycled packaging is, umm, that said, in order to do so, we would be taking, we would be charging them less than would be charging them less and umm, at least for some packaging material types, we've seen that the the cost is essentially higher than what we're allowed to challenge charge someone to the statue. 02:13:11.860 --> 02:13:13.270 Peter, did you have something to add? 02:13:16.870 --> 02:13:18.330 No, sorry about that. 02:13:18.390 --> 02:13:19.310 Just left my hand up. 02:13:22.260 --> 02:13:23.540 So nothing. 02:13:23.550 --> 02:13:23.850 Bye. 02:13:23.940 --> 02:13:24.320 Yeah. 02:13:24.330 --> 02:13:25.010 Thoughts on that? 02:13:25.020 --> 02:13:25.970 So move on. 02:13:26.560 --> 02:13:27.750 If we saved the best for last. 02:13:30.010 --> 02:13:31.250 Eco modulation. 02:13:31.820 --> 02:13:34.240 I think that the people must have. Yep. 02:13:34.290 --> 02:13:59.770 So yeah, when it comes to the prioritization of the incentives and the payment schedule, we're just wondering, yeah, do we want to conform to other jurisdictions or if we or do we wanna strongly prioritize 1 incentive or do we wanna prioritize a limited number of incentives? 02:14:02.670 --> 02:14:03.060 Thank you. 02:14:03.460 --> 02:14:31.170 And I'm gonna sound off the list of of incentives here, and no particular order, but the incentives that need to be considered here are the use of recycled content, increased recyclability, lower toxicity reduction and amount of packaging, reduction of litter, increased reuse, labeling or or other. 02:14:36.920 --> 02:14:44.530 So that's the list of things that are in the statute, as this should be part of your eco modulation schedule. 02:14:46.760 --> 02:14:48.510 And one of the questions we asked was. 02:14:51.020 --> 02:14:55.810 One like the idea that you're gonna prioritize everything on that list, is kind of silly. 02:14:55.920 --> 02:14:57.200 I think we can probably all agree on that. 02:14:57.940 --> 02:15:01.400 Umm, so the question then becomes do we want to just? 02:15:02.860 --> 02:15:03.260 Umm. 02:15:04.220 --> 02:15:13.430 Obviously, if we were had the same eco modulation fee as other jurisdictions, that would provide a stronger, clearer incentive to producers. 02:15:13.520 --> 02:15:28.140 So do we wanna try to do that or is there some incentive on that list that we feel very strongly about that Maine wants to prioritize and we wanna do that instead of conforming to other jurisdictions one or or or a few? 02:15:30.680 --> 02:15:32.950 Neil, please, no. 02:15:41.870 --> 02:15:42.590 Uh, thank you. 02:15:44.340 --> 02:15:54.090 I think from the Canadian context, there isn't really eco modulation in terms of all of these criteria. 02:15:54.640 --> 02:16:07.590 Most of the eco modulation is done through recyclability and cost to manage, which tends to be and at least measurable from a consistent basis within jurisdictions. 02:16:07.640 --> 02:16:30.850 Once you introduce like toxicity and reuse and litter, it really becomes much, much more complex to measure and understand which organizations are kind of participating in, you know, say depending on where they source their materials toxicity, you can change significantly from one one source forces another source. 02:16:31.760 --> 02:16:46.880 I think the key learning from the Canadian context is is there's a lot of talk about eco modulation and it's typically in the sense that most EPR programs, fee models, has this, uh, perverse, where the more you recycle, the more you pay. 02:16:46.930 --> 02:16:56.170 So the idea is if you introduce eco modulation you will create continue to create an incentive for companies to recycle more without having a linear cost increase. 02:16:57.560 --> 02:17:05.330 The challenge is no one's quite figured out how to eco modulate that because there has to be a cost associated with the service received. 02:17:05.340 --> 02:17:13.650 So the more of your materials that take up a recycling bin, a truck enter a MRF, the more in theory you have to pay. 02:17:13.800 --> 02:17:23.540 So you have to find a balance between the fee for the service you receive versus not creating a defense disincentive to recycle more. 02:17:24.120 --> 02:17:35.470 And I think the only way you can address that is to allow the PRO to work with their producers to figure out where they want to draw those lines because it is a bit of a 0 sum game. 02:17:35.480 --> 02:17:41.160 If you modulate fees from one and reduce your cost, someone else has to pay that cost. 02:17:41.170 --> 02:17:42.330 So there are gonna be tradeoffs. 02:17:42.340 --> 02:17:59.230 And then it will be a contentious issue when you recognize costs are being shifted from one to the other, the other risk to that as well is that in some cases like the use of PCR has a greater cost than the use of virgin materials. 02:17:59.240 --> 02:18:06.230 So there is a greater burden for companies that you want to create a modulated fee that can incentivize the use of PCR. 02:18:07.520 --> 02:18:23.010 But you also have this potential unintended consequence where mid to larger organizations will typically have a ability to use PCR, whereas in mid to small sized can't take the hit for the additional resource requirements. 02:18:23.480 --> 02:18:25.770 So everyone's gonna find this balance. 02:18:26.140 --> 02:18:47.530 Everyone will need to find this balance to say how much are we willing to incentivize and then how do we adjust it going forward as we measure the results of the programs effectiveness, because if it's not getting the unintended, if it's not achieving the intended outcomes, then you want to give the ability for the PRO to adjust that to say all right, we're gonna increase the weighting of this. 02:18:47.580 --> 02:18:51.620 So we get more recycled content usage or more reusability, things like that. 02:18:53.000 --> 02:18:54.620 There is unfortunately no silver bullet. 02:18:57.330 --> 02:19:00.460 So I think we, I think we don't have the same 0 sum game. 02:19:01.500 --> 02:19:13.800 Please correct me if I'm wrong, because in Maine's law requires that producers pay regardless of recyclability. 02:19:13.850 --> 02:19:18.510 More if they're material isn't recycle able? 02:19:21.060 --> 02:19:27.120 And Per ton put on the market, so there's no direct, there's no direct. 02:19:31.020 --> 02:19:38.310 There's not a let's look at how much we have to pay municipalities, and then we're gonna use that number to set up producer fees. 02:19:38.820 --> 02:19:40.230 It's a per ton. 02:19:40.240 --> 02:19:47.210 How much did it cost municipalities to manage this material and not producers pay per ton for material they put on the market. 02:19:47.560 --> 02:19:59.600 So I think we have a little bit less of the 0 sum game in that the the level of recycling isn't going to affect producer fees. 02:20:00.070 --> 02:20:06.340 Directly it's the recyclability of the packaging that affects the producer fees on. 02:20:08.890 --> 02:20:11.250 So I hope we actually do avoid that. 02:20:12.480 --> 02:20:15.970 The more you recycle, the more it cost you issue. 02:20:18.980 --> 02:20:24.840 Our next questions were about what you just alluded to at the end. 02:20:25.770 --> 02:20:31.170 Umm, how should how should incentives change over time? 02:20:31.180 --> 02:20:33.730 So that the law does note that. 02:20:35.750 --> 02:20:39.140 Goals should feed into producer fees. 02:20:40.370 --> 02:20:42.090 So umm. 02:20:44.550 --> 02:20:54.320 Meaning that one of our next questions was how should failure to meet a program goal affect the predict payment schedule, for instance? 02:20:54.330 --> 02:20:56.200 And this is just something that we made up. 02:20:56.210 --> 02:20:59.760 This is not a goal that's in any draft rule. 02:21:00.280 --> 02:21:11.160 If we don't meet a goal, say the goal is that 50% of packaging material be readily recyclable by 2030, then what happens to a penalty for being not readily recyclable? 02:21:11.450 --> 02:21:12.640 Does it go up by 10%? 02:21:12.650 --> 02:21:30.000 Does it go up by 20% and then if it is sort of automatically going up, is there a limit to how much it should be increased where you sort of get to a point where you're like, OK, like increasing the cost is not changing anything here, you don't just keep increasing it when it's you're not getting results. 02:21:34.210 --> 02:21:35.880 Yeah, maybe I have a followup question. 02:21:35.890 --> 02:21:42.600 So and maybe for clarification, so if in main every municipality they report their total cost of. 02:21:43.240 --> 02:22:00.980 And as $1,000,000 and 10,000 tons of it was recyclable, it is there a scenario where the municipalities would receive more than $1,000,000 if that was their report it cost? 02:22:03.290 --> 02:22:17.810 The municipalities will have will have reported costs for municipalities that will be per ton, feel that that are designed to this create a per ton cost for different material types. 02:22:17.820 --> 02:22:20.720 This is how much it costs this municipality to recycle. 02:22:22.000 --> 02:22:22.260 Uh. 02:22:24.480 --> 02:22:37.250 Mixed paper and from there that's and that from there you can assume that that's how much it cost that municipality to recycle box board, for example cereal box and. 02:22:35.510 --> 02:22:42.210 So would with each municipality need to determine their own cost to manage individual materials, or would they be? 02:22:42.270 --> 02:22:45.910 Would there be an average across those? 02:22:45.200 --> 02:22:55.810 So so we would be getting, we would be getting with with the help of SO auditing we would be slowly gaining more cost is what our we're proposing that we're hoping to get up to you shortly. 02:22:55.940 --> 02:23:04.360 We slowly begin gaining more cost information year after year and then that cost information is going to be used to create an A median cost. 02:23:04.370 --> 02:23:14.950 You're gonna find the median cost per ton for managing a material type, and then the municipalities will be reimbursed based on the number of tons that they were cycled at. 02:23:14.960 --> 02:23:15.820 That median cost? 02:23:16.230 --> 02:23:17.420 Yeah, median cost. 02:23:17.870 --> 02:23:18.240 So. 02:23:18.280 --> 02:23:21.860 So so there could be some municipalities, the more efficient municipalities. 02:23:22.190 --> 02:23:29.570 So 50% of the municipalities will actually receive more money for each ton of box. 02:23:29.580 --> 02:23:30.710 For that they recycled. 02:23:31.780 --> 02:23:35.940 Then it cost them in, 50% would receive less because it's a median. 02:23:38.740 --> 02:23:39.200 Hmm. 02:23:49.640 --> 02:23:50.180 Only the thing. 02:23:49.470 --> 02:23:54.130 Why wouldn't we just the actual costs or the median, whichever is? 02:23:56.470 --> 02:23:57.520 whichever is lower. 02:24:00.300 --> 02:24:00.750 Well, yeah. 02:24:00.760 --> 02:24:01.340 Why wouldn't you? 02:24:01.350 --> 02:24:03.440 Why wouldn't we just give them their actual costs? 02:24:04.670 --> 02:24:07.420 Or if it's or or the median. 02:24:07.430 --> 02:24:12.610 If they're actual costs are above the median, why would we be paying them more? 02:24:14.340 --> 02:24:18.290 Well, I guess it's an incentive to to do a better job. 02:24:19.510 --> 02:24:39.460 The statute says that you're going to pay the median and the reason that was the median and not the actual cost was because if I you know otherwise I could hire my cousin Joe to like, go around and pick up recycling for, you know, 100 bucks an hour. 02:24:40.070 --> 02:24:42.520 And I would be getting reimbursed right. 02:24:42.530 --> 02:24:43.370 There'd be no if you. 02:24:43.380 --> 02:24:49.440 If you're, if you're reimbursing it actual cost, you potentially have no incentive for an efficient, efficient program. 02:24:50.400 --> 02:24:50.890 Well, thank you. 02:24:51.050 --> 02:24:52.810 You would never be able to. 02:24:52.940 --> 02:24:55.090 You wouldn't get any more than what the median is. 02:24:56.930 --> 02:24:57.450 Well, the. 02:24:57.080 --> 02:24:59.350 Yeah, I think we would agree with that. 02:25:02.950 --> 02:25:03.140 Uh-huh. 02:24:59.360 --> 02:25:08.500 So if the median says $500.00 a ton and you have someone at 300 and someone has 700, the organization at 300 would get 100%. 02:25:08.510 --> 02:25:09.770 So they would get $300.00. 02:25:09.780 --> 02:25:14.110 They organizations are at 700, we get paid the maximum 500. 02:25:15.150 --> 02:25:19.470 So there's always an incentive to come to the median if you want to cover your full cost. 02:25:20.340 --> 02:25:27.960 Umm, but yeah, if someone's running efficient system at $300.00, you wouldn't wanna pay them $500.00 a ton. 02:25:29.000 --> 02:25:31.070 Well, then, why are they going to run an efficient system? 02:25:31.390 --> 02:25:32.320 Here's your 300. 02:25:31.480 --> 02:25:36.420 I mean, that's that's not a decision that we're making anyway, because that's a that's in statute statute. 02:25:36.430 --> 02:25:41.780 But but I think that the reason that it's in statute is that you want to incentivize that that efficient program. 02:25:44.800 --> 02:25:53.310 But that's not a decision that we're making here anyway, cause that's already been decided as you're driving towards more efficiency, the transfer level. 02:25:53.760 --> 02:25:56.620 Aren't you gonna be lowering the median cost? 02:25:56.810 --> 02:26:04.050 The right so it, you know, it'll take a little time, but that would, yeah, that would just the idea. 02:26:04.140 --> 02:26:04.650 Yeah. 02:26:04.720 --> 02:26:06.440 Is that that's the idea behind that, right? 02:26:06.450 --> 02:26:17.800 The the inefficient, more costly programs will it didn't make themselves more efficient in order to match what they're getting and drop that meeting. 02:26:17.810 --> 02:26:24.470 Drop that cost and then then they'll slowly kind of equalize out the cost. 02:26:26.500 --> 02:26:38.100 And the slip to that is if a program operates at 300 and you pay them 500, then they have an incentive to go up to $500.00 and then the median shifts as that number goes up too. 02:26:38.130 --> 02:26:38.860 No, they don't. 02:26:38.870 --> 02:26:46.640 Because if I'm if I'm spending 300 bucks and you're giving me 500 bucks, I don't have an incentive to spend 500 bucks. 02:26:47.020 --> 02:26:49.010 My incentive is to spend as little as possible. 02:26:49.020 --> 02:26:54.060 If you're gonna give me 500 bucks and I only spend 200 bucks and I get 300 bucks for my pocket. 02:26:57.660 --> 02:26:59.930 Yeah, that's one way else, yeah. 02:26:58.760 --> 02:27:03.580 That I I I realize you're not familiar with the context of this law. 02:27:03.590 --> 02:27:10.850 The way that we are, but the reason they they did that is because anything anything I get extras is mine. 02:27:12.510 --> 02:27:12.760 Umm. 02:27:12.580 --> 02:27:13.090 So I have. 02:27:13.100 --> 02:27:18.590 I still have every incentive to go lower versus if I were only if I'm gonna have to. 02:27:18.640 --> 02:27:22.430 If I'm only gonna get 300 bucks, then why am I gonna bother? 02:27:22.440 --> 02:27:23.180 Be incentive. 02:27:23.190 --> 02:27:24.200 Why am I gonna bother? 02:27:24.210 --> 02:27:33.870 Like bust my **** to do to do a $300.00 per ton program when I'm only gonna get 300 and I could be getting 500 if I work a little bit less hard. 02:27:33.980 --> 02:27:43.740 Well, but does that mean then that General Mills and Kellogg and American and other companies are gonna be funding, you know, cops and firemen? 02:27:43.890 --> 02:27:56.040 Not that those aren't good reasons, but I mean, if they're, if the towns are getting an extra $200.00 per ton for recycling something better than the average, they can't. 02:27:56.170 --> 02:28:00.190 They and they keep that money and it's scope. 02:28:00.200 --> 02:28:00.850 What going to? 02:28:02.100 --> 02:28:02.460 Crossing. 02:28:02.960 --> 02:28:04.150 Education. 02:28:04.260 --> 02:28:06.510 I mean the the fixing roads and bridges. 02:28:06.520 --> 02:28:06.850 Why? 02:28:06.860 --> 02:28:07.540 Why does it? 02:28:07.890 --> 02:28:11.330 Why would the producers be having have to pay for that? 02:28:11.390 --> 02:28:14.730 The producers are paying for the median cost of managing their materials. 02:28:14.740 --> 02:28:21.840 The median cost of managing my cereal boxes in the state of Maine is $100 per ton, and that's what I'm paying $100 per ton. 02:28:25.020 --> 02:28:31.370 But this is this is also a question seems like you're dropping that, but that's maybe that's what, maybe that'll be taken up later. 02:28:31.380 --> 02:28:34.050 But that does seem like it's been taking up three years ago. 02:28:34.060 --> 02:28:34.300 I did. 02:28:34.760 --> 02:28:45.130 But but when something but then again the producers are paying municipalities that are inefficient, less money and they're actually, then they're actually paying pending. 02:28:45.140 --> 02:28:48.980 So that's so yes, you could look at it that OK, yeah. 02:28:48.990 --> 02:28:53.600 So, so one municipality that's super efficient will get an extra 100 bucks to do with. 02:28:53.610 --> 02:29:14.840 Yeah, what it wants, but the but the in the inefficient one is is going to not get fully reimbursed and the producers are still going to technically are going to pay the same amount of money because it's the thing it's based on the mean it's the median. 02:29:15.110 --> 02:29:16.830 So they're gonna pay the same. 02:29:18.430 --> 02:29:22.690 They would pay the same if it was a straight up reimbursement or not. 02:29:23.070 --> 02:29:34.110 The median incentivizes people to be more efficient because, yeah, they'll get an extra 50 bucks to give their police station or whatever they want to do with it. 02:29:35.000 --> 02:29:56.770 But that's what then, over the course of time, that range should become smaller because those that are being inefficient will be efficient and the and those that are being efficient are trying to still try to be more efficient. 02:29:56.780 --> 02:29:57.040 Yeah. 02:29:57.050 --> 02:29:57.550 So. 02:29:57.730 --> 02:29:59.860 So you'll kind of get it won't be this like this. 02:29:59.870 --> 02:30:02.840 It'll be more of a shift to them. 02:30:02.900 --> 02:30:03.240 Yeah. 02:30:03.250 --> 02:30:03.740 Price. 02:30:04.090 --> 02:30:04.580 Yeah. 02:30:04.830 --> 02:30:10.640 So and the producers, though, will pay exactly the same, because it's the median. 02:30:11.190 --> 02:30:18.440 So it just it it more as an overtime should pay less because you couldn't set it, you got set up has to do better, yeah. 02:30:20.470 --> 02:30:25.050 Yeah, in in the Ontario context, they kind of went through the same uh. 02:30:25.060 --> 02:30:26.320 Paths. 02:30:26.520 --> 02:30:46.610 As long as the performance metrics and the materials collected are consistent, that works because the one way some municipal identities, just the reality behind it is to get an efficient cost of the system is you reduce the number of material you really collect the easy to sort materials and your dollar per ton becomes really low. 02:30:46.700 --> 02:30:55.140 And then the larger municipalities because they are providing greater typically greater services, they're cost per ton increases because they're handling more complex material. 02:30:55.670 --> 02:31:00.500 So long as you have in the ability to manage those bounds, that it's fairly consistent. 02:31:00.510 --> 02:31:16.500 Otherwise you're not comparing apples to apples where organization may just pick pick cardboard paper boxboard, PT, steel and aluminum, and then we'll leave everything else off the list and your dollar per ton will look fantastic. 02:31:17.460 --> 02:31:17.780 Umm. 02:31:17.090 --> 02:31:22.980 And then they're getting paid to median, where a municipality is collecting mixed plastics, film and everything. 02:31:23.390 --> 02:31:28.490 And then you have a municipality pocketing it without actually increasing the version. 02:31:28.500 --> 02:31:36.830 So as long as there's some bounds to that in terms of how you use the median, you can create some unintended consequences which happened in the Ontario space. 02:31:37.330 --> 02:31:43.440 Well, the well, the medians permit the material type of material, it's material type and then in order for municipality to. 02:31:45.890 --> 02:32:00.970 Be eligible, they have to collect everything that's considered readily recyclable, so they can't just they all we're we're just going to collect aluminum cans and then we're going to get reimbursed for everything that's recycable. 02:32:03.690 --> 02:32:03.960 Yeah. 02:32:03.970 --> 02:32:07.790 So luckily someone thought of that already or or got lucky. 02:32:10.680 --> 02:32:11.450 Combination. 02:32:11.600 --> 02:32:12.280 Maybe a little about. 02:32:20.020 --> 02:32:29.890 But do we have any thoughts on on conforming versus it sounds so it sounds like no one has strong priorities in that list that they think Maine should like prioritize toxicity. 02:32:30.400 --> 02:32:33.950 That may be the best thing to do is to follow other jurisdictions jurisdictions. 02:32:50.030 --> 02:32:50.440 Than that. 02:32:56.140 --> 02:32:56.410 Here. 02:32:58.140 --> 02:33:08.310 Umm, so we were to follow Canada and use recyclability, which is the law already kind of requires and and Cost to manage. 02:33:09.440 --> 02:33:22.710 Uh, the law requires that you know, we it producers that are producing packaging that's not readily recyclable and more than those that are producing packaging that's readily recyclable. 02:33:23.580 --> 02:33:25.060 The next question is how much more? 02:33:27.270 --> 02:33:27.710 Umm. 02:33:30.750 --> 02:33:31.530 Any thoughts on that? 02:33:32.680 --> 02:33:35.860 50% more double, triple 10 times more. 02:33:37.760 --> 02:33:39.410 Anything. Exponentially. 02:33:42.950 --> 02:33:46.620 Because you could kind of go anywhere with that, yeah. 02:33:48.670 --> 02:33:52.440 I no thought about the difference between not readily recyclable and readily recyclable. 02:33:52.450 --> 02:33:54.140 Yeah, much more. 02:33:54.150 --> 02:33:55.860 How much more should it cost to make trash? 02:33:56.450 --> 02:33:56.960 OK. 02:33:57.210 --> 02:33:59.400 We have Neil come on now. 02:34:08.770 --> 02:34:09.340 Hello. 02:34:09.430 --> 02:34:09.990 Yeah. 02:34:10.050 --> 02:34:21.050 So I I don't have an opinion on what that should be specifically, I was just gonna suggest that that would be something that could potentially be. 02:34:22.590 --> 02:34:39.210 Changed over time by the annual committee that gets together with the SO and the producers and municipalities, something that they may want to discuss and and change based on current conditions because the odds that we'll get it right up front and it'll work perfectly. 02:34:39.730 --> 02:34:41.450 I think it's probably pretty hard. 02:34:41.460 --> 02:34:44.190 This seems like something that would we'd wanna be able to pull that lever. 02:34:44.360 --> 02:34:45.320 So that's all. 02:34:47.850 --> 02:34:49.370 Thank you. Thanks. 02:35:10.190 --> 02:35:11.610 That people are gonna wanna talk about. 02:35:11.620 --> 02:35:12.360 eco modulation. 02:35:16.860 --> 02:35:17.490 I was better. 02:35:17.560 --> 02:35:18.070 Yeah. 02:35:18.080 --> 02:35:18.290 Yes. 02:35:18.490 --> 02:35:22.950 And they're waiting for the movie. 02:35:22.960 --> 02:35:24.030 They're gonna wait for the book. 02:35:30.280 --> 02:35:34.640 That is, that's our last question that we prepared for today's meeting. 02:35:36.090 --> 02:35:41.350 Uh, so does anyone have any, I guess final thoughts that hasn't come up. 02:35:46.640 --> 02:35:48.250 And the other issues items. 02:35:53.080 --> 02:35:55.500 Ohh Neil. 02:35:56.200 --> 02:35:57.340 Yeah, I mean something. 02:35:59.660 --> 02:36:06.000 Ohh and so make Bill and then Michael. 02:36:05.960 --> 02:36:25.830 Hey dude, just maybe one quick question recognizing that each or if may need to come up with a dollar per ton for the recyclable materials they manage, how will the system manage that the composition in each community might differ like the consumption patterns made it really vary. 02:36:26.640 --> 02:36:32.120 How does it get factored into figuring out the dollar per ton for each material managed? 02:36:34.600 --> 02:36:41.460 So what we we were planning on not factoring it in as being different across communities and just using a. 02:36:44.000 --> 02:36:54.270 Random samples of material going into the MRF is how we were planning on doing that, but we're certainly open to alternatives cause it just seemed overwhelming to do anything different. 02:36:54.280 --> 02:37:00.570 But it is the way we can factor that in part of the way we would create those similar municipalities. 02:37:02.930 --> 02:37:03.150 Hey. 02:37:11.290 --> 02:37:12.060 With that, Wi-Fi. 02:37:14.360 --> 02:37:15.330 Are you friend weird? 02:37:06.740 --> 02:37:16.940 Yeah, I think I've been involved in a waste audits and typically in like rural communities, you will see like you'll see an abundance of like cardboard. What? 02:37:15.740 --> 02:37:18.300 Yeah, no, not to the Ethernet kit. 02:37:18.340 --> 02:37:20.120 And that cord is up there. 02:37:24.520 --> 02:37:24.690 OK. 02:37:24.700 --> 02:37:25.240 Over there. 02:37:25.250 --> 02:37:28.110 So I don't know if it's gonna run. 02:37:28.240 --> 02:37:28.870 For good. 02:37:28.960 --> 02:37:29.470 OK. 02:37:29.810 --> 02:37:30.890 Sorry about that, sorry. 02:37:31.120 --> 02:37:31.960 No, no worries. 02:37:34.520 --> 02:37:34.750 It. 02:37:34.160 --> 02:37:40.130 And I was just going to say there could be some variations in like the world communities. 02:37:40.220 --> 02:37:47.320 Typically you see more items being purchased in bulk, so you'll see a lot more cardboard in urban communities. 02:37:47.400 --> 02:37:52.730 It's kind of a toss up depending on ecommerce and access to grocery store. 02:37:52.740 --> 02:37:57.630 So you will see potentially significant variations in composition. 02:37:58.040 --> 02:38:14.040 We you can even see composition variations in between neighborhoods within urban communities, and I imagine if there is recent wastes that will probably reflect some of those variations, which can have an impact on the cost to manage. 02:38:15.040 --> 02:38:17.980 Uh, each material in a MRF or in a community? 02:38:22.080 --> 02:38:22.360 Thanks. 02:38:23.470 --> 02:38:23.900 Thank you. 02:38:23.910 --> 02:38:24.310 Right. 02:38:24.370 --> 02:38:25.020 So that would. 02:38:25.710 --> 02:38:36.540 So I imagine your concern would be more along the lines of, like making sure that. 02:38:39.190 --> 02:38:48.760 If there's a lot of variation of what's going into the MRF, if you're going to use one number for all communities, make sure that you get that number right and you take a lot of samples. 02:38:49.210 --> 02:38:51.710 Is that maybe a way of dealing with that? 02:38:52.650 --> 02:38:53.440 Yeah, it's. 02:38:53.450 --> 02:38:55.360 And you'll want to find that balance of what? 02:38:55.410 --> 02:38:57.930 A lot of samples because they're seasonal variations too. 02:38:57.940 --> 02:39:00.290 That will happen. Umm. 02:39:02.020 --> 02:39:02.210 Me. 02:39:02.080 --> 02:39:07.390 And then just a presence of certain materials, some of the smaller volume materials may not be as present. 02:39:07.400 --> 02:39:11.300 So, uh, do you really need to do a lot of samples? 02:39:11.310 --> 02:39:22.020 If it's just gonna be a low volume material versus some of the higher volume materials and is also a considerable fixed cost in both collection and processing. 02:39:22.490 --> 02:39:27.360 So the more tons you put through it, it's not like a linear growth in cost. 02:39:27.410 --> 02:39:28.370 You just should be anything. 02:39:29.240 --> 02:39:33.330 Uh, the fixed cost over greater time, so actually seems a little bit more efficient. 02:39:33.420 --> 02:39:37.210 And then the and then there's a variable component that needs to be addressed. 02:39:40.480 --> 02:39:40.650 And. 02:39:50.400 --> 02:39:51.930 Michael, we made you presenter. 02:39:51.940 --> 02:39:55.860 If you wanted to add to that, you're welcome to. 02:39:57.700 --> 02:39:58.360 Ohh excellent. 02:39:58.370 --> 02:40:04.590 Hey, I just had a kind of a follow up question on the eco modulation discussion. 02:40:05.400 --> 02:40:11.010 Just by way of background, Mike Smaha can manufacturers Institute Trade Association represents metal. 02:40:11.020 --> 02:40:13.270 Can manufacturers, umm. 02:40:13.830 --> 02:40:22.820 So I know the lot of discussion on the recyclability of packaging or readily recyclable, which is, you know, great. 02:40:23.010 --> 02:40:31.550 But then there are a number of other factors that were listed in the in the document that you guys sent out. 02:40:31.710 --> 02:40:35.950 So just to kind of go through them all, we haven't made a decision yet. 02:40:35.960 --> 02:40:48.050 Are you guys haven't made a decision yet around, you know, material reduction, reduction of litter toxicity, increased recyclability or reuse at this time? 02:40:48.840 --> 02:40:50.790 These are all just kind of discussion points for now. 02:40:52.060 --> 02:40:57.850 Correct this, the statute requires that there's eco modulation around all of those things. 02:40:57.860 --> 02:41:12.210 We have to incentivize all of those things, and I mean, I guess sort of what happens, what are where are thinking is that what happens when you incentivize all of those things is you kind of incentivize none of them because there's give and take in whatever. 02:41:24.180 --> 02:41:24.740 Yeah, well. 02:41:12.220 --> 02:41:26.320 And so one of the things we're wondering is there, if there's one that we should really or couple that we should really prioritize and make the incentives for those significantly stronger than the incentive for the rest is is what we're trying to think about now. 02:41:27.090 --> 02:41:27.540 Got it. 02:41:27.610 --> 02:41:29.560 No, I I agree with Neil's comments. 02:41:29.570 --> 02:41:36.000 I think that this is a very broad list that and many of these factors are really difficult to to measure. 02:41:36.150 --> 02:41:44.710 So picking, you know one or two, possibly three, seems to make the most sense, so I appreciate you guys the opportunity just to to weigh in. 02:41:45.780 --> 02:41:46.730 Do you have a preference? 02:41:49.580 --> 02:41:56.940 Umm, we're gonna put forth comments, but I would say you know, obviously I incentivizing readily recyclable. 02:41:59.110 --> 02:42:00.460 Use of recycled content. 02:42:01.330 --> 02:42:02.160 Umm. 02:42:03.090 --> 02:42:07.880 And I think that the reduction in costs of collection. 02:42:08.840 --> 02:42:20.260 I material value is obviously something that that's beneficial for for our products kind of matches up with the with the strong end market demand there. 02:42:23.460 --> 02:42:23.930 Thanks. 02:42:24.060 --> 02:42:24.530 Thank you. 02:42:24.540 --> 02:42:24.900 Thank you. 02:42:24.390 --> 02:42:24.910 Thank you. 02:42:48.960 --> 02:42:49.530 All right. 02:42:50.330 --> 02:42:55.530 I guess last call, is there any other topics? 02:42:59.430 --> 02:43:03.030 That you wanted to discuss and so make time for them. 02:43:03.040 --> 02:43:04.660 Now school. 02:43:05.930 --> 02:43:15.140 Otherwise, we are meeting again on the 8th, so that was A to be determined if we were gonna have a meeting then or not. 02:43:15.150 --> 02:43:15.550 And we are. 02:43:15.560 --> 02:43:18.720 We're going to carry out the kind of like a hybrid meeting. 02:43:18.730 --> 02:43:26.250 We'll have comment sharing and discussion at that one time the 8th of August and same time, same place. 02:43:26.260 --> 02:43:35.500 And we're going to discuss alternative collection programs and and we'll have a background document out in preparation for that meeting to. 02:43:41.580 --> 02:43:45.330 Great, but yeah, it doesn't seem like there's any other comments left to be shared. 02:43:45.340 --> 02:43:47.070 So, OK, yes, we can conclude. 02:43:47.080 --> 02:43:48.420 Thank you so much. 02:43:48.740 --> 02:43:50.410 But they're big. 02:43:50.420 --> 02:43:51.300 They're victor. 02:43:58.360 --> 02:44:00.050 Alright, stay awake everybody. 02:44:00.060 --> 02:44:01.350 Just I had one more question. 02:44:02.220 --> 02:44:02.440 Right. 02:44:02.440 --> 02:44:07.670 You never discuss like the npeanut cans, Nestle Quik. 02:44:09.090 --> 02:44:11.390 It seems like these aren't acceptable in the metal. 02:44:11.400 --> 02:44:18.840 I could ask this to smile, but it was quick enough, but it seems like they're going to mix paper they India and probably have that setting up in the trash. 02:44:18.850 --> 02:44:19.510 You know what I mean? 02:44:19.520 --> 02:44:21.400 It's the like a Pringles can. 02:44:22.760 --> 02:44:25.870 Uh, peanuts, all those things. 02:44:25.880 --> 02:44:27.070 I have a paper. 02:44:27.720 --> 02:44:28.520 I was the other one. 02:44:28.530 --> 02:44:31.150 There the pop in French double that blows up on you all the time. 02:44:32.790 --> 02:44:39.980 A lot of people pull the Enzo off, but 10 hard to get some of those ends off of those 15 bean coffee. 02:44:40.510 --> 02:44:42.470 So we discussed that. 02:44:42.480 --> 02:44:44.940 I just missed it or it's come up again. 02:44:44.950 --> 02:44:48.320 One of the channel I was wondering. 02:44:49.530 --> 02:44:50.500 Composite cans. 02:44:50.510 --> 02:44:53.900 Yeah, combined because talked about that the paper, the paper. 02:44:53.910 --> 02:44:56.600 Yeah, just a box with a plastic window. 02:44:56.910 --> 02:45:00.340 Dream example of a component of multiple components, right? 02:45:00.350 --> 02:45:01.090 Yeah, right. 02:45:01.100 --> 02:45:01.720 Like not. 02:45:01.730 --> 02:45:04.820 It's almost not clear what the majority is. 02:45:16.640 --> 02:45:16.840 Correct. 02:45:04.830 --> 02:45:17.590 Material is and that's also where like volume versus weight it would be if you would, you would need those pieces of information maybe to determine what are you. 02:45:17.220 --> 02:45:19.460 I guess it package. 02:45:17.600 --> 02:45:20.820 I didn't know you were here though, like like depending on like. 02:45:20.830 --> 02:45:22.850 So if it's, if it's so you gotta. 02:45:23.100 --> 02:45:37.850 Cardboard metal composite can, if it actually gets pulled out as it gets pulled out as a paper, then they can't, then the ends get get coverages, get maybe get recycled. 02:45:38.000 --> 02:45:42.990 But if it if they get pulled out as a metal, then the paper gets burned, right? 02:45:43.060 --> 02:45:43.490 Yeah. 02:45:43.500 --> 02:45:45.770 So it's it's A and it often goes in the metal. 02:45:45.780 --> 02:45:46.210 Metal. 02:45:46.280 --> 02:45:46.480 Yeah. 02:45:48.320 --> 02:45:50.090 Because just because of the shape, right? 02:45:50.100 --> 02:45:50.580 Naturally. 02:45:51.480 --> 02:45:54.030 And it's a little heavier than your standard. 02:45:54.820 --> 02:45:55.390 Paper. 02:45:55.470 --> 02:45:55.910 Yeah. 02:45:55.920 --> 02:45:57.640 So it might fall through the screening. 02:45:58.910 --> 02:46:06.680 I think one way that that can be dealt with is that it could be potentially its own packaging material type. 02:46:07.410 --> 02:46:09.620 It couldn't think could identify it as such. 02:46:10.540 --> 02:46:11.090 Umm. 02:46:11.240 --> 02:46:16.690 And then whether it's readily recyclable or not would be a decision for that annual meeting. 02:46:16.710 --> 02:46:17.590 And annual meeting. 02:46:17.680 --> 02:46:26.030 Yeah, I think that's maybe that's how I've sort of imagined dealing with some of those that are like, right. 02:46:26.040 --> 02:46:28.650 It's not really components, it's almost just like on its own. 02:46:28.700 --> 02:46:29.210 It's on. 02:46:29.220 --> 02:46:30.890 It's it's not paper. 02:46:30.900 --> 02:46:31.440 It's not metal. 02:46:32.920 --> 02:46:35.350 The glass is not plastic, but it's all of them. 02:46:35.520 --> 02:46:36.910 Yeah, maybe it's just it's own. 02:46:36.980 --> 02:46:40.760 That's how I've imagined dealing with it is as its own packaging material type. 02:46:43.140 --> 02:46:43.310 Right. 02:46:41.610 --> 02:46:46.510 Umm, but but it's right, it's all along a continuum and some of them probably don't. 02:46:47.270 --> 02:46:49.170 That's a really difficult question, I think. 02:46:50.920 --> 02:46:53.040 Umm, the thing about? 02:46:52.410 --> 02:46:53.250 I'll give you that then. 02:46:56.110 --> 02:46:57.640 Thanks for bringing up the problems. 02:46:57.650 --> 02:46:58.000 Yeah. 02:46:58.010 --> 02:47:01.210 Thanks. OK. 02:47:04.520 --> 02:47:08.180 And but that. 02:47:09.510 --> 02:47:09.730 Yeah. 02:47:11.270 --> 02:47:13.790 With that, I thank everyone for attending. 02:47:14.750 --> 02:47:21.230 Uh, this was a great, great dialogue we had today and have a great rest of the evening. 02:47:22.290 --> 02:47:25.450 Yep, please join on the 8th if you can. 02:47:25.840 --> 02:47:26.430 OK. 02:47:26.580 --> 02:47:27.210 Thank you. 02:47:27.270 --> 02:47:27.730 Thank you. 02:47:27.800 --> 02:47:28.230 Bye everyone. 02:48:04.440 --> 02:48:06.690 So now everything. 02:48:06.860 --> 02:48:08.980 Which there's only one person. 02:48:08.990 --> 02:48:09.650 That's amazing. 02:48:09.660 --> 02:48:10.210 OK. 02:48:10.220 --> 02:48:14.790 So that we'd have more, more building 1. 02:48:14.830 --> 02:48:15.560 There's only one person. 02:48:16.330 --> 02:48:16.720 Yeah.