WEBVTT
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OK great.
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I am Brian Beneski, the head of the Department Sustainability Unit, and I will be handling the technical issues of the meeting.
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I would just like to introduce Elena Bertocci and Jessica Nadeau.
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They own the sustainability unit and the staff in charge of implementing the EPR for packaging program.
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Jim Guerrera Sustainability unit is here as well.
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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.
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We actually had someone from OIT here to help us set up.
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So I think we're going to be good this this meeting.
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We are.
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These meetings are part of the stakeholder process and initiated by the department.
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This is the second meeting regarding the topics of producer payments and reporting.
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The opening meeting held earlier, allowed stakeholders present comments.
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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.
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We will make sure that everyone who wishes to make a statement or ask a question will get a chance to do so.
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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.
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Additionally, it transcript will also be made available with the speeding with any additional comments received through a link on the programs website.
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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.
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Submittal is not limited to the attendees of this meeting.
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The department will accept all comments for consideration that are submitted in writing.
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Additionally, new or additional comments can be presented at anytime through the EPR for packaging email address found on our website.
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Uh, let me use registered.
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We currently have.
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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.
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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.
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So everybody hears your questions.
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You do not have to be attending in person to ask questions or make a statement.
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Just use the raise hand feature.
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I will now hand the meeting over to Elena, Jessica, and Jim.
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Everyone.
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Umm, so as usual, we we've come with discussion topics that can get the discussion started and sustain it.
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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.
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So if you do have a direction you want to take the discussion regarding, we're producer reporting and payments.
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You're welcome to put up your hand now and we'll give you the floor and use that to get the discussion started.
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OK, Neal Cowles has raised his hand, so I will make you a presenter.
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Hey, Neal.
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Hey, Neal.
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Hello, can you hear me?
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Yeah.
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Wonderful.
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Yeah.
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So at the last meeting I heard some comments around the idea of not reporting at the product level and by product.
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I'm.
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I'm.
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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.
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Some questions I had and I'm not sure if Curtis Picard is is here or not.
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But he had mentioned a few things that I would I was just wanting to get some clarification on.
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I think the the 1st it's Curtis here.
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I think he is.
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I can Curtis if you want.
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Yeah, I can make you a presenter.
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OK.
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Hold right on and then they too.
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I'll make Andy a presenter as well right on.
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OK.
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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.
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And I guess uh, to that point, I would.
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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.
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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.
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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.
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I'm specifically being able to determine if it was sold in Maine or New Hampshire.
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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.
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Sure, I'll can you guys hear me OK.
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Yep.
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Yeah, yeah.
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OK, so I knew I didn't catch the entirety of your question.
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OK.
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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.
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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.
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Yeah.
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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.
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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.
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So we just think it's going to be really challenging for anybody involved to put together any sort of master database.
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And I think we had some concerns about it being done at the UPC code level.
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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.
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But that's that's kind of what I gathered from what I did hear you say when I tuned in.
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Yeah.
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Yeah, that's that's that's good.
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Appreciate that. Yeah.
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Yeah, I'll.
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I'll just.
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So Curtis then.
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Ohh go ahead Andy.
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No, it's just gonna offer what we had suggested that still relies on the UPC or the the structure of the ISBN.
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Yeah, barcode system just would be reporting at the brick code level.
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So you would know, for example, that Frida Lay sells chips and there would be, you know, potentially, you know, some bifurcation within that.
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Yeah.
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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.
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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.
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This obviously is just relative to paying the right amount of fees and tracking UPC codes versus overall volume.
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That is generally gonna be a more known factor.
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That you know that, that granular level, the same package it's being used across the 12 different flavors of chips.
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But Frito-lay knows that they're still in a certain volume of chips versus having to constantly have the pro and or the.
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Department received that information because it's a huge amount of data.
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Yeah.
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An example that's relevant in Vermont.
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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.
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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.
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Perhaps because this is a new system.
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So and yeah, I take your point on that.
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But in terms of of the function of the law, right?
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Is is to deliver funding to assess packaging that all could be done at the brick code level without losing any performance.
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Sound of the the goal of the EPR system.
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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.
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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.
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So late.
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I'm sorry.
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I didn't mean to cut you off, but that was that was kind of where we were going.
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Yet do you?
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I would love to see examples of other people that are using this this brick code for this reporting.
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If you know of any case studies or links, I would appreciate that.
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Yeah, I mean I the chemicals reporting programs that Maine uses Washington State and Oregon all use this brick code level.
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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.
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We don't have chat function on this, never mind.
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So you know, I'll try to find a way to get it to, you know.
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OK.
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And if so, if the the reporting is unobtainable at the lower product level.
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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.
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Or maybe you're saying that it's accessible.
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It's just too hard to convey to an an outside party because of the volume.
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But it probably goes back to.
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The data is gonna be not at at the per unit per day sea level like we're not gonna be seen.
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Fees change daily to the PRO right, like you know, the second a bag is sold.
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The pro doesn't get $0.05 you know, or something like that.
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Yeah.
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Similar to the bottle deposit, right?
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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.
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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.
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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.
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But the PRO is going to establish that budget and they have the ability to make adjustments, right?
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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.
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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?
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It might be from there's a group called NPD, which tracks data nationally and breaks it down to a certain markets.
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And then they might get different data back from their distributors and their retail partners.
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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.
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So it's a whole lot easier.
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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.
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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.
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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.
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You know it's a red ball versus a blue ball, but it's in the same packaging.
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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.
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Gonna add complexity to the whole system.
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Yeah.
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Yeah. OK.
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Yeah.
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OK, OK, I understand that.
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Umm you you said something along the lines of reporting when something was sold.
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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.
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Yeah.
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Yeah.
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And it's also gonna be less CBI too, with which we didn't really touch on before.
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Yeah.
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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.
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So there's a little bit of that.
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Yeah.
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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.
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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.
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Everything.
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Yeah, and it may not have packaging, right.
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And so you're still going to have to as a producer.
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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.
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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.
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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.
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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.
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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.
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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.
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And you know, to determine what, what's our optimal?
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Eco modulation mix.
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That's that's also not overly complex.
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Where?
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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.
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Now the algorithms, not the right word, but scoring around factors.
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OK.
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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.
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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.
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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.
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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.
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Umm.
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And producers is probably would like to to advocate that somehow.
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So this seems like it would be a good good way to kind of shield them from that.
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So I think that's a really solid point about this, so.
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The brick codes.
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I'm not very aware of how a brick code versus UPC code gets assigned to a product and what.
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How can we?
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Where should we look to learn a little bit more about that system and how that just works?
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How does that happen?
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I mean, I think the department's got some experience that the Kids Safe Products Act level, right?
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So I know Kerri Malinowski.
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There's not been an incredible amount of data that has been required to be reported.
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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.
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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.
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Umm.
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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.
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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.
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And then the Interstate Chemicals Clearinghouse, too, run out of NEWMOA.
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And they manage the database that feeds into Washington State and Oregon currently.
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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.