PRO Program Plan Application: 2025-2027 Program Plan Period Page 1
Oregon Recycling Modernization Act
Producer Responsibility Organization Program
Plan Application Form
2025-2027 Program Plan Period
Prospect
ive PRO contact information
Name of organization: Circular Action Alliance
Address: Phone:
Website: www.circularaction.org
Authorized representative: Charles Schwarze Title: Chair
Address of authorized representative (if different from above): n/a
Email of authorized representative: [email protected]
Prospective PRO qualifications
Is the organization a 501(c)3 nonprofit legally operating in Oregon?
Yes No
Corroborating documents appended (check all that have been provided):
The organization’s articles of incorporation
501(c)3 letter of determination
Proof of registration with the Oregon Department of Justice as a charitable organization
Proof of registration with the Oregon Secretary of State as a foreign corporation operating in Oregon (if
applicable)
Are the organization’s producer members likely to comprise at least 10% of Oregon’s market share?
Yes No
Indicate corroborating information provided:
Has the payment of the program plan review fee been remitted to the department?
Yes No
Program information
Program name: Oregon Program Plan Date of submission: March 31, 2024
20 F Street NW, Suite 700
Washington, D.C. 20001
Executive Summary: The attached Circular Action Alliance (CAA) Oregon Program Plan 2025 – 2027 is submitted in
accordance the requirements for producer responsibility organizations under ORS 459A.875. The plan describes
how CAA will fulfill the obligations of a producer responsibility organizations under Oregon’s Recycling
Modernization Act (RMA) for the period from July 1, 2025 to December 31, 2027 if the submitted plan is approved by
the Department of Environmental Quality. The plan describes CAA’s approach to implementing RMA requirements
including: the provision of funding support for both local governments and recycling participants for recycling
activities and system improvements; the creation of a network for the collection of PRO acceptance list materials;
ensuring collected materials are recycled responsibly and education and outreach activities to communicate
recycling changes and opportunities to Oregonians.
(336) 840-9860
Page 2
Certification and Attestation
I/we hereby declare under penalty of false swearing (Oregon Revised Statute 162.075 and ORS 162.085)
that the above information and all the statements, documents and attachments submitted with this plan are
true and correct.
Signed:
Printed name: Charles Schwarz
e
Date: March 31, 2024
Table of Contents
Table of Contents
Oregon
Program Plan
(2025 – 2027)
Oregon
Program Plan
(2025 – 2027)
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Oregon Program Plan
(2025 – 2027)
Table of Contents
Executive Summary ..................................................................................... 5
Goals of the Program ................................................................................................... 5
Operations Plan ......................................................................................................... 6
Financing Strategy ...................................................................................................... 7
Equity ..................................................................................................................... 8
Management and Compliance ......................................................................................... 8
At the Center of the Transformation ................................................................................. 8
Goals of the Program ................................................................................. 10
About Circular Action Alliance...................................................................... 14
Description of the Organization ..................................................................................... 14
CAA’s Qualifications to Serve as a PRO in Oregon ................................................................ 15
Understanding of Oregon’s Recycling Modernization Act ........................................................ 15
Team Expertise and Capabilities .................................................................................... 16
Qualifications to Deliver Interim Coordination Tasks ............................................................ 16
CAA’s Producer Membership ......................................................................................... 17
Operations Plan ....................................................................................... 18
a. Collection and Recycling of USCL Materials .............................................................. 18
i. System Expansions and Improvements ........................................................................... 19
ii. Transportation Reimbursements ................................................................................. 25
iii. Additional Reimbursement and Funding for Local Governments ........................................... 30
iv. Start-Up Approach for Time-Sensitive Tasks .................................................................. 33
b. The PRO Recycling Acceptance List ....................................................................... 35
i. Proposed Approach to Achieving Convenience Standards ..................................................... 36
ii. Proposed Approach to Addressing Performance Standards................................................... 42
iii. Start-Up Approach for Establishing the Depot Collection System ......................................... 48
iv. Proposed Depot Collection Targets ............................................................................. 50
c. Materials Strategy ............................................................................................. 56
i. Proposed Additions to the USCL .................................................................................. 57
ii. Specifically Identified Materials on the USCL .................................................................. 62
iii. Specifically Identified Materials on the PRO Recycling Acceptance List .................................. 64
iv. Proposal to Trial Commingled Collection of Non-USCL Materials ........................................... 66
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v. Initial Plastic Recycling Rate Projections ....................................................................... 68
vi. Ensuring Responsible End Markets .............................................................................. 72
vii. Upholding Oregon’s Materials Management Hierarchy ...................................................... 83
d. Education and Outreach ..................................................................................... 84
i. Goals for Education and Outreach ............................................................................... 84
ii. CAA’s Education and Outreach Plan............................................................................. 85
iii. A Description of the Statewide Promotional Campaign ...................................................... 90
iv. A Culturally Responsive Approach .............................................................................. 92
v. Schedule Including Proposed Timings for Start-Up Approach ................................................ 93
vi. Relevant experience .............................................................................................. 97
Financing ............................................................................................... 99
a. Membership Fee Structure and Base Fee Rates ........................................................ 99
i. Product Speciation for the Fee Structure ....................................................................... 99
ii. Development of the Base Fee Algorithm ...................................................................... 100
iii. Preliminary Base Fee Schedule Ranges ....................................................................... 103
iv. Producer Fee Incentives, Other Than Graduated Fee Adjustments ....................................... 104
v. Meeting the Statutory Requirement ............................................................................ 104
b. Graduated Fee Algorithm and Methods ................................................................. 107
i. The Algorithm and Accompanying Descriptive Text for the Proposed Graduated Fee Structure ....... 107
ii. Methods by which the PRO will Accept and Consider Requests for Ecomodulation Credits ............ 110
c. Alternative membership fee structure (if applicable) ............................................... 113
d. Adequacy of Financing ..................................................................................... 114
Equity .................................................................................................. 115
CAA’s Proposed Approach to Equity ............................................................................... 115
CAA Management and Compliance ................................................................ 118
a. Overall Day-to-Day Management ......................................................................... 118
b. Communications ............................................................................................. 119
CAA Plans for Communication and Coordination................................................................. 119
c. Reporting ...................................................................................................... 122
Metrics and Data Collection ........................................................................................ 122
Producer Reporting .................................................................................................. 122
Annual Reporting ..................................................................................................... 122
d. Managing Compliance....................................................................................... 124
e. Dispute Resolution (Local Governments and CRPFs) ................................................ 127
f. General Policies, Procedures, and Practices........................................................... 128
i. Management of Contracts ........................................................................................ 128
ii. Workplace Safety and Conduct ................................................................................. 128
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iii. Protection of Confidential Information ....................................................................... 128
iv. Successful and Timely Delivery ................................................................................ 129
v. Retention of Information ........................................................................................ 129
g. Closure Plan .................................................................................................. 130
Certification and Attestation...................................................................... 132
a. Contents ....................................................................................................... 132
i. Contact Information .............................................................................................. 132
ii. The Prospective PRO’s Employer Identification Number .................................................... 132
iii. Proof of the Prospective PRO’s Status as a Nonprofit....................................................... 132
iv. Certifying Statement ............................................................................................ 133
Appendices ............................................................................................ 134
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Executive Summary
Oregon’s Plastic Pollution and Recycling Modernization Act (RMA) creates important changes in how materials management
is undertaken and funded within the state. The legislation strives to improve the overall effectiveness of Oregon’s recycling
collection and processing ecosystem through a shared responsibility model.
A key element of this new framework is the concept of a producer responsibility organization (PRO), the entity through
which producers of covered materials will fund recycling services, support innovation and manage collection of certain
materials through a depot system.
To achieve the objectives of the RMA, Circular Action Alliance (CAA) submits this draft program plan to the Oregon
Department of Environmental Quality (DEQ) for consideration.
As a prospective PRO, CAA has developed a detailed approach to managing and administering an extended producer
responsibility (EPR) program to fulfill key obligations pursuant to the RMA. The team behind this program plan includes a
wide range of recycling industry and policy experts with extensive knowledge in program plan development,
implementation, operations, education and outreach, and local government structure. The CAA team has spent a great deal
of time engaging with stakeholders in Oregon and referencing a wide range of applicable studies to formulate strategies and
cost estimates tailored to Oregon’s unique and dynamic materials recovery landscape.
CAA has taken DEQ’s Internal Management Directive (IMD) on the RMA PRO Program Plans as a basis for the structure of
this submission. Some adaptations have been made to the proposed IMD outline to improve narrative flow.
The table of contents, charts, and subheadings in the document will help readers effectively navigate all the plan’s content,
and brief overviews of core sections are provided below.
Goals of the Program
CAA’s overarching objective is to support the successful implementation of the RMA in collaboration with DEQ and all other
key stakeholders. It is the view of CAA that this program plan will result in successful implementation to achieve four high-
level goals:
1. Reduce the negative environmental, social, and health impacts from the end-of-life management of products
and packaging
2. Increase the diversion of recyclable materials from disposal.
3. Improve public participation, understanding and equity in the state’s recycling system.
4. Create a system that fulfills the needs and regulatory requirements of the PRO, its members, and all other
relevant stakeholders.
These top-line objectives are defined in further detail in the Goals of the Program section, along with key metrics and
measures to help chart progress and determine success.
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Operations Plan
The operations plan segment delves into the specific steps and strategies that CAA will employ to meet RMA requirements
and help catalyze a range of recycling system expansions and improvements that can lead to a stronger, more efficient
framework of materials management. This includes detailed plans and recommendations for:
Collection and Recycling of UCSL Materials – A plan for the collection, transport, and recycling of all covered materials
on the RMA’s Uniform Statewide Collection List (USCL) and a framework for deploying funding to support these
activities. Highlights include:
o The Oregon Recycling System Optimization Project (ORSOP), a critical project that will offer a more complete
picture of system gaps, opportunities for efficiency, and more. This initiative will provide additional data and
details required to more precisely estimate and schedule the distribution of funding for system
improvements;
o Key tasks to support the distribution of funding and reimbursements to eligible parties that must be
completed in advance of the July 1, 2025 (the RMA implementation date), in addition to the ORSOP:
▪ Negotiating with and then providing associated compensation (with a single accounting point-of-
contact system) to local governments for service expansion;
▪ Setting up a single accounting point-of-contact system for compensation of local governments for
expenses besides service expansion;
▪ Setting up a single accounting point-of-contact system for payment of contamination management
fees and processor commodity risk fees to commingled recycling processing facilities.
The PRO Recycling Acceptance List – This section outlines activities, timelines, and recommendations for increasing
diversion of materials named on the PRO Recycling Acceptance List, including proposed approaches to meeting
service convenience and performance standards and proposed collection targets for each material category.
Highlights include:
o Identification of 173 existing permitted depot sites that meet the state convenience standard, and another
285 to serve as substitutes if any existing facilities choose to not participate as a PRO collection point;
o Key activities to ensure timely provision of depot services that must be completed in advance of the July 1,
2025, RMA implementation date:
▪ Perform additional analysis of needs and further design of PRO depot system in consultation with
DEQ, potential partner depots, local governments, and service providers;
▪ Finalize contracts with local governments, service providers, and end markets and launch reporting
and accounting systems while onboarding key stakeholders;
▪ Open the first phase of PRO acceptance list collection points.
Materials Management – Key materials management considerations including strategies for Specifically Identified
Materials (SIMs) and engagement with and verification of responsible end markets (REMs). Highlights include:
o Proposals to expand the USCL to include PET thermoforms, transparent blue and green PET bottles, and spiral
wound containers;
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o A proposal to explore commingled, trial collection of polycoated paper packaging and single-use cups with
the intent to better understand generator behaviors and other system barriers to the inclusion of these
materials on the USCL;
o Insight into the program plan’s anticipated impact on plastic recycling and an estimate of Oregon’s current
plastic recycling rate;
o A strategy to create a materials tracking system that supports REM verification for all system participants and
proposed approach to supporting REM development.
o Key activities to support effective materials management and REMs that must be completed in advance of
the July 1, 2025, RMA implementation date.
Education and Outreach – A vision for delivering effective and harmonized education in a manner that incorporates
feedback from, and supports, local government outreach and is responsive to diverse audiences across this state.
Highlights include:
o Goals to ensure widespread recycling awareness through culturally responsive support and messaging that
has been proven to effectively drive increased participation and capture of recyclables, deployed in a manner
complementary to programmatic efforts to reduce contamination;
o Key activities to support the education and outreach plan that must be completed in advance of the July 1,
2025, RMA implementation date.
Financing Strategy
An essential role of the PRO is developing a comprehensive methodology for determining how much funding obligated
producers of covered materials are required to contribute to the statewide system. Factors such as material type, volume of
product sold into state, environmental impact of materials and commodity revenues must be properly accounted for when
designing and implementing a fair & effective program fee.
The financing section of the program plan lays out the guiding principles CAA has developed and used as the basis of an
interim base fee methodology to set preliminary base fees. This section also describes how the fee outcomes from using
this fee algorithm satisfy the RMA statutory requirements and fulfill the adequacy of financing requirement.
CAA will introduce a graduated fee algorithm to provide producers with practical and measurable criteria upon which to
qualify for fee incentives and disincentives in future program plan amendments.
In advance of the Oregon System Optimization Project being completed, a preliminary estimate of the Year 1 program
budget range is provided in Appendix E. This sum, to be covered by producer fees, accounts for management costs of
materials, service expansion costs, PRO depot system development, as well as costs to develop and sustain viable
responsible end markets and other contributions to advance program improvement initiatives.
CAA expects the program costs to be refined for future Program Plan amendments.
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Equity
There is no one-size-fits-all solution to recycling because motivators and barriers vary across age, region, race, ethnicity, and
other factors. For this reason, CAA has embedded principles of equity into the program plan in a manner that upholds and
reinforces the goals set out in the RMA. These principles are integrated into each key component of PRO administration and
program implementation.
This proposal describes how CAA has built equity into the proposed approaches for key activities, including:
The establishment of a PRO depot network
The development of responsible end markets
Development and deployment of recycling education and outreach efforts
PRO administration
CAA consulted with Oregon community-based organizations (CBOs) to develop the equity components of this plan. It
recognizes the importance of fostering relationships with Oregon CBOs to effectively address program equity issues.
In short, the program plan outlines strategies to use this transformational moment in Oregon’s materials management as a
springboard to greater equity in various areas.
Management and Compliance
As an organization helping to introduce a new approach to recycling funding and management in the U.S., CAA recognizes
the critical importance of stakeholder communication as the RMA moves toward implementation.
As such, this program plan offers a detailed explanation on CAA’s structure of day-to-day management, as well as a
communications strategy for maintaining strong connections with government entities and other stakeholders.
Furthermore, CAA has outlined data collection steps and metrics considerations to effectively track program successes and
areas in need of improvement. The elements of an optimized annual report are also explained.
Finally, this section of the plan lays out an in-depth process for tracking and maintaining producer compliance, setting clear
standards and expectations on rules, audits, and action to take place when companies are found to be in noncompliance.
This information is supplemented by important details on contract management, recordkeeping and other best practices
around organizational and program governance.
It is through these clear processes that CAA has confidence in its ability to meet the expectations of regulators, drive overall
program efficiency, and maintain strong coordination both internally as an organization and externally with partners across
the public and private sectors.
At the Center of the Transformation
The ultimate goal of RMA implementation is a transformed system of materials usage and recovery that will be responsive
to the needs of all stakeholders and that will lead to significant environmental and social benefits for Oregonians.
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CAA has invested significant resources in developing this program plan and is committed to working with recycling
stakeholders to deliver on the RMA objectives. There is no doubt that effectively and efficiently transitioning to a shared
responsibility model of materials management and delivering on other RMA priorities will be a complicated and challenging
effort and one in which producers and other stakeholders will learn much along the way.
But CAA is confident the transition can and will happen successfully.
Data-driven decision-making, combined with a spirit of collaboration and communication, will be critical in the quest to see
the RMA realize its full potential. CAA has embedded those core principles in all segments of this plan. The group is excited
at the prospect of helping Oregon usher in system shifts that help reduce costs, drive more material into an expanded
recycling marketplace, and open the door to a better materials management future.
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Goals of the Program
The overarching goal of Circular Action Alliance (CAA) for this initial program plan period is to support the successful
implementation of the Recycling Modernization Act (RMA) in collaboration with the Oregon Department of Environmental
Quality (DEQ) and all key stakeholders, including local governments, commingled recycling processing facilities (CRPFs),
haulers, and Oregon waste generators. Success will center on four critical high-level objectives:
Objective 1: Reduce the negative environmental, social, and health impacts from the end-of-life
management of products and packaging.
Program Goal
Outcomes/Indicaons of Success
Ensure that materials
collected and processed
for recycling in Oregon are
consistently delivered to
responsible end markets.
▪ System of idenfying responsible end
markets (REMs) and tracking material ows
established with full cooperaon from
comingled recycling processing facility
(CRPFs) and other key stakeholders.
▪ CRPF and depot material streams directed to
REMs.
▪ System established to address and correct
issues that arise regarding REMs.
▪ Specifically identified materials (SIMs)
directed to REMs, where practicable.
▪ Percentage of recycled material going to
REMs, including SIMs.
▪ Number, kind, and specific REMs used by
CRPFs and CAA for depot material.
▪ Number of instances in which REM material
routing has needed correction and the results
of correction.
▪ Summary of REM verification undertaken
▪ Percentage of chain of custody anomalies
detected during quarterly reporting review
process.
Design and implement
producer fee structures
that provide adequate
financing for RMA
obligations and
incentivize producers to
improve environmental
outcomes associated with
the production and
recycling of printed paper
and packaging supplied to
the Oregon market.
▪ Inial base fee schedule adequately supports
RMA vericaon of REM requirements and
other system improvements.
▪ Eco-modulaon factors integrated into
producer fee following development of
datasets and feedback mechanisms required
to adjust fees for greater impact reducon.
▪ Comparative base fees for covered products
reflecting their individual features as directed
by the RMA.
▪ Data on producer changes to packaging
materials and formats that reflect effects of
base fees (and at a later date, as applicable,
graduated fees).
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Objective 2: Increase the diversion of recyclable materials from disposal.
Program Goal
Outcomes/Indicaons of Success
Create new and expanded
opportunies for more
Oregon residents (waste
generators) to recycle a
wider array of generated
materials, including
supporng enhancement
of local collecon services
and establishing
convenient depots for
addional material
collecon.
▪ PRO-assigned depot system established,
meeng convenience standards and
providing recycling opportunies for
materials assigned for depot collecon and
impact on material recycling rates.
▪ Local government service expansion requests
evaluated and funded according to
priorizaon guidelines resulng in new
collecon opportunies created for waste
generators.
▪ Uniform Statewide Collecon List (USCL)
applied across the state to expand what is
collected in commingled recycling, and steps
taken by CAA to successfully add materials to
the USCL.
▪ SIMs collecon issues successfully addressed.
▪ Progress toward 2028 plasc recycling goals
at the end of each program year.
Facilitate the
modernizaon of Oregon’s
commingled material
processing infrastructure,
driving more ecient
capture and delivery of
high-quality materials to
end markets while
reducing loss of materials
to residue.
▪ Processor commodity risk fee (PCRF) and
contaminaon management fee (CMF)
payment system established to provide
necessary funding to CRPFs.
▪ CRPFs meeng DEQ’s performance standards
regarding capture rates and bale quality.
▪ Investments made in new equipment and
sorng processes to accommodate the USCL
and addions to the USCL.
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Objective 3: Improve public participation, understanding and equity in the state’s recycling system.
Program Goal
Outcomes/Indicaons of Success
Ensure Oregon residents
(waste generators),
reecng the states’ many
diverse communies, are
fully informed about their
recycling opportunies
and how to use those
opportunies opmally,
condently, and correctly.
▪ Increase amount of USCL and depot
materials collected, indexed against
populaon and generaon.
▪ Reducon in the amount of contaminant
materials entering the recycling collecon
stream in commingled recycling and at
depots.
▪ Increase in waste generator understanding
and condence in the recycling system across
all populaons.
Incorporate principles of
equity into the
deployment of recycling
opportunies, educaon,
and other elements of the
recycling system.
▪ Provision of equitable recycling opportunies
for populaons that may nd it dicult to
access service at collecon points.
▪ Work with local governments and
community groups to ensure any proposals
for the alternate delivery of recycling
convenience standards address equitable
access for communies and diverse
populaons.
▪ Educaonal materials that are clear and
demonstrably understandable are universally
distributed or made available.
▪ Explore and pursue opportunies with
Cercaon Oce for Business Inclusion and
Diversity (COBID) businesses and depot
collecon partners represenng diverse
communies.
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Objective 4: Create a system that fulfills the needs and regulatory requirements of the PRO, its
members, and all other relevant stakeholders.
Program Goal
Outcomes/Indicaons of Success
Key Metrics
Manage organizaonal
operaons to ensure
compliance with all statutory
requirements.
▪ Systems and mechanisms in place to fulll
CAA PRO obligaons under the RMA regarding
day-to-day management, policies and
procedures, communicaon, membership,
melines, and budgets.
▪ Mechanisms in place to address gaps,
shoralls, or other issues regarding CAA’s PRO
obligaons.
▪ Number, kind, and operaonal status
of systems and mechanisms for CAA
management obligaons.
▪ Number and nature of gaps or issues
that needed to be addressed and
resoluon status of those gaps/issues.
▪ Producer compliance acvity reports.
Provide an eecve plaorm of
support and interacon with
local governments, commingled
recycling processing facilies,
and haulers that allow them to
steadily improve their programs
and facilies to meet regulatory
targets and the goals of the
RMA.
▪ Applicaon, reporng, invoicing, and
informaonal plaorms established that are
clear, eecve, and ecient for stakeholders
to use.
▪ Mechanisms in place to use stakeholder
feedback for improving plaorms.
▪ Number and kind of plaorms in
place for stakeholder interacon.
▪ Extent of plaorm use (number of
users, etc.).
▪ Number and kind of issues with
plaorms expressed through
stakeholder feedback and any related
adjustments made to plaorms.
The following program plan details the integrated steps CAA will take to produce results that meet the objectives outlined
above. In putting this plan into action, CAA will prioritize clear and consistent engagement with all stakeholders and will
adopt an approach of continual improvement, recognizing the dynamic and complex nature of the Oregon materials
management system.
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About Circular Action Alliance
This section of the plan provides summary information about Circular Action Alliance, including details of its structure,
governance and members, as well as its qualifications to serve as a PRO in Oregon.
Description of the Organization
Circular Action Alliance (CAA) is a U.S., nonprofit producer responsibility organization (PRO) established to support the
implementation of extended producer responsibility (EPR) laws for paper, packaging, and food service ware. The
organization was founded by leading U.S. producers representing retail, food, beverage, and consumer packaged goods
manufacturing.
CAA’s 20 Founding Members are Amazon; The Clorox Company; The Coca-Cola Company; Colgate-Palmolive; Danone North
America; Ferrero US; General Mills; Keurig Dr Pepper; Kraft Heinz; L’Oréal USA; Mars Incorporated; Mondelez International;
Nestlé USA; Niagara Bottling, LLC; PepsiCo, Inc.; Procter & Gamble; SC Johnson; Target; Unilever United States; and
Walmart.
Together, CAA’s membership represents more than 900 brands sold in the U.S., representing a wide variety of covered
product material types.
CAA was incorporated as a nonprofit corporation on December 21, 2022, and is recognized by the Internal Revenue Service
as exempt from taxation under Section 501(c)(3) of the Internal Revenue Code.
The organization’s mission is to provide producers with consistent EPR services across multiple states while developing and
implementing EPR programs that:
Meet state-specific regulatory requirements
Leverage existing recycling systems and infrastructure
Advance the circularity of covered materials on a national scale through collaboration with local governments, service
providers, and recycling system stakeholders
CAA’s National Board of Directors is made up of 20 voting representatives of Founding Member companies, which
represent a diversity of covered material supplied to the Oregon market. Each Founding Member has the right to appoint
one representative to serve as a Director on CAA’s National Board of Directors.
The CAA National Board of Directors has established the following committees and has the ability to create additional
committees or dissolve committees in the future:
Governance Committee – consisting of at least three members appointed by the Board of Directors who have
relevant experience and expertise in governance, membership development, and compliance.
Finance, Audit and Investment Committee – consisting of at least three members appointed by the Board of
Directors who have relevant experience, expertise, and knowledge in accounting, auditing, investments, budgeting,
cash flow management, reserve management, and financial risk management.
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Human Resources Committee – consisting of at least three members, appointed by the Board of Directors, who have
relevant experience, expertise, and knowledge in human resources, employment law, organizational development,
and/or diversity, equity, and inclusion.
The CAA National Board of Directors intends to establish a designated governing body known as the Oregon Board, which
will have the delegated authority to act on behalf of the National Board of Directors to approve the producer responsibility
plan and the budget for implementation of the plan, as well as oversee the implementation of the approved producer
responsibility plan under the RMA. The Oregon Board will include Founding Member representatives, other producer
representatives, and non-voting members.
Additionally, CAA has engaged a third-party organization to provide support in the development of the Oregon governance
model. This organization is conducting a comprehensive review of CAA’s governance.
CAA’s Qualifications to Serve as a PRO in Oregon
CAA was established to support the implementation of EPR laws for paper, packaging, and food service ware and is fully
capable of meeting the PRO statutory requirements under the RMA. The organization has the expertise and vision to
collaboratively build a producer responsibility plan that will achieve the objectives of the RMA.
CAA’s progress to date includes the following:
On May 1, 2023, CAA became the first PRO approved to administer an EPR program for paper, packaging and food
service ware in the U.S., being appointed by the Colorado Department of Public Health and Environment (CDPHE) as
the single PRO responsible for implementing Colorado’s Producer Responsibility Program for Statewide Recycling Act.
On October 18, 2023, CAA was approved as the single PRO to represent the interests of producers in Maryland. As the
Maryland PRO, CAA will have a seat on the Producer Responsibility Advisory Council, which will make
recommendations to the Maryland governor on how to effectively establish and implement a producer responsibility
program for packaging materials.
On January 5, 2024, CAA was approved as the single PRO to deliver the objectives of the California Plastic Pollution
Prevention and Packaging Producer Responsibility Act (California Public Resources Code Sections 42040 to 42084).
As they have in these other EPR states, CAA members have invested time and resources to ensure the organization can
fulfill the specific PRO obligations in relation to the RMA in Oregon.
Understanding of Oregon’s Recycling Modernization Act
CAA has a strong and detailed understanding of the RMA. Following its incorporation, CAA was engaged in the Phase I
rulemaking process (and subsequently the Rulemaking Advisory Committee), which included the submission of comments
in July 2023.
CAA has also participated in DEQ Technical Working Groups and has pursued independent and extensive engagement with
Oregon DEQ and other Oregon stakeholders and groups, including: Oregon Refuse & Recycling Association (ORRA), local
governments and service providers, and the Association of Oregon Recyclers (AOR). Full details on CAA’s stakeholder
engagement during the development of this program plan can be found in Appendix D.
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As a result of this engagement, CAA understands not only the requirements of the statute and rules, but also the priorities
of key stakeholder groups that are essential to the success of the RMA.
Team Expertise and Capabilities
CAA Founding Members are united in their vision to create a circular economy for paper, packaging, and food service ware
in the United States. CAA’s Founding Members have experience with the implementation of various EPR programs, and
they have assembled a team of independent service providers drawn from across North America with expertise in
developing and operating EPR programs to respond to state-specific regulatory requirements and recycling system needs.
CAA team members have participated in EPR implementation and program operation for many years, playing integral roles
in the creation, operation, and improvement of PROs. The team has expertise in regulatory compliance, project
management, governance, recycling systems and materials management, system improvement, end markets, finance, fee
setting, eco-modulation, packaging design, not-for-profit operation, information technology, reporting, consumer
education, producer and stakeholder relations, and public affairs.
The CAA team also includes Oregon-specific expertise and has plans in place to hire Oregon staff, capable of supporting
implementation. This local team will supplement the organization’s central expertise to enable seamless knowledge
transfer across jurisdictions and consistent producer services. CAA’s organization charts are included in Appendix C.
Qualifications to Deliver Interim Coordination Tasks
CAA is well-qualified to deliver the start-up tasks (previously referred to as interim coordination tasks) required to launch
the program successfully on July 1, 2025, as required by state statute. In particular, the CAA team is preparing to launch the
following workstreams:
Local Government and Service Provider Engagement (Oregon Recycling System Optimization Project)
This workstream is planned for April 2024 onward. The goal is to liaise further with local governments and their service
providers on expansion needs, to finalize plans for expansions to be funded in the first program plan, and to conduct
consultations on other relevant aspects of the plan. CAA has assembled a team of experts to undertake this work, building
from the initial discussions with a selection of local governments outlined in Appendix D that have taken place since
September 2023. The team has experience relevant to Oregon’s regulatory requirements, recycling system design, and
Oregon’s local government ecosystem. More information on plans for this workstream can be found in the Operations Plan
section of this plan, under “Collection and Recycling of USCL Materials.”
PRO Depot Development (Oregon Recycling System Optimization Project)
This workstream is planned for April 2024 onward. The goal is to liaise further with existing drop-off facilities and depot
locations, as well as new potential partners to finalize a network of PRO depot locations (supplemented by events and other
collection services) to meet the necessary collection targets, convenience and performance standards, and Responsible End
Market (REM) requirements under the RMA. CAA has assembled a team of experts to undertake this work, building from
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the initial discussions with depot organizations outlined in Appendix D. More information on plans for this workstream can
be found in the Operations Plan section of this plan, under “The PRO Recycling Acceptance List.”
Education and Outreach
This workstream is planned for April 2024 and onward. The goal is to develop education and outreach collateral and a
statewide promotional campaign to communicate the USCL and PRO Recycling Acceptance List to residents and commercial
entities in Oregon. The workstream includes consultations with local stakeholders, including but not limited to DEQ, the
Oregon Recycling System Advisory Council (ORSAC), Oregon residents (in a range of geographies and housing situations),
Oregon businesses, local governments, service providers, and community-based organizations (CBOs). CAA has assembled a
team of experts to undertake this work. The team has experience in the Oregon regulatory requirements, waste generator
behavior trends, education materials development and delivery, Oregon-focused media executions, and Oregon local
government engagement. More information on plans for this workstream can be found in the Operations Plan section of
this plan, under “Education and Outreach.”
CAA’s Producer Membership
CAA membership exceeds the 10% market share threshold for covered products in Oregon required for approved PROs.
Based on available data, CAA estimates that current membership accounts for a minimum of 12% to 15% of the state’s
market share of covered products. (Details of how the market share estimate was calculated can be found in Appendix B.)
CAA is also conducting information sessions with hundreds of non-member producers regarding EPR obligations in Oregon
and other states and will expand membership further through 2024 and into 2025, in advance of the program start date.
CAA is resourced to complete all the tasks necessary to start the program, including all of the interim coordination (start-
up) tasks referenced in the RMA rules. CAA Oregon will be a subsidiary of the national organization that is supported by its
founding members. These members have made significant funding commitments to support the CAA program plan
development in Oregon and other EPR states.
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Operations Plan
The operations plan section of this program plan describes activities and recommendations for increasing the diversion of
recyclable materials from disposal to support progress toward targets outlined in the Recycling Modernization Act (RMA).
Important areas of Producer Responsibility Organization (PRO) involvement around operations include meeting local
government needs assessment requests, establishing collection depots, improving materials processing, and conducting
robust and consistent education.
a. Collection and Recycling of USCL Materials
In this subsection, CAA details how it plans to support the collection and recycling of covered products that are included on
the Uniform Statewide Collection List (USCL).
Under ORS 459A.890, local governments and their service providers are entitled to be reimbursed or be provided advance
funding for, as appropriate, eligible expenses in several RMA program areas, including but not limited to: system expansions
and improvements (costs associated with the expansion and provision of recycling collection services); the transportation of
covered products over 50 miles; contamination reduction programming and periodic contamination evaluations outside of
comingled recycling processing facilities (CRPFs); and ensuring 10% post-consumer content in roll carts.
The collection and recycling section of the program plan addresses each of these areas in turn, and it also discusses CAA’s
start-up approach to address specific time sensitive tasks (previously interim coordination tasks).
Following the submission of this initial draft of the program plan, CAA will conduct further outreach and consultation with
local governments and service providers to:
Undertake the Oregon Recycling System Optimization Project (more details are provided below)
Enable the development of more accurate local government funding estimates and prioritization of disbursements
which cannot currently be done due to limited available information.
Develop a schedule for the disbursement of funding for local government service expansion requests as per RMA
requirements
Finalize the details of how various funding programs related to USCL materials will be administered
Administrative design principles have been developed to inform further consultation as detailed below.
Administrative Design Principles
Streamlined and expeditious processes for the disbursement of eligible expenses
Clear and accessible claims submission instructions and mechanisms (reliance on online submissions where possible)
Transparent information requirements all parties should utilize understandable similar source data in support of
funding requests
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Standardized review criteria in support of prioritization and assessment of eligibility of claims (see proposed review
criteria below)
Coordination of funding program processes with local government budget cycles wherever possible
Streamlined dispute resolution processes
Appropriate accountability mechanisms to track reimbursements and any advance funding provided
For each compensation program, CAA proposes to post related policy documents, standardized registration forms, claims
submissions and other program documents on its stakeholder portal, for ease of access. These programs would also be
supported by CAA program staff dedicated to answering questions and guiding stakeholders through program
administrative processes.
i. System Expansions and Improvements
Providing financial and other assistance to local governments that need to expand recycling collection services is a critical
step in the implementation of this program plan and the execution of the RMA. The activities outlined below will help meet
a range of objectives and goals, including expanding overall opportunities to recycle, and help meet the plastics recycling
goal set out in the RMA.
Proposal for an Oregon Recycling System Optimization Project
2023 Department of Environmental Quality (DEQ) Needs Assessment Findings
Oregon DEQ released its initial RMA Local Government Needs Assessment in May 2023. While completing the needs
assessment survey was voluntary for local governments, eligibility for expansion funding from the PRO(s) in the first
program plan is contingent on completion of the needs assessment.
Two hundred forty-five local governments responded to the needs assessment survey (200 cities, 36 counties, and nine
additional county responses) with 92.2% of respondents indicating an interest in expanding recycling services.
To support program plan development, CAA consulted with a select number of local government representatives (see
Appendix D for more details) to gather more information about initial needs assessment requests and develop a better
understanding of existing recycling infrastructure in those jurisdictions.
This consultation process highlighted the different wasteshed infrastructure across the state, including a wide range of
different local government and service provider roles and responsibilities and variations in such recycling activities such as
contamination reduction activities, material flows, and current education and outreach efforts. This process underscored
the need for a second more detailed needs assessment process and continued outreach to local governments to further
develop the necessary components for RMA implementation.
The first needs assessment simply identified areas of potential interest in terms of service expansion. Local governments
checked general areas of interest to maintain eligibility for funding under the process, which may in some cases have
resulted in an inaccurate picture of needs in relation to existing recycling services. Information provided by local
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governments was insufficient to prioritize funding requests in relation to RMA rule criteria (which had not been finalized at
the time of the needs assessment survey).
As anticipated in DEQ’s Internal Management Directive (IMD) related to the program plan submission, CAA is proposing to
conduct a follow up on DEQ's 2023 Needs Assessment by conducting an Oregon Recycling System Optimization Project
(ORSOP) between April and August 2024 to gather information necessary to further develop its estimates of required local
government funding for recycling system expansions and improvements and refine the schedule for processing funding
requests in accordance with RMA rule prioritization criteria.
Proposed Approach
Given the interrelationship between local government needs assessment requests and other areas of the program plan
pursuant to the RMA, CAA is proposing an integrated approach to the ORSOP. CAA will coordinate the outreach activities
required to develop more accurate estimates of service program expansion requests (ORSOP) with continued program
development of other local government compensation funding programs.
CAA proposes the following approach for engaging local governments and their service providers in the ORSOP:
1. Follow up outreach to all 2023 Needs Assessment respondents (details pending)
2. Engagement between CAA and local governments and service providers based on wastesheds (with additional
engagement as required for specific geographic areas). Consultation focuses on:
a. Understanding the unique conditions that may exist in each jurisdiction (i.e. local government
service provider franchise arrangements, nature of existing recycling services provided, etc.)
b. Consulting with local governments and service providers on the reimbursement process, review
criteria and administrative process that will be established to finalize and rollout service expansion
system funding
c. Confirm which permitted facilities and existing local government facilities would like to participate in
the PRO depot network
d. Coordinate needs assessment requests in the context of other local government compensation
programs such as transportation reimbursement (see relevant section below).
e. Identify primary contacts for each local government and service provider
f. Review anticipated processes for disbursement of education and outreach materials and the
provision of funding for contamination reduction activities
The ORSOP will enable the development of a schedule, prioritization, and cost estimates of local government service
expansion requests, as well as refined estimates of costs associated with reimbursements in other program areas.
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General Process and Timelines for Prioritizing and Processing Service Expansion
Requests
Proposed Timeline
Under the RMA, producers are not obligated to become members of a PRO until the program starts on July 1, 2025. Given
the anticipated cost of local government infrastructure service expansions, CAA will not be in a position to fund service
expansion requests until it is generating revenue from obligated producers.
Actual local government service expansion disbursements, therefore, are anticipated to begin after the July 1, 2025,
program start date, with CAA prioritizing funding requests in accordance with RMA rule priorities. The general steps and
timeframe associated with implementation of this service expansion funding program is below. (This timeline can also be
reviewed in Appendix M, Preliminary Program Implementation Timeline.)
CAA Conducts ORSOP (April – August 2024)
CAA Program Plan is updated based on the ORSOP (September 2024). Updates will include:
o A more detailed schedule for implementing collection program expansion disbursements
o Revised estimates of local government expansion disbursements
o A formalized Administrative Process for Review and Approval of Expansion Disbursements.
o Prioritization of expansion disbursement requests
o Development of a 2025-2027 Schedule for Processing Expansion Disbursement Requests
CAA Program Plan Approved (November/December 2024)
CAA-Local government processing of 2025 Expansion Funding Requests (begins Spring 2025)
o Detailed CAA – local government negotiations
o Identification of individual local government/service provider funding amounts
Disbursement of 2025 Expansion Funding Requests (July – December 2025)
CAA-Local government processing of 2026 Expansion Funding Requests (begins Fall 2025)
o Detailed CAA – local government negotiations
o Identification of individual local government/service provider funding amounts
Disbursement of 2026 Expansion Funding Requests (January – December 2026)
CAA-Local government processing of 2027 Expansion Funding Requests (begins Fall 2026)
Detailed CAA – local government negotiations
o Identification of individual local government/service provider funding amounts
Disbursement of 2027 Expansion Funding Requests (January – December 2027)
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Initial Outline for Disbursement of Local Government System Expansions
Preliminary Esmated Funding for Local Government System Expansion
2025
$54 Million to $70 Million
2026
$143 Million to $186 Million
2027
$159 Million to $207 Million
Total Program Plan Funding
$356 Million to $463 Million
Table 1
Actual funding amounts for local government service expansion initiatives will be determined on a case-by-case basis
subject to RMA eligibility requirements as per a schedule for disbursements included in future program plan amendments.
For more information related to how CAA developed initial estimates see Appendix E.
Revised Local Government Funding Schedule
Following the ORSOP, CAA’s revised program plan will include a more detailed schedule for processing the disbursement of
system expansion funding requests. Where appropriate, CAA will schedule the funding of local government system
expansion on a geographic basis so that infrastructure improvements can be coordinated and support broader system
efficiencies.
The proposed draft disbursement schedule to be included in the revised program plan could follow a format like the
following:
Local
Government
Type of Funding
Request
Reason for Priorizaon
Target Date for
Processing System
Funding Request
Target Date for
Funding
Disbursement
LG X
On-route Expansion
Required by OTR
September 2025
December 2025
LG Y
Depot
Populaon under 4,000
Oct 2025
Jan 2026
Table 2
CAA will consult with local governments to review optimal timing of funding disbursals to align with local government
budget policies.
Where prioritized local governments are not ready to process their funding requests in accordance with the proposed
Revised Program Plan funding schedule, CAA will work with those local governments to process service expansion requests
as soon as that local government is ready to engage in the processing exercise necessary to determine final disbursement
amounts.
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Assessing Priority of Funding Requests
All PRO funding for expansions and provision of recycling services from July 2025 through to December 2027 will be
prioritized following RMA rule guidelines:
1. Local governments that are not, or will not be, able to provide the opportunity to recycle
2. Existing recycling depots to provide for the collection of any materials that were formerly collected on-route by
the local government or a local government’s service provider, as needed to ensure continuation of recycling
opportunities
3. Existing recycling depots to provide for the collection of any materials that are not currently or were not
formerly collected on-route by the local government or local government’s service provider
4. Local governments with populations less than 4,000, according to the Portland State University Population
Research Center’s most recent Population Estimate Report, or such other estimate approved by the Department
5. Local governments of any size that are looking to add new on-route or recycling depot service
6. All other local governments that are looking to expand existing on-route collection, recycling depots or both, in
order of ascending population
Where local government requests fall into multiple RMA rule prioritization categories, CAA will attempt to identify and
sequence in accordance with the most applicable rule criteria. As noted earlier, CAA will also attempt to assess local
government requests on a geographic or wasteshed basis to improve system efficiencies. Additional criteria that CAA
proposes to employ for evaluation are described below.
Evaluation of Funding Requests
CAA will use a standardized information-gathering mechanism to gather needed specifics for assessing and meeting funding
requests and to be able to gauge the requests against these evaluation criteria. This information may include:
1. Name of the project
2. Detailed description of the project
3. Financial request with detailed list of items to be acquired
4. Timeline for the project and funds to be disbursed
5. Who will be overseeing and undertaking the project
6. What is the projected impact on the intent of the RMA
7. Is the project consistent with industry best practices/guidelines
8. Will the project meet the performance standards outlined in RMA rules
Proposed Review Criteria
While RMA rules provide guidance on how to prioritize local government eligible funding requests, there are several
references in the RMA related to potential service expansion requests where further clarifications will be required to
determine whether a particular local government service expansion request is eligible for funding under the statute.
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For example, service expansion requests related to expanded on-route collection services and the addition of recycling
reload facilities indicate that the recycling reload facility is an eligible expense if necessary. RMA rule requirements also
indicate that PRO funding for additional recycling depots is in relation to “as needed to provide convenient recycling
opportunities.” See OAR 340-090-0800(1)(A)(C). In the absence of additional review criteria, to address how RMA terms
such as “if necessary” or “as needed” should be interpreted, CAA is proposing program review criteria to clarify how needs
assessment funding requests will be assessed. Such criteria will also support other RMA requirements related to the
verification of funding amounts anticipated under the statute.
As part of the ORSOP, CAA will consult with local governments regarding funding eligibility protocols and the proposed
needs assessment review criteria outlined below:
1. Support for Existing Services and Infrastructure
Local governments and service providers have invested heavily in recycling infrastructure over decades to deliver recycling
services in conjunction with the delivery of other solid waste services that form the greater solid waste management
system. Where needed, improvements and additions will be considered, but existing infrastructure should remain the
foundation for services. Where consistent with other rule and funding assessment criteria, funding requests should support
and utilize existing recycling infrastructure.
2. Consistent with RMA Objectives
Funding requests must be qualified expenses under the statute, that are consistent with RMA objectives to minimize the
environmental impacts of producer packaging. Regarding local government infrastructure, requests should efficiently
support improved environmental outcomes related to both local government recycling and statewide packaging objectives.
3. Driving Efficiency and Effectiveness
Funding requests should improve current system efficiency and support cost-effective diversion. The funding should be
used both to improve the performance of existing recycling programs (e.g., increasing the recovery of materials that are
currently recycled) and add new materials in a cost-effective manner. Investments should create new capacity that meets
the newly anticipated volumes of recyclables under the RMA. Efficiency measurements (e.g., a “net cost per ton” diverted)
may be developed for considering applications for funding. It is recognized that any new tons added into the recycling
system will likely increase the total and net system costs.
4. Balancing Local Government and Statewide Needs
Local government funding requests should integrate well with statewide infrastructure. A balance is required between
funding to support State-wide system benefits and funding for local/regional funding needs and opportunities.
5. No Cross Subsidization or Duplication of Funding
There should be no cross subsidization between local government needs assessment funding and non-RMA solid waste
program funding. Funding provided by CAA for recycling programs will be dedicated to eligible recycling programs only.
Funding requests should also not duplicate funding provided through other RMA programs.
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6. Accuracy and Transparency
Funding requests must be based on accurate and transparent information. CAA will work in good faith with local
governments and their services providers to document required information associated with various types of system
expansion service requests. (i.e., required information in relation to a request for expanded on-route collection).
Dispute Settlement Process relating to Service Expansion Funding Requests
Given the language of the RMA, there may be disagreements between CAA and local governments and their service
providers about the eligibility for certain types of funding requests. These disagreements may be more complex than typical
contractual disputes (which often involve disputes over the interpretation of contractual clauses) as they will likely involve
different legal interpretations of what reimbursement the statute requires and what qualifies as an eligible cost.
CAA proposes to utilize the ORSOP to identify and catalog the types of costs associated with the expansion and provision of
recycling collection service for covered products. CAA would propose to convene a working group comprised of
representatives from CAA, local government, and DEQ to attempt to mediate disagreements over service funding requests
between the approval of the second program plan and the start of the program plan on July 1, 2025. This process will
hopefully minimize potential disagreements between CAA and local governments prior to the processing of individual local
government service expansion requests once the program begins on July 1, 2025. In addition to resolving or narrowing
potential dispute issues, the working group could also align on the details of the dispute settlement process to be utilized
once more detailed CAA local governments negotiations related to service expansion requests are undertaken.
Accountability Mechanisms
Funding provided to local governments will need to be accompanied by accountability mechanisms to ensure that PRO
funding provided to local governments is allocated to its intended RMA purpose. In many cases, this may include advance
funding for capital items such as trucks or other capital items. As part of the ORSOP, CAA will consult with local
governments regarding the accountability reporting and conditions associated with the provision of funding in relation to
service expansion requests and different types of eligible funding categories. The details of proposed accountability
processes will be provided in the revised second draft of the program plan, anticipated in September 2024.
ii. Transportation Reimbursements
Under the RMA, the PRO is required to fund local government or their service provider costs of transporting covered
products from a recycling depot or recycling reload facility to a CRPF, processor, or responsible end market (REM).
DEQ rules establish methods for determining funding and reimbursement amounts which may include payments based on
zones. The rules require that:
Costs must be based on the actual costs of managing and transporting covered products that must be shipped more
than 50 miles
50-mile distance is the shortest driving distance to:
o the nearest CRPF with capacity to process the material, if the material is commingled
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o the nearest processing or sorting facility that will prepare it for market or REM, if the material is collected
separately (e.g., glass) or is not fully commingled
o the nearest REM if the material is collected separately and in condition to be sent to an REM
Costs to receive, consolidate, load and transport covered products include but are not limited to purchasing and
maintaining equipment, signage (not already covered under RMA provisions), administrative costs including related
staffing costs
Transportation costs of covered products directly from a generator to a CRPF or REM are not eligible
In 2027, the PRO must also conduct a transportation study
The PRO program plan must include methods for calculating transportation costs
Payment methods may include rate schedules or zonal maps with periodic adjustments for fuel prices or other
variable factors
o Consultation with local governments and service providers required on payment methods
o Methods must include a voluntary option where PRO and local government/service provider may agree to
transfer some or all transportation responsibilities to PRO
Consultation Process
During the program plan development process, CAA consulted with a select number of local government service providers
on the design of the program for administering transportation disbursements under the RMA. These service providers are
all likely claimants for transportation reimbursement under the RMA and were selected in consultation with ORRA, which
represents haulers and other recycling businesses throughout the state.
The purpose of this pre-program plan consultation was to identify elements that need to be included in this funding
program and outline a general approach to administration. As with other RMA funding programs, CAA’s intention is to seek
feedback from affected parties throughout the state to support development of this RMA compensation program. Given
this requires outreach to the same parties involved in the ORSOP, CAA will coordinate consultation related to the
development of this funding program in tandem.
The proposed transportation reimbursement model, which CAA will seek feedback on in conjunction with the Oregon
Recycling System Optimization Project, is described below. Following further consultation and outreach CAA would finalize
transportation reimbursement policies and required forms and documents. These policy documents would be available
online, and CAA would propose to conduct webinars and stakeholder outreach prior to program plan implementation to
explain the claims submission process before the program start date.
CAA would begin processing claims from eligible funding recipients for any qualifying shipments made after the start of the
program on July 1, 2025.
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Proposed Methods for Calculating Transportation Costs
General Model
CAA will calculate disbursements based on standardized rates per mile from eligible outbound facilities to the nearest CRPF
with capacity or end market, with some adjustment for loading and preparation of outbound loads:
A standardized rate per ton per mile, with different rates for different types of loads, would be utilized to calculate the
transportation reimbursement compensation for different facilities
The standard per mile rate would be used to calculate set transportation reimbursements for each eligible outbound
facility based on the application of the standard rate to the distance between eligible facilities and the nearest
processing facility or end market
Reimbursement rates would include a process to address fluctuations in fuel prices
Local governments can assign transportation eligibility funding rights to service providers, and eligible transporters would
register with CAA and enter into a transportation claims agreement. Functioning through an online portal, eligible applicants
would confirm eligibility for reimbursement for individual shipments with CAA prior to the shipment taking place. CAA
would confirm their shipment request and notify the receiving CRPF of the delivery. Once received the CRPF will confirm the
load was accepted and input final weights. Once that is complete, reimbursement would be disbursed to the party initiating
the shipment request. The program would include a dispute settlement process with specified timelines for contested
claims.
Although funding requests from service providers for facility upgrades and capital costs associated with preparation of
materials (excluding costs covered under expansion of services funding to local governments) may coincide with requests
for transportation cost reimbursement, CAA recommends managing funding requests for capital items (e.g. depot signage,
compaction equipment, etc.) separately from transportation claims.
Registration of Claimants
A process must be established for local governments to identify the recycling depots, recycling facilities and haulers eligible
for transportation reimbursements in their jurisdictions. At the time of this submission, DEQ informed CAA that it was
consulting with local governments on an authorization or designation process for local governments to utilize with respect
to all RMA local government compensation programs.
Eligible recipients of transportation funding, which could include both local governments and service providers, would enter
into a transportation claims agreement with CAA prior to receiving transportation reimbursements:
This agreement would include terms of payments including indemnification clauses that clarify each party’s liabilities
and obligations with respect to transportation of RMA materials including situations where a funding recipient was
utilizing a third party to transport covered products
CAA intends to consult with service providers and local governments on the content of a draft transportation claims
agreement template
CAA will facilitate the registration process and completion of transportation reimbursement claims agreements in time to
enable implementation by July 1, 2025.
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Establishing Standard Rates
CAA will develop a draft recycling depot and recycling reload facility list for review by local governments and service
providers
A facility receiving rate of inbound shipments that need to be scaled, received, consolidated, stored, and reloaded and
all the associated administration and reporting would be paid a standard fee per ton managed
A transportation reimbursement rate for outbound shipments from each facility would be calculated based on a
standard per mile rate applied to the eligible distance and recorded weight received at the CRPF
Process for calculation of transportation rates for each facility would be reviewed including:
o The categories of shipments that would be subject to different standard transportation rates (i.e. material
type, destination)
Calculation of facility rates reflecting the shipping distance from each eligible facility to the nearest processing facility
with capacity or nearest end market based on the standard rate per mile
Proposed rates will be set on a per ton of eligible covered product basis
Payment process would include determining rates for mixed loads
Timing of Submissions and Reimbursements
CAA will develop an online portal to process submissions of claims. Claims processing will reflect the steps outlined below:
1. Eligible recipients would provide CAA notice of shipment through standard form via an online process
2. CAA would pre-approve eligible shipments (within specified time frames)
3. A Bill of Lading (BOL) would be released to relevant parties
4. Final weights of transported materials would be reconciled by CRPFs and other receiving facilities
5. Payment is released
As per RMA rule requirements, CAA would notify local governments of all payments made to authorized service providers
under this program.
Claims Submission Content
During the next phase of consultation, CAA proposes to review a draft claims submission template in consultation with local
governments and service providers. Operational information collected via claims submissions could include:
Confirmation of shipment eligibility (i.e. local government expense for transportation of covered products)
Location of recycling depot or recycling reload facility (origin)
Date of load pick up at recycling depot or recycling reload facility
Location of delivery location: CRPF, processor, or REM (destination)
Date of delivery to CRPF, processor, or REM
Confirmation of delivery by authorized CRPF, processor, or REM representative
Identification of covered product load type:
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o Comingled material, specific material, if appropriate
o Baled material vs. compaction vs. uncompacted material
o If applicable, percentage of load associated with eligible covered product
Outbound, inbound weights - confirmation of outbound and inbound weights from outbound and inbound facilities
Timing of Payments
CAA proposes that service providers confirm eligibility of shipments and submit claims on a delivery-by-delivery basis. CAA
would consult on proposed timelines for payment of claims and the processes for verifying, approving and adjusting claims.
CAA would also consult on proposed deadlines for the submission of transportation claims and adjustments to
transportation claims.
Dispute Settlement Process
As noted above, CAA is proposing a pre-submission claims review process to minimize disputes about whether a particular
claim for funding is eligible. In cases where a submitted transportation claim is not considered eligible by CAA, that
transportation request will not be approved, and the BOL generation process will not be initiated. If a load is approved for
transportation and is rejected upon receipt at the CRPF due to contamination, the transporter shall incur the cost of the
transport, removal, and disposal of the material and that load will not be eligible for transportation reimbursement.
CAA will develop a dispute settlement process for claims where a service provider and CAA disagree on eligibility for a
claimed cost or the amount of the transportation cost reimbursement. Details would be included in a Service Provider/CAA
transportation agreement, with the potential for arbitration by a third party agreed to by both parties. Affected local
governments will be notified when a dispute settlement process has been initiated.
Percentage of covered product in commingled loads
Under RMA rules – initially PROs will use data from the 2023 Oregon Solid Waste Characterization and Composition
Study to determine the portion of recyclable material that is not covered product in commingled loads
CAA will propose a standard percentage for use in all rate sheet calculations
If a local government, service provider, or PRO in a particular county believes that the local commingled stream has a
significantly different proportion of covered product (in comparison to the statewide average), it can conduct a study
in consultation with the affected parties to determine the proportion of covered product in the local commingled
stream
In 2027 the PRO is obligated to conduct a study to determine the proportion of covered material in commingled loads:
o CAA will consult with stakeholders on the appropriate methodology associated to be used in this study and
the revised program plan will include an outline of the proposed approach and timing of initiative
Voluntary Transportation Option
As per RMA rules, CAA would develop an option where CAA would assume responsibility for transporting covered product
materials from a local government’s recycling depot or recycling reload facilities to the nearest facility if the local
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government and CAA agree to such an approach. This would be implemented through a CAA/local government agreement
which would describe service details. CAA will consult with service providers on the details of the transportation funding
program to determine their level of interest in the voluntary interest option.
Opportunities for Efficiency and Effectiveness
Wasteshed-Level Management
The management of materials at the wasteshed level offers a number of advantages from an administrative, planning,
operational, and financial perspective. It is important to manage all the materials at the wasteshed level. The materials can
be planned, administered, received, consolidated, prepared for shipment, and loaded in each wasteshed. In some cases,
neighboring wastesheds may find it beneficial to work together to benefit from economies of scale and avoid unnecessary
duplication of services. CAA will explore options to coordinate transportation of materials on a wasteshed basis during
consultation on the details of the transportation funding program.
Material Compaction
The movement of materials must be minimized where possible. One of the most effective ways to minimize the movement
of materials is by maximizing load capacities thus reducing the overall number of loads needed, however, this must not be
done at the risk of compromising the recyclability and recovery of the materials by CRPFs.
While baling is an effective way to maximize capacity, it has negative impacts on the recovery yield of the materials.
Shipping loose materials is the least effective way of shipping materials resulting in the most loads to be managed. The
most effective way is to compact the material into closed top walking floor trailers, maximizing the volume capacity without
affecting the integrity of the material to be sorted. This will lower freight costs and increase recovery at the CRPF while
reducing residue rates.
CAA will consult with local governments and their service providers regarding efficient transportation options. The rate
sheet will likely, pending the results of consultation, distinguish between different types of loads to encourage
transportation efficiencies.
iii. Additional Reimbursement and Funding for Local Governments
Contamination Reduction Programming
The RMA requires DEQ to establish and maintain list of approved contamination reduction program elements, including:
Customer-facing materials, methods responsive to diverse populations
Standards for providing feedback to generators that contribute to contamination
Standards for service or financial consequences to generators that are repeated sources of contamination
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Local governments must implement programs to reduce contamination that include program elements identified by DEQ,
or materials or methods that are as effective, and must include a process to review and revise as local elements once every
five years. Local governments are only obligated to participate to the extent program funding is provided by a PRO. PRO
contamination reduction funding is capped at $3 per capita per year.
RMA rules related to contamination reduction funding will be finalized as part of the RMA’s Phase II rulemaking process
with a review and approval by the Environmental Quality Commission anticipated in November 2024.
CAA has conducted some preliminary outreach with local governments related to this program, but as in other program
areas, further consultation is required to develop the details of how this program will be administered.
As with other reimbursement programs, local governments may designate service providers as eligible recipients for
program funding. Local governments may also assign other local governments as funding recipients (i.e. a city may choose
to designate a county as the funding recipient).
Given that PRO program funding is capped at $3 per capita, the assignment or designation process related to this program
requires local governments to assign or designate portions of funding in situations where it may be assigning funding to
multiple service providers. The per capita cap also requires the determination of funding years for which to calculate the
cap, and the population period on which the per capita cap was calculated so that in any given funding year, local
governments are working from the same population estimates.
CAA proposes the following general approach to disbursing funding for contamination reduction programming:
The funding year for disbursements would be based on the municipal calendar year (e.g. July 1, 2025 to June 30, 2026)
Prior to the start of each funding year CAA would calculate the eligible cap for Oregon local governments for the
upcoming year based on the most recent estimate of Oregon population available from the Portland State University
Population Research Center as per RMA rules 340-090-0810 (2) (timing to be determined) and provide to local
governments and DEQ (potentially post on its website)
Prior to the start of each funding year, local governments would through the Opportunity to Recycle (OTR) process
assign funding eligibility identifying the portion of funding available to recipients in cases where the local government
was assigning eligibility to multiple recipients
CAA would encourage local governments and eligible service providers to submit contamination reduction funding
budgets, identifying what the CRF will be utilized for, to CAA for pre-approval prior to the start of each program year –
this process would expedite the processing of payments later in the year
Where recipients want advance funding for contamination reduction programs, they would submit a budget for
eligible items to CAA prior to the start of the program year (timing to be determined)
Recipients that are provided advanced funding in relation to the contamination program would need to monitor
spending and provide CAA with updates confirming advance funds were utilized for eligible contamination reduction
program elements (timing to be determined)
In the event that recipients of advance funding related to the contamination reduction program had not spent the
advance funding by the end of the funding year, they would be required to return unspent advance funding amounts
to CAA (timing to be determined)
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Ensuring 10% Post-Consumer Content in Roll Carts
Many manufacturers of roll carts currently offer 10% or more post-consumer content in new containers. To get the post-
consumer material needed, manufacturers need access to residentially sourced resin and there has been concern in the
past about an adequate supply of this material. Some manufacturers may indicate that, depending on the size of the
container and the weight of the resin used the purchaser, there may be the need for a small premium for a 10% cart during
procurement. However, some cart manufacturers are already able to provide 10% post-consumer content at the same
price and same warranty terms as 100 percent virgin resin carts.
CAA proposes to work closely with local governments and haulers to facilitate procurement that ensures the 10% standard
is met and that the content is derived from residential post-consumer sources.
Measures to Protect Ratepayers from Increased Costs
Under the RMA, producers will provide funding for several activities that are currently financed indirectly through
ratepayer recycling fees. In addition, producers will fund activities designed to implement recycling system improvements.
While the level of many of these investments have yet to be finalized, the investments are anticipated to be significant and
will indirectly protect existing ratepayers from fee increases as local governments and system participants will no longer be
required to recover such costs exclusively through rate payers.
Producer funding directed toward existing activities that should provide ratepayer protection include:
Annual compensation to CRPFs to cover current operating and contaminant disposal costs as well as future system
improvement costs
Annual local government contamination reduction program funding
Funding for local government transportation of covered products for more than 50 miles
New sources of producer funding directed toward recycling system improvements that should provide rate payer protection
include:
Producer funding for expansion of local government collection services
Close to 50% of CRPF compensation relates to recycling system improvements associated with RMA obligations
Producer funding for the collection of PRO acceptance list materials including potential funding in support of
continued curbside collection of select materials
Producer funding for the provision of local government education and outreach materials
Producer funding to ensure collected materials are recycled at responsible end markets
Producer funding for waste prevention and reuse projects designed to lower the environmental impact of covered
products
With respect to the processing costs of collected materials and the requirement under 459A.923 (2) which requires PROs to
share in processing costs to allow local governments to reduce the financial impact on ratepayers, CAA supports data
reporting processes that would allow it to provide local governments with an annual estimate of PRO funding provided to
processing facilities in relation to the volume of commingled materials collected in their jurisdiction. This would allow
individual local governments to take PRO funding into account when setting ratepayer fees and processes for their local
service providers. CAA can track certain commingled volumes through the provision of transportation subsidies, but will
likely require additional reporting by CRPFs to ensure that this information is accurate on a local government basis. CAA will
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work with DEQ to review various data reporting requirements under the RMA with the goal of providing this type of
information to local governments.
CAA also supports the monitoring of developments at CRPFs over the course of the program plan in relation to the
anticipated investments and costs identified through the study by Crowe on the Oregon Processor Commodity Risk Fee and
Contamination Management Fee.
1
This is necessary to review whether anticipated investments were made and to review
whether processing facility anticipated cost estimates were accurate. Such information will help refine forecasting estimates
associated with anticipated future studies related to the calculation of CRPF processing fees. CAA believes that DEQ is best
positioned to gather this information as a requirement of CRPF permitting reporting.
Finally, CAA has an obligation under 469A.875 to describe how it will provide funding to allow local governments to protect
ratepayers from the increased costs associated with processing and marketing recyclable materials. As noted above, CAA
will be making significant investments to support recycling throughout the state and indirectly protect ratepayers. CAA will
provide local governments with an annual summary of RMA funding in relation to materials collected in their jurisdiction so
that these amounts can be reviewed by local governments when conducting ratepayer reviews in relation to recycling
services.
iv. Start-Up Approach for Time-Sensitive Tasks
Given the program start date of July 1, 2025, there are time-sensitive tasks that need to be completed during 2024 and
early 2025.
The expected start-up tasks include:
1. Negotiating with and then providing associated compensation (with a single accounting point-of-contact
system) to local governments for service expansion
2. Setting up a single accounting point-of-contact system for compensation of local governments for expenses not
related to service expansion (i.e. transportation funding, contamination funding, roll cart funding, etc.)
3. Setting up a single accounting point-of-contact system for payment of contamination management fees and
processor commodity risk fees to CRPFs.
In relation to the stated start-up tasks, CAA will begin outreach to and preliminary negotiations with all respondents to the
initial needs assessment to further develop understanding of service expansion funding needs. Details of this proposed
outreach, including ways to gather information that uses stakeholder time efficiently (by addressing multiple related topic
areas for example), are included under the “Proposal for an Oregon Recycling System Optimization Project" section above.
By June 30, 2025, the development, buildout, and implementation of a local government-facing portal will be completed.
The portal solution will provide an easy to use yet secure platform for producers, service providers, and state/local
stakeholders to interact with CAA. All data within the portal will be encrypted to safeguard against external threats and
ensure the confidentiality of data.
1
Crowe. Study Results: Processor Commodity Risk Fee / Contamination Management Fee. Retrieved March 8, 2024 from
https://www.oregon.gov/deq/recycling/Documents/TWGTask4-5Report.pdf.
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For local governments and service providers, the portal will allow access through a secure user ID and password. Once in
the portal, service providers will be able to view their claims, account history and balance due, and reports and
notices. Additionally, the portal will provide multiple means for service providers to send their claims data to CAA through
data exchange, structured file upload, or direct entry. As described above, details for administering each of the individual
reimbursement programs will be discussed with local governments during the next phase of outreach. This process will
inform further specific portal requirements.
In parallel to local government and service provider outreach, CAA will continue its discussions and engagement with
Oregon’s eligible CRPFs to better understand their needs and align on administrative processes for the payment of
contamination management fees (CMF) and processor commodity risk fees (PCRF). Payment of these fees will also be
facilitated through CAA’s secure portal system.
Leveraging functionality that will support the overall achievement of Objective 1, including ensuring that materials are
collected and processed for recycling in Oregon are consistently delivered to responsible end markets, CAA will provide full
material flow traceability through a system that manages and reconciles inventory flow from initial possession, through
validation of receipt by responsible end markets. This same functionality will support the track and trace needs under the
transportation reimbursement process.
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b. The PRO Recycling Acceptance List
This section outlines activities, timelines, and recommendations for increasing diversion of materials named on the PRO
Acceptance List from disposal, including proposed approaches to meeting convenience and performance standards and
setting collection targets.
As noted below, CAA has completed a GIS mapping exercise to assess existing depots and alternate collection sites in
relation to the RMA rule requirements. In general, where there are service gaps in relation to RMA convenience standards,
local governments are currently collecting some PRO materials through curbside collection. These local governments have
indicated to CAA that they would like curbside collection of certain PRO materials to continue under the RMA and CAA has
indicated its interest in working with local governments to support this added level of convenience.
As the exact number of physical collection points that CAA will propose is dependent on the outcome of local government
discussions in relation alternate collection activities in key local government jurisdictions, CAA has not aligned on a
proposed number of physical collection sites for PRO acceptance list materials at the start of the Program. The numbers
provided below are initial estimates, which combine physical locations with alternate activities.
As CAA conducts further outreach in relation to assessing local government service expansion requests, it will also work with
local governments to confirm potential participation in the collection system for PRO acceptance list materials. These
discussions will enable the development of a more detailed plan for the collection system which in turn will layout a detailed
proposal for CAA’s compliance with convenience standards as part of the anticipated second program plan required in
September.
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i. Proposed Approach to Achieving Convenience Standards
Requirements
Through the rulemaking process, DEQ has defined the convenience standards for depots to ensure Oregonians have
reasonable and equal access to recycle materials that the PRO is responsible for collecting and managing. ORS 340-090-
0640 outlines minimum sites for counties, cities and the Metro region.
Figure 1. An infographic summarizing the requirements of recycling access laid out in the RMA
The PRO will be required to have a minimum of:
One depot in every county
One additional collection point in counties with over 40,000 residents
Additional depot locations for counties in the Metro region (Clackamas, Multnomah, and Washington Counties)
A depot in cities of 7,000 or more for cities outside the metro region
A depot for every city of 14,000 within the Metro region
Additional collection points based on population and location of the city
The achievement of this distribution is demonstrated in Appendix F.
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In addition to minimum regional requirements for depots, there are additional considerations that CAA is factoring in when
considering optimal locations for siting depots, including:
Incorporated versus unincorporated parts of counties
Proximity to public transit in the multi-depot cities
A goal that 95% of Oregonians live within 15 miles of a depot
Further, enhanced convenience standards exist for PE film, plastic buckets and pails, glass bottles and jars, PE and PP lids
and caps, and HDPE package handles.
Block EPS, pressurized cylinders, aerosol packaging, aluminum foil and shredded paper are not included in the materials
that must be collected at locations that meet the enhanced convenience standards. However, CAA, when possible,
proposes to attempt to have most existing permitted sites, collection events and on-route (in specific urban areas) collect
most, if not all PRO materials (collected separately from Universal Statewide Collection List materials), meeting the
enhanced convenience standards for all materials while minimizing costs to the system and increasing convenience for the
user. All depot locations shown in this section on the maps (Figures 2 and 3) and in Appendix F are being considered as
enhanced locations accepting all PRO materials.
CAA will also consider alternative depot locations, where necessary for certain product categories, such as PE films, aerosols
and pressurized cylinders. The use of on-route collection in certain metropolitan areas, at no additional cost to residents, is
also being explored as a means to help meet convenience standards.
Further discussion of suggestions around the proper management of pressurized cylinders and block EPS can be found in
the relevant sections below.
Network Analysis and Mapping
Given all the requirements to meet convenience standards, CAA estimates it will need to establish between 138 and 189
points of collection for materials on the PRO acceptance list. Points of collection refer to physical depots and events. The
number also includes 38 identified areas where on-route collection may, in part, replace the need for a physical depot.
CAA contracted with IncaTech, a consultant group specializing in geospatial analysis, to utilize a GIS mapping tool to predict
where coverage might be possible through existing depots and permitted facilities. Lists of prospective depots sites were
prioritized and input separately as layers of information to produce different network coverage scenarios.
The RMA requires the PRO to prioritize outreach to permitted DEQ facilities and existing depots. CAA will issue letters to all
permitted and existing sites inviting them to participate in the PRO depot network. This will occur in the first stages of the
ORSOP and be followed by a series of outreach activities to prepare local governments and service providers for the ORSOP.
Through this outreach, permitted DEQ facilities and existing local government depots will receive no less than two specific
and direct requests to consider joining the PRO depot network. Access to webinars, information offered on the CAA
website, and other anticipated electronic communications will further increase awareness opportunities for these sites as
required in ORS 459A.896(1)(a).
A map of existing depots and permitted facilities was layered over the county and city convenience standard requirements
to determine where gaps in convenience standards would exist if all existing locations joined the network as ‘enhanced’
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locations. Given the location requirements, many gaps were discovered in the state where alternative locations or methods
of collection are needed.
To fill some of the gaps, CAA researched likely participating partner locations of existing refuse-related industry locations
and community-based organization (CBO)/current Ecycles locations. CAA also noted and layered many of the existing
permitted locations, as well as potential future partner locations that could serve as backup in cities where convenience
standards would not be met if some of the central existing permitted locations chose not to participate.
173 existing permitted depot sites were identified with additional plausible existing locations (hauler yards, CBOs, etc.).
These 173 locations cover much of the state, meeting the state convenience standards of reaching more than 95% of
residents within a 15-mile range and having at least one site per county. However, CAA may not be able to initially meet the
city convenience standards, leaving gaps in some of the cities. Strategies to close gaps in convenience standards are
explained below.
Closing Gaps to Meet Convenience Standards
The initial phase of depot implementation is estimated to begin in 2025 by expanding collection of PRO material to the
participating existing depot and permitted site locations.
Many existing hauler sites and permitted locations have expressed interest in participating as a PRO material collection
point, however confirmation of participation is not yet confirmed. CAA has also identified over 285 backup sites that could
be substituted if any existing facilities ultimately chose to not participate as a PRO collection point.
CAA also proposes to conduct outreach to retailers to explore existing or expanded collection opportunities for certain
product categories, such as PE films, block white EPS, and pressurized single-use containers.
In metropolitan areas where on-route glass collection services currently exist, CAA will explore the potential of adding
certain PRO materials to on-route collection services. CAA has sent out a questionnaire to Metro Regional governments to
explore the economic feasibility and practicality of curbside collection. In the event that CAA and the local governments
agree this is the best way to meet convenience standards for PRO materials, CAA proposes the number of depots required
be adjusted in those enhanced service areas. CAA recommends offering direct service for the collection of PRO materials as
it would help increase participation for all residents, increasing recovery rates and broadening access for residents.
CAA will explore the potential of enhanced curbside collection of PRO materials for both single-family and multifamily
residents. To further address underserved communities and neighborhoods, CAA will consider hosting collection events in
those identified areas.
As the depot network is built, there may be instances where barriers exist in establishing depots, such as a lack of available
commercially zoned properties, or locations that do not immediately meet performance or geographic convenience
standards. Where there are gaps and barriers that prevent ready identification of a suitable depot location, the CAA team
will consider all practicable measures to work with prospective partners to develop a suitable site. Until a site can be
developed, collection events may be necessary to meet convenience standards (more details on events below).
In these locations, CAA will explore one of three main options to fill the gap:
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1. Adding PRO materials to a curbside container service, separate from USCL collections, and available at no cost to
single family and multifamily properties to meet and exceed the convenience standards. Property density,
service provider availability, and economic viability will guide this option
2. Partner with a CBO or independently host collection events regularly in areas lacking a permanent depot
location
a. An emphasis on events in underserved areas of the cities will be prioritized. This option will be
better suited where sites and infrastructure are limited and/or there is a lack of economies of scale
for the alternative options
b. Option 2 and 3 will be combined in areas where single family convenience standards are met by on-
route collection by adding targeted events to multifamily apartment complexes multiple times a
year
3. Constructing a new facility to act as a depot location for PRO items in the community. Site availability and
economic viability will likely be the main drivers of this option
Running Collection Events
For events, CAA proposes to work with the municipality to prepare events that will best serve the population. CAA will work
with cities and counties to find the most suitable sites for collection events and determine the best time and frequency of
hosting events. CAA will work with jurisdictions to promote the collection events and collect data on utilization. The events
will either be staffed by the local municipality and reimbursed by CAA, or by a partner CBO or local COBID certified
contractor with experience in waste management. Design for these events will be based on the models of existing Metro
area collection events such as Metro Hazardous Waste Rounds Ups, City of Gresham Earth Day Events, Lane County’s
Plastics Round Ups or James Recycling’s recycling collection events and they may be combined to increase participation.
CAA team members and partners have experience conducting similar events in other parts of the U.S. and Canada. The type
of event will depend on the community’s needs and what other disposal options currently exist. Events will be conducted in
accordance with the same performance standards as depot locations (outlined in the Performance Standards section),
offering free collection services and collecting covered materials in a way that preserves the quality of the material and
prevents risk of litter or loss of materials.
Requesting Variances
Onboarding the backup locations, siting and construction of new locations and event implementation for filling convenience
standard gaps will begin in 2025 and CAA expects its proposed collection system to be completed by the end of the
program plan. CAA intends to meet convenience standards in all service locations via one of the three options identified
above for targeted communities.
In the event a suitable location cannot be identified for a permanent collection location or collection event, but a suitable
location is established within a reasonable distance, CAA will request a proximity exemption variance. CAA proposes a
reasonable distance would be 15 miles from the established depot serving as the basis of the proximity exemption to the
jurisdiction where the PRO depot location/collection service is lacking.
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If there are extenuating circumstances beyond the PRO’s control, including natural disasters such a wildfires and floods, or
other situations that could affect service to a community for a prolonged period, CAA will seek a temporary variance on
operations of that depot.
Figure 2. Proposed sites to meet performance standards and most convenience standards.
Using the existing collection sites of permitted facilities and local government depots, CAA has identified 142 suitable
existing sites that, combined with special events and/or enhanced curbside service, will serve 96.9% of the population
within a 15-mile buffer, based on 2020 census data.
Number of Exisng
Collecon Points
Total
Populaon
Populaon within
15 Miles
% Beyond 15
Miles
% of Populaon
within 15 Miles
State of Oregon
173
4,237,256
4,105,681
131,575
96.9%
Table 3
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Figure 3. Identified backup sites where proposed sites do not wish to participate.
Due to the magnitude of the task and the need for the ORSOP, outreach to all sites has not yet been completed. CAA will
prioritize detailed outreach to inform the planning processes. However, based on preliminary discussions with local
governments and their service providers, CAA believes many of these sites will host depot collections for at least some PRO
materials.
As mentioned above, CAA recognizes not all permitted sites and local government depots will elect to accept PRO depot
materials. The requirement for a higher concentration of depots in metropolitan areas will also require additional locations
beyond the existing sites. Anticipating this need, CAA has consulted with several organizations to explore the feasibility of
utilizing their services to fulfill the remainder of the convenience standards requirements. Those organizations include:
St. Vincent de Paul
Bring Recycling
Oregon Beverage Recycling Cooperative
Habitat ReStores in the Portland Area
James Recycling in the Metro Area
City of Roses Disposal and Recycling
Trash for Peace
The Arc of Portland
All of these organizations, which are either non-profit or minority owned/operated, have expressed interest in continuing
to explore the opportunity to be part of the PRO depot network.
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Once the program is underway, to ensure compliance with convenience standards for transit access, CAA proposes to use
the GIS mapping tool to overlay public transit routes to ensure the additional depot locations meet the proximity
requirements for access to public transit.
Underserved Populations
The CAA team has also considered mechanisms for collecting PRO materials from residents that might not be able to access
depot points. CAA will explore the possibility of providing valet services through haulers currently servicing the area, many
of which offer a form of subscription collection service, such as Recycle+, in metropolitan areas. The contracted hauler’s
ability to offer valet services across the state will be explored as part of the proposed ORSOP.
CAA proposes to develop eligibility criteria for these valet services. Some of those criteria could include that a resident is a
recipient of Meals on Wheels, receiving home care services, and/or set-out/set-back assistance. CAA proposes to consult
with organizations representing aging and disabled populations to develop the appropriate criteria for eligibility and means
to educate these populations about collection services available to them.
Just as CAA has been exploring working with a on route collection model for areas lacking sufficient depots, these collection
methods are also being explored for collecting PRO and USCL materials for handicapped individuals via the same method. In
the Portland area for example, CAA is exploring contracting with Trash for Peace to use electric vehicles (cars/vans/bikes) to
serve mobility-limited populations within the city in addition to exploring similar services that may be offered by haulers.
ii. Proposed Approach to Addressing Performance Standards
Once the depot network is developed, it will be CAA’s responsibility to ensure that each site is operating in conformance
with the performance standards defined in the rules. Oversight includes ensuring:
Sites and services consistently conform to operating standards
Depots are free to the public
Sites are well promoted to maximize awareness and participation
Infrastructure around the site promotes ease of accessibility
Quality of recyclable materials is maintained
Depot sites have a positive impact on the communities and environment within which they operate
CAA proposes to build multiple check points into the process of establishing and maintaining the network in a way that
meets all these performance standards.
Criteria for Site Selection
CAA is responsible for reaching out to permitted facilities and existing locations to assess their interest in participating as a
PRO depot and their suitability as a site. If a permitted facility or existing depot location is found not to conform to the
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performance standards, CAA will reconsider the eligibility of that depot to serve as a drop off facility within 12 months of
that depot correcting any non-conformance to the performance standards.
CAA will also ensure hours of operation conform to the rules. If a depot is located at a “parent facility”, such as a permitted
facility, access to the PRO recycling area will be open those same hours. For all other collection points, or “stand alone”
sites, CAA will ensure they are open for at least 4 days a week, 8 hours a day and that one of those operating hours falls on
a Saturday or Sunday.
All sites must meet accessibility standards, having ADA compliant recycling areas in prominent places or marked so
residents can easily access recycling opportunities. The sites need to also be accessible from a transportation perspective,
ensuring roads and public spaces are suitable for residents to reach sites safely and for logistics partners to service. For
collection opportunities that may be co-located with retail or other commercial activities, clear signage on how to access
the recycling system will be made available at entrance points.
Sites will be fenced or have some other enclosure that acts as a litter mitigation measure. All collection areas shall be
covered by a roof or have lidded bins that protect the material's quality and prevent water from collecting in covered
product collection areas.
Establishment of Depot Sites and Contracts
As depot locations are brought on board, CAA will assess sites for additional equipment and infrastructure needed to meet
the performance standards. Additional staff time necessary to fulfill the operational obligations of the PRO depot network
will also be assessed and worked into the payment schedule. Each site will enter into a services contract with CAA, which
will outline performance expectations as terms of the contract.
CAA will also document that all operational expectations are in place before a depot location is added to the network. CAA
will create a site audit record for each site, demonstrating that each depot location can meet the performance standards at
the outset of operating in the program.
Depot staff will undergo initial onboarding training with their CAA point of contact. Staff will receive training in all
operational procedures, become familiarized with the system for pick-up requests, and learn where to find resources to
promote their services. CAA will provide a depot management handbook outlining the above information to all depot sites.
CAA will work with collection sites to determine the best compensation method. Collection volumes may be low for some
sites, in which case factoring a per pound reimbursement might not be practical. To adequately accommodate for the fixed
space and labor costs, CAA may need to compensate collection sites based on a flat, per month service fee. Terms of
compensation will be part of the depot negotiation process.
A provision of the contract will state that any incidents that could substantially impact services offered or require
emergency response be reported to the PRO within 24 hours. That will allow the PRO 24 hours from the time of notification
by the collection depot to convey incidents to DEQ within the two business days defined by rule.
Operational Support
Once a depot is operating in the program, CAA will provide resources to support their operations. CAA anticipates offering
the following resources:
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newsletter for depots to keep them informed of the progress of the program, feature information on best practices,
and remind them how to contact the team for assistance
Offer webinars to ensure operators are familiar with operational procedures
Develop a media kit that will help depot sites promote the PRO collection opportunities alongside their other services
Have access to digital resources like the PRO depot management handbook and digital files for signage
To ensure residents across Oregon have an equal opportunity to recycle, CAA will make education and promotional
materials available in multiple languages. Different language options offered for depot education will mirror the language
options used in each jurisdiction for broader program education elements.
Annual Audits
CAA will develop an audit cycle that will include a mix of on-site and desktop audits performed each year for every site. On-
site audit inspection will be conducted to ensure operations are running smoothly and in accordance with the terms of the
contract. Desktop audits and on-site audits will assess the same criteria. When a desk audit is performed rather than an on-
site audit, documentation via photos, promotional efforts and compliance documentation will be requested. All the same
documentation will be gathered by CAA staff when conducting an on-site audit.
Audit Criteria
The audit criteria will include, but not necessarily be limited to:
Adequate signage advertising the program, program hours, who residents can contact if there is a complaint about
the site and noting that the program is free
Record of program promotion throughout the year
Certificates of insurance
Demonstration that staff are knowledgeable about the PRO program, PRO depot training is provided to all new
employees, and employees have access to the PRO depot management handbook
A mechanism for logging site complaints directly and documentation that complaints were forwarded to CAA
Contamination Management
CAA will require, when feasible, an on-site staff member to be present to assist the public with drop-offs of PRO materials.
This staff member will ensure cleaner material streams and will be an educator to the public about the PRO depot system
and what it can collect. Where repeated contamination or illegal dumping issues arise at a site, CAA may use monitoring
technology to address issues. Signage will be prominently placed to offer instructions on management of materials that are
not accepted in the collection system and would therefore contribute to contamination.
If a load of material is determined to be too contaminated for an end market, the PRO will explore options to remedy the
contamination situation through initial sorting. If that is not possible, the PRO will choose to landfill the material and notify
DEQ within three business days of disposal. The notification will include a description of:
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The nature of contamination
The cause of contamination
The remedy explored to improve the quality of the contaminated load
The remedy that will be put in place to prevent future contamination
Specific Material Handling Requirements
Block White EPS Foam Management
There are three regions in the state that have established foam densifying operations or are themselves a recycling market
for block white EPS foam. Outside of these areas, CAA will work with specific PRO depot locations or partners to house non-
thermal foam densifiers for consolidating the foam in the surrounding communities. CAA is exploring placing densifiers and
exploring mobile densification near Grants Pass, Klamath Falls, Burns, Redmond, Ontario, The Dalles and Pendelton. These
sites will prevent the movement of loose polystyrene for more than 75 miles. Where these sites do not meet the
requirements, third-party sites will be contracted and/or mobile units will be dispatched. Additional contracting with these
locations for staff and proper compensation will be negotiated with those sites.
Pressurized Containers and Aerosols
CAA recognizes that all aerosols and single-use pressurized cylinders will be managed through a household hazardous waste
(HHW) system according to OAR 340-090-0650(2)(b). The DEQ permitted facilities that CAA will be reaching out to as
priority PRO depot locations meet the criteria of being staffed, and some have permanent HHW collection sites.
In addition to working with the permitted DEQ facilities that offer HHW collections, CAA is reaching out to contractors that
host events for many of the counties across Oregon to explore how CAA can support the collection of aerosol containers
and pressurized cylinders through those programs.
CAA has been in contact with PaintCare to explore the potential of partnering on promotion and coordination of HHW
collection points and events where both programs are supporting the cost of managing covered products. Where there is an
opportunity to partner on specific PaintCare collection events, CAA will consider co-sponsorship of those events. Once
collected, both aerosol and pressurized cylinders would be managed by licensed HHW material handlers. CAA proposes
reporting recovery of those products in empty containers weight, if it is possible for third party vendors managing the
evacuation of the packaging to provide that data. If that is not possible, CAA will need to develop a calculation for a proxy
weight that would be used for reporting.
CAA will not accept aerosol cans or pressurized cylinders from any non-residential generator unless that non-residential
generator affirms in writing its status as a very small quantity generator pursuant to 40 CFR 260.10 and 40 CFR part 262.
The table below shows the counties currently supported with either a permanent HHW collection point, collection events or
a combination of both. Aerosol containers and pressurized cylinders are items commonly managed through these existing
programs, and CAA will seek to finance the collection and management of those products in partnership with those
jurisdictions. CAA estimates that 94.6% of the Oregon population currently has access to some form of HHW collection
through their county.
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The table below also identifies the counties that are lacking any HHW access for residents. CAA will prioritize hosting
additional collection events for aerosols and pressurized cylinders in those jurisdictions.
ID
County
2022
Populaon
Wasteshed
HHW
Sites
HHW
Events
HHW Sites
HHW
Events
No
Coverage
801
Baker
16,860
Baker
Yes
-
16,860
0
0
802
Benton
93,976
Benton
-
Yes
0
93,976
0
803
Clackamas
425,316
Part of Metro
Yes
Yes
425,316
425,316
0
804
Clatsop
41,428
Clatsop
-
Yes
0
41,428
0
805
Columbia
53,014
Columbia
-
Yes
0
53,014
0
806
Coos
65,154
Coos
-
Yes
0
65,154
0
807
Crook
25,482
Crook
-
Yes
0
25,482
0
808
Curry
23,662
Curry
-
Yes
0
23,662
0
809
Deschutes
203,390
Deschutes
Yes
-
203,390
0
0
810
Douglas
111,694
Douglas
Yes
-
111,694
0
0
811
Gilliam
2,039
Gilliam
-
Yes
0
2,039
0
812
Grant
7,226
Grant
Nothing
Nothing
0
0
7,226
813
Harney
7,537
Harney
Nothing
Nothing
0
0
7,537
814
Hood River
23,888
Hood River
-
Yes
0
23,888
0
815
Jackson
223,827
Jackson
-
Yes
0
223,827
0
816
Jeerson
24,889
Jeerson
Nothing
Nothing
0
0
24,889
817
Josephine
88,728
Josephine
-
Yes
0
88,728
0
818
Klamath
69,822
Klamath
Nothing
Nothing
0
0
69,822
819
Lake
8,177
Lake
Nothing
Nothing
0
0
8,177
820
Lane
382,647
Lane
Yes
-
382,647
0
0
821
Lincoln
50,903
Lincoln
-
Yes
0
50,903
0
822
Linn
130,440
Linn
-
Yes
0
130,440
0
823
Malheur
31,995
Malheur
Nothing
Nothing
0
0
31,995
824
Marion
347,182
Marion
Yes
-
347,182
0
0
825
Morrow
12,635
Morrow
Yes
-
12,635
0
0
826
Multnomah
820,672
Metro
Yes
Yes
820,672
820,672
0
827
Polk
88,916
Polk
Yes
-
88,916
0
0
828
Sherman
1,908
Sherman
-
Yes
0
1,908
0
829
Tillamook
27,628
Tillamook
Yes
-
27,628
0
0
830
Umalla
80,523
Umalla
Nothing
Nothing
0
0
80,523
831
Union
26,295
Union
-
Yes
0
26,295
0
832
Wallowa
7,433
Wallowa
Yes
-
7,433
0
0
833
Wasco
26,581
Wasco
-
Yes
0
26,581
0
834
Washington
605,036
Part of Metro
Yes
Yes
605,036
605,036
0
835
Wheeler
1,456
Wheeler
Nothing
Nothing
0
0
1,456
836
Yamhill
108,261
Yamhill
-
Yes
0
108,261
0
Total
4,266,620
3,049,409
2,836,610
231,625
71.5%
66.5%
5.4%
Table 4
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Compensation
CAA proposes to contract with each location for wages and salaries for additional depot employees needed to monitor and
maintain PRO materials.
Reuse
CAA will explore opportunities for supporting reusable packaging at depot locations and events. As depot locations and
events will be staffed there may be opportunities for collection of reusable packaging.
If member producers express interest in introducing reusable packaging formats, CAA will work those producers and other
stakeholders to assess the logistics and operational requirements required to facilitate collection through the PRO depot
system. This will likely require additional reverse logistics arrangements specific to refillable packaging. Depending on the
status of the material in question, incorporation of reusable packaging into the PRO acceptance collection system may also
require material reporting category changes and program plan amendments. CAA will work with producers to assess the full
financial and operational implications of managing reusable packaging. Where appropriate trials may be implemented to
assess feasibility.
Advanced Notification
Before considering adding any materials for collection at the depot, including a reusable packaging format as described
above, CAA would engage with DEQ in a process of notification six months before implementation. At that time of
notification, CAA will produce data relevant to the proper screening assessment, which relates to sufficient availability of
responsible end markets.
Promotion of the PRO Depot Network
The statewide promotional campaign, as part of the broader education and outreach component of this Plan, will focus on
three main areas: the USCL, the PRO recycling acceptance list collection materials (including how to take advantage of PRO
Recycling material collection opportunities) and reducing contamination (both in terms of proper preparation of materials
and avoiding non-accepted materials).
Collection opportunities will be promoted via a CAA-developed website that lists the available depots throughout the state.
This will include hours of operation and site accessibility information. Customizable collateral that will be made available to
local governments via an online portal and then distributed through their existing channels will also reinforce relevant
messaging about depot recycling opportunities.
Educational collateral and campaign material will also highlight the importance of proper preparation of materials for
recycling. CAA proposes to use proven motivational messaging to address key issues and inform residents about the new
opportunities to recycle materials in their area.
To ensure that materials are accessible and culturally relevant, CAA has built in audience research and consultation
processes with local governments, community-based organizations, targeted community focus groups, DEQ and the Oregon
Recycling System Advisory Council (ORSAC). This is to ensure that all educational collateral is informative, well-designed,
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culturally relevant and actionable. Local governments will also be able to tailor materials to their area via CAA’s online
portal.
More information about CAA’s proposed approach to education and outreach, including education and outreach specific to
the PRO depot network, can be found in the “Education and Outreach” section of the Operations plan.
Equity in Performance Standards and Collaboration with the Community
As mentioned in the Convenience Standards section above, CAA has been in talks with several CBOs around the state that
have expressed interest in staffing and maintaining depots. Several of the CBOs function as workforce development
programs, such as Trash for Peace’s Environmental Promotor program or The Arc’s Job Training programs for individuals
with Intellectual and Developmental Disabilities (IDDs). Working with these CBOs to utilize the management of the depots
as a training ground for workforce development aligns with the current goals of many of these programs. Saint Vincent de
Paul and James Recycling also have similar workforce development programs tailored to individuals with differing physical
and mental abilities. CAA aims to make some of the depot contamination management and other processes obtainable for
individuals with differing physical and mental abilities.
iii. Start-Up Approach for Establishing the Depot
Collection System
In the sections above relating to meeting convenience and performance standards, there are several references to CAA’s
plans to contact existing depot locations as well as pursue opportunities to partner with new locations or offer alternative
solutions. As previously noted, CAA plans to undertake this start-up activity (previously an interim coordination task) as part
of its proposed ORSOP. However, given there are several considerations that are PRO depot specific, the outline below
explains in more detail the tasks and timings specific to this aspect of the needs assessment work.
Phase 1: Preparation (April 2024)
CAA’s first phase of work to establish a depot collection system will focus on preparing for outreach and engagement. Likely
activities during this phase include, but may not be exclusive to:
Working with Oregon DEQ and other stakeholders to identify key information gaps to inform outreach and analysis
process, for example, the potential role of transfer stations in the depot network
Refining the target list of existing and potential depot partners, including identifying overlaps with outreach to local
governments and service providers
Drafting consultation materials e.g., background and planning documents that will include (at a minimum)
explorations of the following for existing depot/drop-off sites including those run by Local Governments/service
providers, and new sites:
o Existing collection provision and capacity (if applicable)
o Appetite and capacity for expansion (existing and new sites)
o Estimated cost of expansion
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o Specific material questions relating to current and potential handling e.g. proposed status of glass, handling
needs for materials like EPS, aerosols etc.
o Understanding Education and Outreach provision and needs
Phase 2: Consultation, Enhanced Analysis and System Design (May-August 2024)
CAA’s second phase of work will focus on conducting outreach, leveraging efficiencies where this may overlap with other
outreach to local governments and service providers in relation to curbside service. Activities may include, but will not be
limited to:
Undertaking outreach to local government and potential partner depot operators, using the following potential
methods:
o Direct outreach, potentially via a survey mechanism (efficiencies with ORSOP to be explored)
o Follow-up calls and meetings to pursue negotiations with potential depot partners
o Group meetings to facilitate coordination at the wasteshed level
In parallel to, and informed by, the outreach and consultation process:
o Exploring and modeling options for materials management including aggregation, transportation and
Responsible End Market management, informed by learnings from survey and other outreach
o Refining the GIS mapping work CAA has commissioned to date with IncaTech to revise estimates of schedule
for meeting convenience standards
o Developing detailed approach to meeting performance standards, further developing and refining the initial
proposals outlined in this submission
o Refining the plan for achieving collection targets and adjusting corresponding aspects of the Program Plan
o Liaising cross-functionally or across PRO(s) on Education and Outreach needs
Phase 3: Revised Draft Development and Iterations (September 2024)
Informed by additional 2024 outreach, CAA will update plans for the PRO acceptance list collection system.
Phase 4: Operationalization and Onboarding (January-June 2025)
Subject to DEQ approval of the CAA program plan, CAA will focus on the operationalization of the Oregon PRO depot
network. Activities may include, but will not be limited to:
Finalization of contracts with local governments, service providers and end markets
Finalizing the launch of reporting and accounting systems while onboarding key stakeholders
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Phase 5: Launch
By June 30, 2025, the first phase of PRO acceptance list collection points will be open. This will provide continued
opportunity to recycle in Metro areas where items formerly on local government recycling acceptance lists have moved to
the PRO recycling acceptance list. Over the course of the program plan CAA will on board additional collection sites to fully
achieve convenience standards. Continued education and outreach efforts will ensure accurate information for residents
regarding depot location, depot accepted materials, proper preparation of materials for recycling and top-level
contaminants to avoid.
iv. Proposed Depot Collection Targets
CAA has developed initial proposed collection targets for the PRO depot network. Where possible and where data were
available, information from Cascadia’s Overview of Scenario Modeling: Oregon Plastic Pollution and Recycling
Modernization Act (referred to from here on as the “Cascadia report”) was used to generate the values in the following
section. Where data were not available, supplemental sources from depot programs in Ontario (the Resource Productivity
and Recovery Authority for general blue box materials and the Orange Drop program for hazardous materials) were
referenced.
2
For the purposes of simplifying equaons to demonstrate esmated collecon rates per locaon, the following secon will
reference a number of depot locaons. In this secon, the term “depot” is used to represent physical locaons, events and
curbside services for PRO materials as explained in the “Proposed approach to meeng convenience standards” secon of
the Program Plan. Strictly for purposes of calculations here, but pending a number of considerations going forward, the
table and text below use 173 sites against projected collected tons.
3
The numbers are presented as an average per site per
year, recognizing that, in reality, some sites will collect more material than others.
For purposes of projecting collection targets in this section and subject to additional analysis in future versions of this Plan,
CAA also assumes that 15% of the Oregon population will participate in depot and related services.
2
https://stewardshipontario.ca/wp-content/uploads/2022/06/SO-2020AR-FINAL-002-3.pdf
3
Variables that will affect or determine the final number of collection sites include but are not limited to 1) the percentage of local governments agreeing
to host sites, 2) DEQ’s flexibility in meeting convenience standards by city, 3) value of curbside collection to displace number of depots, 4) number of sites
that can accept all materials vs a more limited range, 5) materials management standards for aerosols and pressurized containers as HHW, 6) the ability to
use existing film drop-off points at retailers, and 7) the ability to substitute events for sites
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Proposed Collection Targets and Rates
Material
Proposed Collecon
Targets and Rates
Average Tons/Year Per
Collecon Point
Average Pounds Per
Parcipant Per Year
Steel and Aluminum
Aerosol Packaging
325 tons
(11.6% collecon rate)
1.03
1.88
Single-Use
Pressurized Cylinders
120 tons
(15% collecon rate)
0.38
0.69
Polyethylene Film
Packaging
1,950 tons
(5.9% collecon rate)
6.16
11.27
Aluminum Foil and
Pressed Foil Products
390 tons
(6.2% collecon rate)
1.23
2.25
Block White Expanded
Polystyrene
490 tons
(9.2% collecon rate)
1.55
2.83
Polyethylene (PE) and
Polypropylene (PP) Lids
and High-Density
Polyethylene (HDPE)
Package Handles
290 tons
(10% collecon rate)
0.92
1.68
Plascs Buckets, Pails, and
Storage Containers
975 tons
(15% collecon rate)
3.08
5.64
Table 5
Material-Specific Discussion
Steel and Aluminum Aerosols
Data on available steel and aluminum aerosols is very limited. Data that was available from the Cascadia report did not
provide any generation estimates specific to aerosol cans. Data from other jurisdictions and sources
4
suggest approximately
4
These include capture rate data from The Recycling Partnership and proprietary data from other programs
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2,800 tons of empty containers were generated in Oregon in 2023. The Cascadia report suggests 166 tons of aerosols would
be collected at depots. However, data from other Oregon sources, such as facilities that are currently handling this material,
suggests the number could be significantly higher. It is estimated that approximately 325 tons of empty aerosol containers
will be collected. Thorough education and outreach will help increase diversion.
Overall, the collection rate is estimated to be approximately 11.6%. An average of 1.03 tons (empty package weight) are
expected to be collected per each through the collection point network, at an estimated average of 1.88 pounds collected
per participant per year.
CAA recognizes that aerosol containers will need to be managed as HHW items. CAA is currently working with both
permanent and event collection HHW providers to understand the volumes that will be collected through those channels
and recovered by the PRO. As CAA learns more about the volumes currently collected through HHW programs, this
collection calculation may be revised.
Single-use Pressurized Cylinders
The Cascadia report did not have any specific generation data on single-use pressurized cylinders. The only source identified
was from the Orange Drop program in Ontario, Canada. Extrapolating from data available from the annual reports it is
estimated that approximately 800 tons of pressurized containers were generated in Oregon in 2023. Through an aggressive
depot collection education program, it is anticipated that up to 120 tons may be collected.
The projected collection rate would be approximately 15%, averaging 0.694 tons per each collection point or approximately
0.38 per participant per year.
Polyethylene Film Packaging
Data from the Cascadia report suggests approximately 66,000 tons of polyethylene (PE) film were generated in 2023.
Assuming 50% falls within the RMA scope
5
, approximately 33,000 tons are generated and available for collection. An
estimated 1,950 tons will be collected per year, which is a number consistent with data from available Canadian depot
programs. Consumer confusion over flexible films may result in a mix of film resins being captured at the collection points.
Overall, the collection rate is estimated to be approximately 5.9%. An average of 11.272 tons are expected to be collected
per each of the collection points in the network, at an estimated average of 6.16 pounds collected per participant per year.
As part of the depot network for film collection, CAA will reach out to the retailers currently collecting film in the state to
see which locations may be voluntarily added to the PRO collection network for film.
DEQ designated PE film as a PRO depot material due to concerns surrounding the material’s compatibility with the existing
recycling system. While not challenging this decision, CAA believes that this material could eventually be introduced into
the USCL list and that improving long-term collection rates will likely be necessary to meet statewide plastic recycling goals.
5
This assumes that 50% of PE film is out of scope because it is generated as wrap by non-RMA retail, distribution center and industry sources. This
estimate aligns with other industry sources, for example The Recycling Partnership capture data, accounting for some increases due to commercial
volumes but also some decreases due to plastic bag bans in Oregon. Note that this same generation figure is used in the denominator of the plastics
recycling rate calculations below.
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As such, CAA will work with Oregon processing facilities to review strategies for management of PE film as well as adding
non-PE films over time. Assessment may include the implementation of research opportunities once the Program Plan
period commences to better understand opportunities. Meanwhile, CAA also plans to further investigate the volume of PE
film material flowing through depots, the commingled stream (as contamination) and specialized collection services to
inform potential research and trials while meeting its obligation to ensure the disposition of this material to REMs.
Aluminum Foil and Pressed Foil Products
The Cascadia report provided no specific generation estimates for aluminum foil and pressed foil products. Estimates from
other sources, including The Recycling Partnership (The Partnership), suggest 6,300 tons of residential material were
generated in 2023. Based on The Partnership’s estimates for collection, corroborated by available information from
Canadian depot programs, CAA estimates that approximately 390 tons of aluminum foil and pressed foil products will be
collected through PRO depots (Cascadia’s report suggested only 50 tons may be collected as it is common for residents to
place their aluminum foil products in their curbside container, but this figure seems too low).
A general trend towards grocery products moving away from aluminum foil trays into polycoated boxboard formats may
impact the volume of foil products generated over time. Less expensive, freezer-safe and microwave-safe, boxboard trays
are increasingly replacing aluminum foil products. Provided that assumed participation rates remain the same, the estimate
of collected tonnage may become aggressively high over time.
Overall, the collection rate is estimated to be approximately 6.2%. An average of 2.254 tons are expected to be collected
per each of the collection points in the network, at an estimated average of 1.23 pounds collected per participant per year.
Block White Expanded Polystyrene (EPS)
The Cascadia report suggests approximately 5,300 tons of foam polystyrene were generated in 2023. However, the report
noted there was some downward pressure on EPS for generation. Using available data, adjusted for recent reductions in
EPS usage suggests approximately 490 tons will be collected.
This estimate is consistent with data available from depot programs in Canada. It should be noted that producers utilizing
EPS packaging are under pressure to replace it because of the perception of its impact on ocean beaches and marine litter.
EPS is being replaced by molded pulp forms, corrugated cardboard forms and expanded PE and PP foams. Therefore, the
collection estimate may be on the high side if these other cushion packaging forms continue to make inroads.
Overall, the collection rate is estimated to be approximately 9.2%. An average of 2.83 tons is expected to be collected per
each of the collection points in the network, at an average estimated 1.55 pounds collected per participant per year. CAA
will also be approaching enhanced recycling service programs, such as Recycle+, to offer management of those collected
materials, like EPS, to ensure they are recycled by REMs. These volumes may also be included in the PRO annual recovery
calculations.
PE and PP Lids and Caps and HDPE Package Handles
There is little available data on generation of these materials as typically both are part of a larger tubs and lids collection
program in many jurisdictions. Based on 7.5% of the weight of HDPE and PP bottles, tubs and lids captured in selected
Canadian programs, 290 tons are expected to be collected through the collection point network. Overall, the collection rate
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is estimated to be approximately 10%. An average of 1.676 tons are expected to be collected per each of the collection
points in the network at an estimated average of .92 pounds collected per participant per year.
DEQ has included PE and PP lids on the PRO depot collection list due in large part to sortation concerns (they are permitted
on the USCL when screwed or snapped onto containers). Realistically, caps and lids will likely have low collection rates,
given the time cost associated with households having to collect them and drop them off at designated depot drop-off
points. However, CAA will ensure extensive education and promotional materials are distributed to direct people to take
their caps and lids to local drop-off depots.
CAA believes this material, inclusive of HDPE package handles, should eventually be introduced into the USCL list, as lids
and caps that are screwed or snapped onto containers are already an accepted USCL material. CAA is in contact with an
Oregon-based manufacturer of HDPE package handles that has completed further CRPF-focused studies since the
rulemaking process. CAA proposes to discuss the findings of this new research with DEQ and Oregon CRPFs, as well as
exploring other research needs, potential design improvements among producer members and ways of better
communicating to residents once the Program commences, with a view to making the case for their inclusion on the USCL.
Plastic Buckets, Pails and Storage Containers
The Cascadia report does not provide categorization or other levels of granularity that produces a generation figure for
plastic buckets, pails and storage containers. For purposes of projecting a collection target, it is assumed approximately
6,500 tons of this material are generated per year. Some of this material is likely currently found in curbside recycling loads
in Oregon, but CAA will focus education on driving the right materials to depot locations. At depots, it is estimated that
approximately 975 tons will be collected, although this estimate is higher than data available from depot programs in
Canada.
Overall, the collection rate is estimated to be approximately 15%. CAA expects 5.636 tons to be collected on average per
each of the collection points in the network. An estimated 3.08 pounds per participant per year will be captured.
Glass
Glass currently collected in Oregon via separated curbside streams totals upwards of 38,000 tons annually. Additional glass
bottles and jars are expected to be collected through new communities getting access to glass recycling. Many residents in
more rural areas, or who self-haul in Oregon, already take glass to their local depots for recycling. Through an enhanced
public education and promotion campaign, CAA estimates that an additional 3,100 tons of glass, for a total of
approximately 41,100 tons will be collected through the network of collection points, and on-route collection where local
governments choose to preserve those services (subject to negotiations between CAA and the local governments). This
estimate is consistent with the estimates provided by Cascadia. Overall, with an estimate of 77,000 tons of glass available
for collection, this translates to an estimated collection rate of 53%; eight percentage points higher than the required rate
of 45% under the program.
Challenges associated with glass contaminants in the commingled stream are well understood by CAA and will inform the
education and outreach strategy. Given that glass bottles are used in food contact applications, relevant education and
outreach will also address appropriate disposal practices in case of high levels of food contamination and will mirror that of
delisted materials with similar use cases, such as aluminum foil.
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Supporting the Oregon statewide plastics recycling rate (ORS 459A.926)
The state of Oregon has established a statewide recycling goal for plastic packaging and plastic food service ware, with
targets of:
At least 25% by 2028
At least 50% by 2040 and in each subsequent year, and
At least 70% by the calendar year 2050 and each subsequent year
The establishment of the statewide PRO depot network along with the USCL will significantly increase access and
opportunity uniformly across the state for all Oregonians. The transportation reimbursement to local governments and
their service providers will also serve as an economic equalizer across the state, addressing an existing and significant
barrier to plastics recycling in more rural parts of Oregon.
CAA expects the increase in access to recycling for a greater range of plastic products, coupled with the continued success
of other recycling programs, such as OBRC, to allow the state to reach the first plastics recycling goal of 25% by 2028.
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c. Materials Strategy
CAA acknowledges that specific materials need special attention and potential action to help in the achievement of this
plan’s objectives and goals, as well as the goals of the RMA. These activities connect to the objectives relating to addressing
packaging impacts, the expansion of recycling opportunities, the achievement of the plastics recycling goal, and the
utilization of responsible end markets.
Many CAA members have made significant investments to support the successful collection and recycling of certain
materials nationally and, in many cases, in Oregon specifically. As CAA works to address packaging impacts, the expansion
of recycling opportunities, and the achievement of recycling goals and targets, the organization is committed to further
leveraging work being done by existing material-focused groups and organizations where applicable. Examples of this type
of work include The Recycling Partnership’s PET Recycling Coalition and the Poly Coated Paper Alliance. It is a priority of
CAA to avoid unnecessary duplication of efforts.
CAA is also committed to exploring opportunities to achieve the broadest possible system benefits from any agreed and
funded system interventions. For example, if any investments are made in CRPFs in Oregon, CAA proposes to work with
CRPFs to agree when and whether these may stand to benefit more than one material category.
In addition to the specific material actions identified below, CAA will continue to work with stakeholders in reviewing other
RMA material issues and options. For example, CAA noted support in its Phase I RMA Rules submission for the inclusion on
the USCL of PE and PP lids and caps and HDPE package handles. While CAA does not have a specific action plan in relation
to these materials at the time of this submission, the group will continue to assess these materials and potentially other
USCL additions with Oregon stakeholders in the context of other materials management discussions. Any recommendations
for the addition of other materials to the USCL or recommendations for trial assessments of other materials would be
presented as program plan amendments at a later date.
To effectively improve collection and recycling in Oregon in accordance with the RMA, several material-specific issues must
be addressed. In this section, CAA reviews:
1. Proposed additions to the USCL
2. SIMS on the USCL
3. SIMS on the PRO Recycling Acceptance List
4. Proposals to engage on commingled collection of some materials on a trial basis
5. Initial plastic recycling rate projections
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i. Proposed Additions to the USCL
In addition to taking steps to establish universal adherence to the currently approved USCL, CAA is proposing pathways for
some other materials to be added to the USCL.
PET Thermoforms
Material Status
CAA recognizes that some PET thermoforms have not been included in the USCL list and DEQ has classified them as a SIM.
CAA intends to take steps that will justify the addition of those PET thermoforms to the USCL list, which in turn will
encompass CAA’s obligations to address the concerns raised by Oregon DEQ via the SIMS list. CAA proposes that
appropriate actions be taken to include PET thermoforms on the USCL by July 1, 2027.
DEQ’s overall material collection determination has kept PET thermoforms off both the USCL and PRO depot lists, meaning
these materials will not be collected as a part of curbside commingled streams. However, studies across the country find
that even when not accepted as a part of curbside commingled collection, thermoforms can make up to 10% of an average
PET bale.
8
To minimize the loss of thermoforms as CRPF residue, CAA proposes to engage with CRPFs as outlined below to
create a seamless system for PET thermoforms.
Under CAA’s proposal, PET thermoforms would ultimately be collected statewide as part of commingled curbside streams
and would be processed and sent to responsible end markets (REMs) by CRPFs. In the interim, CAA will engage with the
specialized subscription-based collectors of PET thermoforms and CRPFs to understand the volumes and processing picture
for those materials – and to ensure REMs are being utilized.
Performance Against ORS Criteria
CAA acknowledges that Oregon DEQ made its decision to exclude PET thermoforms from the USCL based on a set of key
criteria in ORS 459A.914(3). Chief among DEQ’s concerns is a lack of consistent, responsible end market demand for the
material, which in turn has caused limited CRPF acceptance and inclusion in curbside programs. The table below provides
information to address the key challenges for PET thermoforms, referencing the specific determination criteria outlined in
ORS 459A.914(3). The information has been gathered through ongoing research and engagement with a wide range of
stakeholders involved with PET thermoform recycling issues (more details can be found in Appendix D).
Criteria
Performance
The stability, maturity,
accessibility and viability of
responsible end markets
Reclaimer investments and interest in PET thermoform recycling are dynamic and growing, with
regional end markets available to Oregon CRPFs and new markets acvely developing.
CAA proposes to facilitate PET thermoform markets between Oregon CRPFs and responsible end
markets.
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CAA also acknowledges the role it will need to play in direcng exisng PET thermoform collecon
(e.g., via specialized collecon services) to REMs while PET thermoforms remain non-USCL
materials.
Further, CAA notes there currently is market demand for thermoform-derived rPET (most
prominently by berry company Driscoll's) that considerably outweighs the current supply. CAA
expects more producers to join this exisng end user in demanding thermoform-derived rPET.
Environmental health and
safety consideraons
PET thermoforms do not present any immediate or substanal health and safety concerns to the
recycling process. Concerns with PET thermoform reclamaon include water usage and wastewater
management. However, it is noteworthy that there is no indicaon that thermoform reclamaon
requires any more water than PET bole reclamaon.
6
CAA proposes to examine water consumpon
in PET thermoform reclamaon as part of its end market engagement and, as needed, develop
intervenons to reduce water consumpon and improve usage of best pracces in wastewater
treatment.
The ancipated yield loss
for the material during the
recycling process
Yield loss during reclamaon includes both the intended removal of non-PET materials and the
unintended loss of PET. The removal of non-PET items during pre-sorng at the reclaimer causes an
unavoidable simultaneous loss of erroneously removed PET. Both forms of yield loss at pre-sorng
can be minimized by implemenng more eecve sorng equipment and procedures at CRPFs.
Reclaimers also experience loss of PET due to the generaon of nes, which tends to be greater in
PET thermoform reclamaon than PET bole reclamaon. CRPFs can minimize yield loss due to nes
generaon by implemenng best pracces and opmizing equipment and processes.
The material’s
compability with exisng
recycling infrastructure
To date, only two Oregon CRPFs are accepng and markeng PET thermoform material gathered
through specialized collecon programs separate from curbside commingled collecon. The current
lack of acceptance in municipally managed collecon programs is a result of a historical lack of end
market demand, which has only recently improved. CAA proposes to address the nexus of CRPF
acceptance/reclaimer demand that then creates the condion for universal collecon.
The amount of the material
available
Informaon submied by various stakeholders in Oregon’s rulemaking and material assessment
processing solidly documents the established, scaled presence of the PET thermoform material in
the packaging stream.
The praccalies of sorng
and storing the material
PET thermoform sortaon and storage at CRPFs is an established pracce, most prominently in
California. CAA proposes to explore the need for CRPF investment in this equipment and facilitate
this as appropriate.
Contaminaon
Contaminaon results from mistaken public recycling of lookalike materials and design issues with
PET thermoforms, including the use of recycling-incompable glues and labels. An addional
challenge can arise from residual food waste on PET thermoforms. CAA proposes to develop
mechanisms to address and minimize all these challenges.
The ability for waste
generators to easily
idenfy and properly
prepare the material
CAA proposes to develop mechanisms designed to reduce the presence of lookalikes in the
packaging stream (without creang adverse environmental impacts) as well as clear educaon to
help generators correctly idenfy the materials that should be placed in commingled recycling.
Economic factors
While there are no direct measurements of PET thermoform value marketed by CRPFs, PET
thermoform bales marketed by California MRFs have consistent posive value, as demonstrated by
RecyclingMarkets.net. Similarly, Plasc Recycling Corporaon of California (PRCC)’s website indicates
that at the me of submission, thermoform-only bales trading at 8 cents per pound, which is a
6
Based on conversations with internal PET thermoform experts at The Recycling Partnership.
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fracon higher than commingled bole and thermoform bales and only two to three cents per
pound lower than bole-only bales.
7
If this value translates to Oregon when PET thermoforms are
collected and processed, it could improve the current “blended value” of all processed materials.
CAA’s plan arculates market-related mechanisms that will help to guarantee the value of PET
thermoform material to CRPFs. Once established in collecon, CAA’s PCRF payments will help
support PET thermoform sortaon and markeng.
Environmental factors from
a life cycle perspecve
N/A
Table 6
CAA submits that PET thermoforms have a positive trajectory in relation to the challenges detailed above and that
concerted action in the implementation of this Plan will encourage that trend, thus facilitating the addition of PET
thermoforms to the USCL.
Proposed Action Steps and Timeline for Inclusion on USCL
As part of its implementation of this plan (once approved), CAA proposes to take the following steps to facilitate inclusion
of PET thermoforms on the USCL:
1. Explore providing technical and financial assistance to CRPFs to receive and sort PET thermoforms for shipment
to responsible end markets
2. Facilitate end market demand for PET thermoforms to ensure that all CRPFs gain the continuous ability to send
PET thermoforms to REMs
3. Address design issues that hinder PET thermoform recyclability
With the implementation of the action steps outlined above during the first Program Plan, CAA proposes that PET
thermoforms can be considered for addition into USCL on July 1, 2027. In the interim, CAA will explore ways to direct
thermoform collection (e.g., via specialized collection services) to CRPFs with existing sortation capabilities to concentrate
the flow of materials and facilitate disposition of these material to REMs.
CAA financing for activities related to the potential inclusion of PET thermoforms (currently not accepted for recycling) will
be managed through the collection of fees applied to these materials. This fee setting principle will be applicable to
material management development costs associated with other materials. CAA will allocate specific material development
costs to those specific materials through the fee setting process.
7
Based on values indicated on https://prcc.biz/pricing/ accessed on 5
th
February 2024.
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Transparent Blue and Green PET Bottles
Material Status
DEQ only included clear PET bottles on the USCL. However, CAA understands from stakeholder discussions that transparent
blue and green PET bottles are widely recycled and recommends that transparent blue and green PET bottles be added to
the USCL by July 1, 2025.
CAA understands that transparent light blue PET bottles are treated separately from transparent dark blue PET bottles, with
transparent light blue PET bottles being desired by reclaimers to counteract the gray color of rPET derived from clear
bottles. Based on email correspondence with subject matter experts from the National Association for PET Container
Resources (NAPCOR), the Association of Plastic Recyclers (APR), and The Recycling Partnership, CAA understands that
transparent dark blue PET bottles are often combined with transparent green PET bottles with minimal impact on end-
market suitability.
8
Given that Oregon is a deposit state, with many transparent blue and green bottles collected for recycling via redemption
centers, CAA anticipates that adding transparent blue and green PET bottles to the USCL will add a relatively small volume
of material to CRPFs.
Performance Against ORS Criteria
Criteria
Performance
The stability, maturity,
accessibility and viability of
responsible end markets
Consultaons with reclaimers made clear that transparent blue and green PET boles are
rounely and successfully routed to established, stable end markets in the Pacic Northwest
Region and other parts of the U.S. Also of note, APR and ISRI bale specicaons
9
are inclusive
of transparent blue and green PET boles with no limitaons on either. CAA will monitor and
consistently engage reclaimers to understand and suitably address any issues that arise in
processing or markeng this material.
Environmental health and safety
consideraons
Transparent blue and green PET boles do not present any immediate or substanal health
and safety concerns on the health or safety of CRPF operators.
The ancipated yield loss for the
material during the recycling
process
Yield loss for transparent blue and green PET boles is not signicantly dierent than the yield
loss during reclamaon of clear PET boles, which can be minimized by opmizing equipment
and processes.
The material’s compability with
exisng recycling infrastructure
Transparent blue and green PET boles are already collected and sorted successfully from
commingled streams in Oregon.
8
Interviews with ORPET and email exchange with NAPCOR, APR, and The Recycling Partnership.
9
APR’s model bale specifications for PET bottle with PET thermoforms and APR and ISRI’s model bale specifications for PET bottle bales without PET
thermoforms states that transparent green and transparent light-blue PET are an acceptable part of a model PET bale. See APR’s Model Bale Specification:
PET Bottles (No PET Thermoforms), APR’s Model Bale Specification: PET Bottles with PET Thermoforms, and ISRI’s Bale Specification: PET Bottles (No PET
Thermoforms). Documents accessed on 02/22/2024.
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The amount of the material
available
The praccalies of sorng and
storing the material
Contaminaon
There are likely no contaminaon issues that are specic to the acceptance of transparent
blue and green PET boles.
The ability for waste generators
to easily idenfy and properly
prepare the material
Engagement with stakeholders has led CAA to believe that transparent blue and green PET
boles are easily idenable by waste generators. Transparent green and blue PET lookalikes
made of other resins are also uncommon.
Economic factors
The exisng market economics surrounding PET bole recycling account for the value of
transparent blue and green PET boles and have demonstrated a viable amount of economic
producvity.
Environmental factors from a life
cycle perspecve
N/A
Table 7
Spiral Wound Containers
Material Status
Spiral Wound Containers were included in DEQ’s draft USCL rule until they were removed by DEQ just prior to submitting
the proposed rule to the Environmental Quality Commission (EQC). This removal occurred because an in-state market,
Cascade Steel Rolling Mills Inc. (CSRM), provided a formal written comment that while the company “is adopting a neutral
position regarding the addition of spiral wound cans” it had concerns regarding “the potential impact of these materials on
emissions of air toxics and other pollutants.”
Although Sonoco (the primary manufacturer of spiral wound containers) reported a screening-level life cycle assessment
demonstrating that for five of six impact factors evaluated, the added (global) environmental benefits of increased steel
recycling outweigh higher (local) emissions associated with combustion of the non-steel fraction of the package, DEQ chose
to remove them from the draft rule submitted to EQC to provide “Cascade Steel Rolling Mills and Sonoco additional time to
better evaluate outstanding concerns involving local air emissions.”
CSRM and Sonoco have subsequently met, and we understand had a positive discussion. As of the time of this program plan
submission, however, CSRM had not yet provided a final decision to Sonoco. There are currently 112 steel mills in the
United States, of which CSRM is only one, and regardless of the decision by CSRM, CAA proposes to add/restore spiral
wound containers to the USCL via this program plan. Other steel mills that Sonoco has approached for their acquiescence to
recycling steel can bundles with spiral wound containers in them have not raised air emissions concerns. In fact, Sonoco has
submitted letters from the following steel mills that accept spiral wound containers in their incoming stream:
United States Steel Corporation (on behalf of their six U.S. steel mills)
Nucor – Plymouth, Utah location (Nucor has 20 U.S, steel mills, including a mill in Seattle)
Transparent blue and green PET bottles are already collected and sorted successfully
from commingled streams in Oregon.
Transparent blue and green PET bottles are already collected and sorted successfully
from commingled streams in Oregon.
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ArcelorMittal Dofasco – 13 U.S. steel mills
Algoma Steel Inc., Sault Ste. Marie, Ontario, Canada
Performance Against ORS Criteria
When removing spiral wound containers from its draft rule, DEQ stated in its comments that:
“DEQ understands that paper cans are appropriate for recycling given consideration of all other criteria contained in ORS
459A.914(3) and if this concern regarding potential air emissions can be addressed. A producer responsibility organization
may propose adding this material to the Uniform Statewide Collection List using the program plan mechanism described in
ORS 459A.914(4)(b).”
10
CAA is not submitting additional information with respect to ORS Criteria at this time.
Proposed Action Steps and Timeline for Inclusion on USCL
CAA proposes to include spiral wound containers on the USCL effective July 1, 2025. Existing equipment in Oregon’s CRPFs –
specifically magnets and paper screens – sort spiral wound cans into acceptable market grades (primarily steel cans, and, to
a far lesser extent, mixed paper) at sufficiently high effective sorting rates. No additional labor or equipment is needed for
CRPFs to successfully sort and market spiral wound cans in incoming commingled material.
If the inclusion of spiral wound paperboard cans in steel can bundles is proven to cause CSRM to exceed its DEQ air permit,
then CSRM would not be deemed a responsible end market. Under this circumstance CAA proposes to develop a list of
alternative steel mills that purchase steel can bundles with spiral wound containers and to distribute such list to CRPFs so
that their steel can bundles go to alternative responsible end markets, of which there are many.
ii. Specifically Identified Materials on the USCL
Some materials that are included on the USCL are also considered SIMs by DEQ. As these materials will require particular
attention, CAA proposes implementation of the following strategies to address relevant recyclability challenges.
Polycoated Gable-Top Cartons and Aseptic Cartons
CAA acknowledges that polycoated gable-top and aseptic cartons have been identified as a SIM in addition to being
included on the USCL. Currently, it is estimated that about half of Oregon households are served by collection programs
that include cartons and this will grow to all households by July 2025. It is CAA’s understanding that Oregon’s CRPFs
currently include cartons in mixed paper bales and do not sort cartons into a separate PSI 52 grade bale. To date, CRPFs
have not seen the value in marketing cartons separately from mixed paper.
10
https://ormswd2.synergydcs.com/HPRMWebDrawer/Record/6446398/File/document, top of Page 7 of 105.
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Processing and Marketing Challenges
CAA aims to address issues associated with processing and marketing of this material by engaging with key stakeholders, as
well as identifying logistical issues that CAA can play an active role in resolving.
CAA proposes to work with CRPFs to explore the barriers they face in sorting and/or storing cartons and work with
interested producers and associations, such as the Carton Council of North America, to review funding options for any
necessary incremental infrastructure.
CAA also proposes to explore offering a marketing service for cartons, which would be voluntary for CRPFs that elect to take
advantage of it. For example, CAA would collect carton bales from individual CRPFs on a pre-agreed cadence, consolidate
them into truckload quantities, and market them. CAA would then compensate CRPFs for the tons marketed. This could be
based on the Pacific Northwest index price for PS54 Mixed Paper as reported on RecyclingMarkets.net’s Secondary
Materials Pricing (SMP).
In exploring these options, CAA will ensure materials are routed to responsible end markets and will consider adjustments
to its fees to provide any necessary funding. In scenarios in which CAA possibly markets materials on behalf of CRPFs, CAA
will work with the facilities to determine the best way for material revenues to be factored into PCRF payments.
Nursery Packaging
CAA acknowledges DEQ’s recommendation to place all nursery packaging in the SIM list while designating only HDPE and
PP-made nursery packaging as material approved for curbside commingled collection with inclusion on the USCL.
Education and Outreach
CAA recognizes that the USCL status recommended for HDPE and PP-based nursery packaging will require the program plan
to account for communities that may not have collected these pots and trays thus far. Education and outreach will aim to
minimize contamination, in particular from problematic PS nursery packaging. To accomplish this, CAA proposes to:
Explore the need to gather data on which communities in Oregon, prior to July 1, 2025, collect nursery packaging and
which ones don’t. When done for nursery packaging, data will try to capture the number of communities that
collect/do not collect the material, quantities and seasonal trends in the generation of this material as a curbside
recyclable, and extent of contamination from PS and LDPE lookalikes. Similar data collection exercises will be explored
for all SIM materials
Explore opportunities for reuse and recycling of this material at Oregon-based nurseries and explore ways for CAA to
leverage this information in its education materials, prioritizing options for reuse wherever possible
Identify and segment communities in Oregon based on those that are most acutely affected by nursery packaging’s
inclusion in the USCL. This segmentation could be based on the determination of which communities have accepted
nursery packaging prior to July 2025 and which ones have not
Design outreach strategies in a phased manner to account for the segmentation. For example, for communities where
curbside collection of nursery packaging is set to start in 2025, the focus will be on informing households of the
availability of commingled curbside collection of nursery packaging. For households already participating in curbside
collection of nursery packaging, CAA will focus the education and outreach strategy on mitigating contamination
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Determine a suitable strategy to help residents identify recyclable nursery packaging from contaminants (lookalikes).
The strategy will aim to help residents differentiate HDPE and PP-based pots and trays from contaminant materials,
examining different approaches, (by use of the resin identification code, for example) As a first step, CAA will
investigate the scale of the contamination issue from PS and LDPE lookalikes in the recycling stream through
conversations with CRPFs.
Processing Improvements
To minimize contamination and improve processing efficiencies of CRPFs, CAA proposes to better understand how Oregon
CRPFs are receiving, sorting and marketing nursery packaging as part of their current operations, for example, if these
materials baled as part of mixed plastics bales. CAA also plans to engage with CRPFs and reclaimers including Denton
Plastics, Merlin Plastics and EFS to understand the scale of the contamination issue with nursery packaging.
As part of a broader stakeholder engagement strategy, CAA will include additional efforts to ensure successful and
responsible recycling of nursery packaging. CAA proposes to identify key manufacturers of nursery packaging and industry
associations such as the Oregon Association of Nurseries and engage with them on strategies to minimize contamination.
iii. Specifically Identified Materials on the PRO Recycling Acceptance List
Steel and Aluminum Aerosol Containers
CAA recognizes that steel and aluminum aerosol containers have been designated as a SIM and will be removed from
curbside commingled collection, primarily in the Portland Metro area. Aerosol containers have thus far been collected in
many Oregon communities, making education and outreach an important component of the program plan for these
materials. Residents’ education will include awareness about the de-listing of aerosol containers and referring residents to
household hazardous waste program as detailed below. To meet this need, CAA proposes to:
Segment Oregon communities based on whether they have had curbside commingled collection of aerosol containers
or no collection prior to July 2025
Create distinct outreach strategies for communities based on segmentation status of curbside commingled collection
Create an outreach strategy for periodic reminders and awareness to residents on PRO depot collection centers and
HHW collection centers, including a “best practices cheat sheet” for disposal of aerosol containers
Subject to member alignment on relevant fee implications, CAA proposes to consider continuing to engage in systemic
changes to minimize hazard potential and perceptions of aerosol containers and to improve the recyclability status of this
material. These may include:
Build on DEQ’s work in examining hazard perceptions related to aerosol containers by investigating the proportion of
aerosol containers generated in Oregon that could be hazardous either due to substances contained in them (e.g.,
pesticides) or from the propellants. To this end, CAA has engaged with key stakeholders to learn that the majority
share (~65%) of aerosol containers in the U.S. are used in non-hazardous consumer segments like personal care,
household products and food products. CAA proposes to investigate similar trends for Oregon. Further, with respect
to propellants, a key design intervention identified by CAA through stakeholder interviews was replacing liquified or
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compressed gas propellant with nitrogen or compressed air propellant, which is less hazardous as the can becomes
less pressurized with use and is non-flammable, unlike liquified gas
Work with the U.S. Aerosol Recycling Initiative, led by the Can Manufacturers Institute and Household and
Commercial Products Association, to learn more about aerosol manufacturing, consumer and end markets, and
recycling
Explore synergies with existing household waste management companies in Oregon to leverage their experience in
collecting and emptying potentially hazardous non-empty aerosol containers
Explore developing logistical models to link household waste management companies and CRPFs/secondary
processors to determine the most cost effective and intuitive approach for aerosol container recycling in Oregon
Engage with CAA members to examine appropriate market-based strategies, including ecomodulation, for phasing out
hazardous propellants
Aluminum Foil and Pressed Foil Products
CAA acknowledges the addition of aluminum foil and foil products to the list of SIMs. Oregon DEQ cited reasons for this
designation that include concerns around food contamination, ability to sort due to the material’s flat shape, and realities
of smelter yields. CAA’s interventions will focus on developing a suitable education and outreach strategy that will help
residents recycle these products at appropriate depot drop-off points and not add to the commingled stream as a
contaminant.
CAA may continue to explore paths for this material to be included on the USCL in future program plan periods.
A key challenge will be instigating a change to the long-standing practice of collecting this material curbside in parts of the
state while simultaneously creating outreach materials that inform residents of appropriate depot locations. CAA’s
approach to developing this strategy will include the following steps:
Segmentation of Oregon communities based on whether they have had curbside commingled collection of aluminum
foil and foil products in the past or no collection prior to July 2025. Communities that have historically treated foil as a
curbside commingled collection material are likely to be most acutely impacted by this change, and CAA will design
the education and outreach strategy to minimize contamination from this group
Communities across Oregon will be targeted for outreach on depot collection points for aluminum foil and foil
products
Given that aluminum foil and foil products are often used in food contact applications, CAA will design education and
outreach materials that address appropriate disposal practices for food contamination
Shredded Paper
Shredded paper is on the PRO Recycling Acceptance list and has been designated a SIM. Much like aluminum foil, shredded
paper has been collected by communities in Oregon and the de-listing of this material from collection lists will impact the
residents of those communities. Education and outreach will be the primary intervention for shredded paper and will mirror
that of other de-listed materials such as aluminum foil.
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Glass Bottles and Jars
CAA acknowledges DEQ’s decision to include glass bottles and jars on the PRO Recycling Acceptance list and classify them as
SIMs.
Glass bottles and jars are currently collected in some areas of Oregon as a separated curbside stream, and the
communication necessary with respect to glass containers will be tailored to the outcome of discussions with local
governments on the development of the collection system for PRO Recycling Acceptance List materials. Where local
governments choose to disconnue exisng on-route collecon systems for glass, CAA will tailor communicaons to orient
residents toward glass drop-off and discourage placing glass in the commingled stream.
As detailed in the PRO Recycling Acceptance list section of this plan, CAA anticipates that a mix of curbside and depot glass
collection will support the achievement of the glass collection target.
iv. Proposal to Trial Commingled Collection of Non-USCL Materials
There are two material groupings that DEQ has designated as SIMS that are neither USCL nor PRO Depot materials. These
are polycoated paper packaging and single-use cups. While these materials are not currently being recommended for
inclusion on the USCL, CAA believes that to adequately address the challenges identified under the SIM designation, it is
appropriate to explore commingled collection of these materials on a trial basis after program commencement, with a view
to better understanding current generator behavior while at the same time working to understand and address other
system barriers to the inclusion of these materials.
Polycoated Paper Packaging
CAA acknowledges that polycoated and similar paperboard packaging have not been included on any collection list due to
concerns surrounding their recyclability. DEQ noted challenges in both sortation and yield. On the issue of yield, DEQ has
questioned whether these materials are effectively recycled by paper mills, if they are readily recyclable (e.g. polycoated
paperboard vs. paperboard with wet strength), and if they showed a high rate of recovery.
CAA also notes that DEQ requests that prospective PROs propose efforts to understand and address the impact of user
behavior on CRPFs and end markets if polycoated paperboard packaging is collected as a part of commingled recycling. CAA
posits that without collecting this material in a commingled curbside trial environment, once the USCL formally launches on
July 1, 2025, it will be challenging to replicate these behaviors and impacts. Therefore, CAA proposes the use of
commingled curbside trials after the commencement of the program period to address this material category’s SIM
designation, while also exploring future paths to the USCL.
In order to meet DEQ’s expectations for this material, CAA proposes conducting time-limited, geographically-bound
commingled collection of these materials to derive real-world, actionable insights:
The trial(s) will primarily aim to understand resident behavior, notably waste generators’ ability to differentiate
recycling information on polycoated paperboard, polycoated paper cups, and cartons. Education and outreach tactics
will be deployed to communicate the appropriate actions
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The trial(s) will aim to understand the nature and quantities of polycoated paper generated, as well as an initial
estimate of the quantities of these materials that end up in mixed paper bales
To scope and plan these trials in the right geography, CAA will research regions where variables and metrics that could
affect results are strongly controlled. Ideally, CAA would target trial regions where willing local partners have:
Strong, stable control or influence over accepted materials lists
Consistent service populations that can be successfully engaged with highly targeted education information
Consistent flows of collected materials to specific CRPFs
CRPFs that are willing and able to participate in the trial to track materials to bales
Responsible end markets willing to participate in the trial to test yield and other factors
CAA proposes to work with relevant stakeholder partners (DEQ, local governments, CRPFs, haulers, and end markets) prior
to any trials to develop a detailed project plan for execution factoring in the following considerations:
Goals and objectives of trials
Timing and duration
Stakeholder partners
Geography (communities potentially impacted)
Logistics of franchised hauling
Resident education (what are the related baseline education materials and how will this work within the broader
education and outreach plan)
Costs associated with the proposed trial
The trials would aim to track materials very specifically from route to bale to market and ensure no other material changes
to the stream or service changes are happening at the same time.
In addition, CAA proposes to address concerns surrounding stability, accessibility, and viability of end markets for this
material by engaging with CRPFs and end markets to understand an acceptable proportion of this material that will not
adversely affect end market applications. Currently, some processors can handle up to 20% of polycoated paperboard
(including polycoated cartons and aseptics) in mixed paper bales.
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CAA proposes to explore options to model the
proportion of polycoated paperboard currently in mixed paper bales and study the implications of an increase. An in-depth
CRPF study could entail examining CRPFs that sort polycoated cups into mixed paper bales separately from those that sort
cups into grade 52 carton bales. Such studies could further entail downstream market research for mixed paper bales with
polycoated cups.
Furthermore, CAA recommends assessing the re-pulpability yield of mixed paper trials. This could potentially include
assessing specific packaging structure potential re-pulpability yield to inform education and outreach.
11
Based on consultation with a key stakeholder processing mixed paper bales.
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Single-Use Cups
DEQ has excluded single-use PP and PET clear cups from recycling collection lists due to contamination concerns. DEQ
stated that the inclusion of single-use cups in acceptance lists may introduce contaminants like trays, clamshells, plates, and
food waste, as well as contamination from PVC and PS lookalike packaging. CAA further notes DEQ’s request to propose
efforts to understand and address the challenges this material poses to the recycling system.
CAA proposes no change to the SIM designation for single-use cups and proposes to conduct a trial study to better
understand user behavior and to investigate the challenges single-use cups pose to the recycling system. CAA proposes that
the limited time, geographically bound trial(s) be conducted after the program period commences in July 2025.
Prior to the trials, CAA will work with relevant stakeholder partners (DEQ, Communities, CRPFs, haulers, end markets) to
develop a detailed project plan for execution factoring in the following considerations:
Goals and objectives of trials
Any material overlaps (for example, polycoated paper cups that may fall into both categories) and how to deal with
these
Timing and duration
Stakeholder partners
Geography (communities)
Logistics of franchised hauling
Resident education
Costs associated with trial
The geography of the trials will be determined in a similar manner as for polycoated paperboard packaging as detailed in
the above section.
In addition, CAA proposes to address information gaps and concerns surrounding single-use cups. For example, the
organization could engage CRPFs and reclaimers receiving single-use cups to understand the extent of yield losses expected
with these materials. Additionally, CAA proposes to examine the extent of contamination introduced from lookalikes made
of PS and understand challenges this may create during the processing of this material.
v. Initial Plastic Recycling Rate Projections
This section of the plan provides CAA’s best estimate of the current plastics generation and recycling rate in Oregon in
relation to the 2028 recycling target of 25% that is laid out in the RMA. It also provides information on the elements of this
plan that can be expected to contribute to achieving the goal, which form a critical part of Objective 2 of this plan: increase
the diversion of recyclable materials from disposal.
Preliminary Plastic Recycling Rate Projections
Oregon currently has limited official data on the generation and recycling of plastic material, especially at levels of detail
that would allow a more precise understanding of recycling rates for specific plastic materials, including the generation
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source of these materials (e.g., residential vs non-residential). Oregon DEQ has indicated that it will work to release data by
August 2024 for the year 2022 to help inform planning toward achieving plastic recycling goals and related calculations.
In the interim and per guidance from DEQ and with no other data source known to CAA to use for this plan, CAA has used
data produced by the Overview of Scenario Modeling: Oregon Plastic Pollution and Recycling Modernization Act and the
2021 Oregon Material Recovery and Waste Generation Rates Report to make a preliminary estimate of the baseline plastics
recycling rate, as shown below. Per guidance from DEQ, CAA has included plastics subject to deposit in the calculations as
well as food service ware.
Note that the table below includes an estimate of the net generated materials that are presumed to be in scope of the
RMA, applying the percentage assumptions displayed in the table. The objective was to try to estimate, account for, and
then exclude materials such as film wrap recycled in distribution centers that is baled and sent to markets directly, never
entering the residential and commercial recycling streams that are focus of the RMA.
CAA welcomes additional data and guidance from DEQ on this issue to ensure that the assumption percentages are correct
(or whether they should be applied at all). The estimates in the table are shown for 2023 as a baseline and for 2028, the
year in which the plastic recycling goal must be met. CAA recognizes that DEQ may set the baseline year as 2022 in its
August data release.
Materials
2023
Generated
(tons)
2028
Generated
(tons)
Assumed % in Scope
(Residenal Sources +
Small Commercial)
2023
Adjusted
Generated
(tons)
2028
Adjusted
Generated
(tons)
PET Boles (Deposit)
16,864
17,363
75%
12,648
13,022
HDPE Boles (Deposit)
171
173
75%
129
130
PP Boles (Deposit)
171
173
75%
129
130
Other Deposit
Plasc Boles
343
346
75%
257
259
Other Pet Boles & Jars
14,912
15,649
90%
13,421
14,084
HDPE Boles & Jars
12,683
13,239
90%
11,415
11,915
PP Boles & Jars
504
523
90%
453
471
Other Boles
936
947
90%
843
853
PET Tubs
919
924
90%
827
832
HDPE Tubs
5,476
6,206
90%
4,928
5,585
PP Tubs & Small Rigids
7,406
7,688
90%
6,666
6,919
Other Accepted Tubs & Pails
533
536
90%
480
482
PET Thermoforms
7,879
8,483
90%
7,091
7,635
Other Rigid Plasc Containers
11,103
11,258
90%
9,993
10,132
PP Rigid Products
11,976
12,200
90%
10,778
10,980
Other Bulky Rigids
28,897
29,438
90%
26,007
26,494
PP Rigid Packaging & Products
10,987
12,411
90%
9,888
11,170
Polystyrene Foam
5,283
5,424
90%
4,754
4,882
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Solid Polystyrene
2,527
2,594
90%
2,274
2,335
Other Non-Recoverable Plasc
54,682
55,733
90%
49,214
50,160
PE Film
65,989
81,460
50%
32,995
40,730
Other Recoverable Film
1,283
1,273
90%
1,155
1,146
Plasc Pouches
1,937
1,972
90%
1,743
1,775
Other Film
50,904
51,937
90%
45,814
46,744
TOTAL
314,365
337,950
253,900
268,863
Table 8
The denominator estimated above for the adjusted total plastic generation for 2023 is 253,900 tons. This number can be
compared to data from DEQ’s 2021 Recovery Rate report that includes recycled tonnage information to then estimate the
current plastic recycling rate (presuming that 2021 recycling rates have not changed substantially between 2021 and 2023).
Table 9 below shows the tonnage recycling data from the Recovery Rate report:
Material
Tons Recycled
Composite Plasc
1,185
Mixed Plasc
N/A
Other Plasc (P7)
N/A
Plasc Boles
N/A
Plasc Film
10,442
Plasc Other
7,380
Rigid Plasc Containers
31,531
Total
50,538
Table 9
The data in Table 9 does not provide enough detail to map to the specific material generation in Table 8, nor to help decide
whether any of the 2021 recycled tonnage should be excluded for being out of scope with the RMA and the plastics
recycling goal. However, the overall totals allow for a general estimate of the baseline plastics recycling rate in Table 10.
Recycled Tons
50,538
2023 Generated Tons
253,900
Plastics Recycling Rate
20%
Table 10
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Using the 2028 Generation estimate in Table 8, it is also possible to project the necessary tonnage that would need to be
recycled to meet the 25% goal and to calculate the net recycled tonnage growth over the baseline that would be needed to
meet the goal.
2028 Projected Tons Generated
268,863
Recycled Tons needed to meet 25% target
67,216
Difference between target tonnage and 2023 baseline
16,678
Table 11
Table 11 provides a preliminary estimate that an additional 16,678 tons of plastic would need to be recycled per year over
current tonnage to meet a 25% recycling goal in 2028. Again, CAA acknowledges that DEQ’s data release in August 2024
may alter this analysis substantially.
The implementation of this plan includes elements that are expected to result in more recycled plastic, thus allowing
Oregon to meet its plastics recycling target. At a very general level, with a great deal of uncertainty as to the true potential
of each of these elements to contribute additional tons, Table 12 displays the main elements and notation on how they
might create new recycled plastic tonnage. Where available data allowed, the notes include a preliminary projection of new
tons.
Plan Element
Notes on Potenal Impact
Expand curbside, mulfamily, and
small commercial recycling access
through local government needs
assessment requests
CAA funding and support of local government requests for new collecon infrastructure
should result in the collecon of addional plascs. Projected tons are dicult to esmate
without more data on the number of generators who will receive new service, their
generated tonnage, and ancipated parcipaon and parcipant capture rates.
Enhance collected material mix in
local programs to meet USCL
requirements
As collecon programs add new plasc materials to meet the USCL requirements, it should
result in more plasc tons. A rough projecon for new polyproplyene collecon alone is
about 1,400 tons/year.
Implement PRO Depots that collect
specic plascs
CAA (and potenally addional PROs) will collect a range of plasc materials at new and
exisng depots. A preliminary esmate of new plascs collecon is 3,840 tons/year.
Add PET thermoforms to the USCL
and local collecon
CAA is proposing to add PET thermoform packaging to the USCL by 2027, at which point
thermoform collecon could provide as much as 1,500 new plascs tons per year toward
the plasc recycling goal.
Enhance plascs capture at
Commingled Recycling Processing
Facilies
PCRF and CMF payments, along with regulatory mandates to improve capture rates and
bale quality, are expected to reduce plasc material disposed at CRPFs and increase
tonnage recycled. It is dicult to project the associated tonnages without more direct
engagement with individual CRPFs.
Improve recycling parcipaon and
parcipant capture rates in
collecon programs
CAA’s educaonal eorts and coordinaon with local recycling programs and franchised
haulers may include specic eorts to raise parcipaon and plascs capture rates (a 2019
Metro capture study showed a 68% capture rate for colored HDPE boles collected from
single-family households and a 35% rate for PP tubs, assumed to be the high end for most
Oregon recycling programs and showing room for improvement). It is dicult to project
the amount of new tonnage that could be expected from educaonal eorts without more
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specic data from local programs and haulers on current parcipaon and parcipant
capture rates.
Expand curbside, mulfamily, and
small commercial recycling access
through local government needs
assessment requests
CAA funding and support of local government requests for new collecon infrastructure
should result in the collecon of addional plascs. Projected tons are dicult to esmate
without more data on the number of generators who will receive new service, their
generated tonnage, and ancipated parcipaon and parcipant capture rates.
Enhance collected material mix in
local programs to meet USCL
requirements
As collecon programs add new plasc materials to meet the USCL requirements, it should
result in more plasc tons. A rough projecon for new polyproplyene collecon alone is
about 1,400 tons/year.
Implement PRO Depots that collect
specic plascs
CAA (and potenally addional PROs) will collect a range of plasc materials at new and
exisng depots. A preliminary esmate of new plascs collecon is 3,840 tons/year.
Table 12
In summary, CAA has provided in this section a preliminary calculation of the baseline generation and recycling tonnage
subject to 2028 plastic recycling rate target in Oregon and has identified the plan elements that will help achieve the target.
Implementation of the plan will provide new data that will allow CAA to adjust its strategies. CAA will continue to engage
DEQ in the search for better data and estimates of plastics generation and recycling as well as continue to seek DEQ
guidance on what materials are subject to the recycling goal calculations.
vi. Ensuring Responsible End Markets
CAA will ensure that covered products and contaminants collected with covered products are managed and disposed of in a
manner that aligns with Objective 1 of the program plan (Reduce the negative environmental, social, and health impacts
from the end-of-life management of products and packaging).
An important component of this management strategy is the transfer of such materials to responsible end markets (REMs).
Example End Markets
Based on discussions with CRPFs, CAA anticipates that most covered products collected for recycling under the RMA
program will be processed in North America, with the exception of:
Mixed paper
Aseptic and gable top cartons (a mix of North American and overseas markets)
Expanded polystyrene protective packaging (block white EPS)
Based on industry knowledge, CAA team expertise, and discussions with CRPFs, an initial assessment of the entities that
could potentially use materials collected in Oregon range between 130 and 150 entities, excluding plastic converters.
Examples include:
OCC and Mixed Paper: NORPAC, Pratt Industries
HDPE: Denton Plastics
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Mixed Plastics: Merlin Plastics, EFS-Plastics
Cartons: Sustana Fiber, Great Lakes Tissue
Glass: Glass to Glass
Polystyrene: Nepco
For commodities processed overseas (e.g., mixed paper), CAA will work in close collaboration with material brokers to
ensure its obligation under ORS 459A.860 to 459A.97. For example, CAA will assist in getting the self-attestation forms from
brokers’ clients.
Verification of REMs
CAA has developed end market verification processes for jurisdictions where it has been designated as a PRO (Colorado,
California). CAA’s verification approach was designed based on the principles of the International Organization for
Standardization’s Guidelines for auditing management systems (ISO 19 011) with input from the expertise of PROs active in
other jurisdictions with similar REM verification requirements (including European PROs). CAA’s verification approach is a
three-step process (see table below):
1. Initial screening
2. Reporting review
3. Entities verification
Verification bodies will be contracted by CAA to undertake the audit step. They will be selected based on several criteria,
such as:
Capacity to perform overseas audits (e.g., the verification body has local offices or agents in targeted overseas
market) as well as North Americans audits
Experience in chain of custody verification
Experience in waste management
Experience in health and safety
Existence of policy for prevention of conflict of interests
Compliance to ISO 17065 (Conformity Assessment – Requirements for Bodies Certifying Products, Processes and
Services)
Possesses professional liability insurance
A proposal of standards to use to measure REM compliance
Cost of services
CAA will also rely on DEQ endorsement of verification programs.
CAA will also contract only with certification bodies that fulfill the requirements of ISO 17065 (Conformity Assessment –
Requirements for Bodies Certifying Products, Processes and Services).
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Vericaon Acon
When
Who
Purpose
Inial screening
Immediately for each
unveried end market
CAA and CRPFs
(collaboraon)
• Obtain self-aestaon form
• Pre-approve markets
Reporng review
Quarterly
CAA
• Detect any reporng anomalies
• Calculate yield
Enes vericaon
Annually
Vericaon bodies
contracted by CAA
• Verify compliance with REM
standards
Table 13
The verification will also include a material tracking component, ensured by:
A Material Flow Management System that will be made available to the different stakeholders of the supply chain for
their reporting obligation under the regulation (e.g. CRPFs quarterly disposition reports) and will ensure data
confidentiality is preserved
A random bale tracking process, connected to the material flow management system
An agreement with brokers that will voluntarily collaborate with CAA to ensure they will provide the required
information for verification
Figure 4. Infographic visual aid depicting the proposed Material Flow Management System.
Verification Sampling Plan
Not all entities will be verified every year. By July 1, 2027, all entities will have been verified at least once. The CAA on-site
audit cycle will be performed on a five-year cycle, with every entity verified on-site every five years after the first on-site
verification. In the interim, desk audits (review of documentation) will be performed.
CAA will determine the sites to be verified based on the following criteria:
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Tonnage received: larger tonnage will be prioritized
Previous verification: sites that have not been previously audited will be prioritized
Risk of non-compliance: overseas end markets and entities for which CAA has received information related to
potential non-compliance spotted in the quarterly reporting review will be prioritized
Compliance with other verification process: entities already participating in other certification (e.g. recycled content)
or verification programs (e.g. food grade quality control) will not be prioritized if stakeholders share relevant
information and if that information allows CAA to verify compliance against REM standards
Specific Verification Approach by REM Standard
Verification of compliance to laws and regulations: For each end market, the verification process will make sure to
list any local, state, and national laws and international treaties applicable to the entity. This work will be undertaken
by the verification body(ies) retained by CAA. Based on this assessment, the verification body(ies) will inform CAA of
its strategy to measure compliance to laws and regulations. At a minimum, CAA can expect the verification body(ies)
to review operating permits of the entities.
Verification of chain of custody: CAA will use an internal system to enable continuous material tracking throughout
the value chain (material flow management system). The detail of how the system will work is presented below. The
audit process includes an audit initiation and preparation phase between the verification body and the entity verified,
in which the paper trails related to chain of custody (e.g. purchase orders, processing information such as conversion
factors, production and stock records, sales orders, inventory balance) will be reviewed. On-site audits will review the
chain of custody documents for specific loads. Finally, CAA will use random bale tracking, as described in the section
below.
Verification of environmental compliance: For each end market, the verification body will list the applicable laws and
regulations. It will also request any relevant information during the audit initiation and preparation phase, such as
environmental procedures or the existence of an environmental management system (EMS). Based on this
assessment, the verification body(ies) will inform CAA of its strategy to measure environmental compliance. At a
minimum, CAA can expect the verification body(ies) to review operating permits of the entities and to document
plastic leakage during on-
site visits.
Verification of recycling yield: CAA will provide access to the material flow management system to the verification
body(ies) in order to measure and verify yield compliance.
Investigating Non-Compliance
For each entity audited, the verification bodies contracted by CAA will provide an audit report that will clearly state:
If the end market entity passes or fails each of the REM standards, and the rationale for each potential fail
If the end market entity can be deemed responsible or not (if it is not deemed responsible, the report will list steps
that would be required to bring it into compliance)
The report will not contain detailed information about the entity for confidentiality purposes.
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Instances of non-compliance are most likely to be reported to CAA during the verification process, by the chosen
verification body. Once CAA is informed, representatives will review the non-compliance finding with the verification body
and the entity in question at the earliest reasonable date following the initial finding. The investigation will help to
determine if the entity is confirmed to be non-compliant, the level of severity of the infraction, and the appropriate course
of action as described in the section below.
DEQ will receive the verification report and will be informed of any entity that is not compliant after CAA’s review process.
Actions to Address Non-Compliance
The verification report will clearly state if the end market entity can be deemed responsible or not and, if not, steps that
would be required to bring it into compliance. CAA will provide non-compliant entities with this information along with
guidance to support corrective action. The verification body will classify potential non-compliance according to the severity
of the infraction: Based on ISO 19 011, CAA will classify non-compliance into three categories of severity:
Minor non-compliance
Major non-compliance
Disqualification non-compliance
In collaboration with the Verification Body, CAA will define the rules and criteria to classify non-compliances in the
appropriate category. Entities with minor and major non-compliances will have the opportunity to take corrective action of
the situation in a defined period of time. Entities with disqualification non-compliance will not have that opportunity.
Entities with minor compliance could be considered a REM during the time they are taking corrective action.
Requests for Temporary Variance in Verification
CAA requests temporary variance from the required components of a verification under the following conditions:
1. When another PRO has already approved the end market and deemed it responsible
a. Other PROs periodically verify the end market on its performance (e.g. recycling yield) and
compliance to their jurisdiction’s requirements or the PRO’s policy. For example:
i. LDPE recyclers in North America that process materials from the agricultural sector may be
audited by Clean Farms, a Canadian PRO for agricultural products
ii. Paper mills in Asia may be audited by Valipac, a Belgian PRO for packaging material, in
compliance with the Waste Shipment Directive Regulation
b. CAA requests variance instances for when an entity can prove, with evidence, it has been audited by
a recognized PRO within the last three years and can provide a self-attestation of its compliance to
REM standards under the RMA
c. If an entity can only prove compliance against certain but not all REM standards (e.g. environmental
compliance), CAA will undertake the verification against the missing REM standards
2. When an end market entity already has certification requiring verification (e.g. recycled content, food grade)
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a. Several entities are already engaged in different certification schemes, such as recycler certifications
(e.g. EuCertPlast, FDA LNO) or recycled content certifications (e.g. SCS, ISCC+)
b. The rationale is similar to what is detailed above for cases when there is verification from another
PRO program.
c. CAA requests variance when an entity can prove, with evidence, it has been audited by a recognized
certification scheme within the last three years and can provide a self-attestation of its compliance
to REM standards under the RMA
i. If an entity can only prove compliance against certain but not all REM standards (e.g.
environmental compliance), CAA will undertake the verification against the missing REM
standards
3. Domestic landfills will be deemed responsible, unless CAA receives information on potential noncompliance
a. Landfills and disposal sites in U.S. and Canada are already verified and controlled periodically by local
environmental agencies
b. CAA requests variance for landfill or disposal sites in the U.S. and in Canada, as soon as they provide
an operating permit delivered by the local authority. Verification might be performed if information
regarding potential noncompliance is provided to CAA
Tracking Material Flows
CAA is developing an internal material flow management system to enable continuous material tracking throughout the
value chain. The material flow management system is a cloud-based platform that provides the following services, among
other capabilities to be determined:
Collect and store integral data from external service provider partners, from haulers to end markets, including loads
and weights of materials received, processed and shipped out, inbound and outbound data, and information on
stakeholder process and environmental compliance. The system will provide “track and trace” functionality with the
ability to securely receive transaction data through system-to-system data exchange, file upload, or secure web-based
data entry
Protect confidential data. The platform will implement data security measures that meet the highest security
standards, including native encryption of all data, real-time event monitoring, field-level monitoring and audit trails,
and field-level data sensitivity
Ensure independent verification. Data and disposition reporting will be tracked and maintained in a manner that can
easily be made available for auditing by authorized external parties
Report information to stakeholders for accountability through the secure-access stakeholder portal
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Figure 5. Infographic depicting the fate and transport of different materials from collection through to disposition.
Accounting For Disposition and Yield
CAA will implement measures to account for end market variance in disposition and yield when obligated materials from
Oregon mix with non-obligated materials from elsewhere.
CAA will use one of the following chain of custody model defined by ISO 22095:2020
Controlled blending model
Mass balance model with rolling average percentage method
The controlled blending model will be used when an entity is using materials from Oregon mixed with other sources in a
batch production. ISO 22095 requires that the ratio between Oregon and non-Oregon materials is known for all outputs, at
all times, for a contained volume (see figure below). This model will be limited in its application as most of the recycling
industry does not utilize batch production.
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Figure 6. Controlled blending model example from ISO 22095.
The mass balance model with rolling average percentage method will be used for continuous processes. This is the method
most commonly used in the recycling industry, including for mechanical recycling of plastic. The model as defined by ISO
22095 requires calculating an average percentage of Oregon and non-Oregon materials for each output. It also requires
claim period. CAA defines those boundaries as follows:
Single site only (no multiple sites possible)
Average to be calculated at most quarterly and annually
Characteristic to be used: Oregon source vs non-Oregon source
Auditing the Verification Program
CAA plans to take a number of steps to ensure a reliable and high-performing REM system.
CAA will select verification bodies that are compliant with ISO 17065 (Conformity Assessment – Requirements for Bodies
Certifying Products, Processes and Services). This will give CAA the confidence that the REM verification process will be
undertaken with professionalism, ethics and neutrality.
CAA’s verification program is based on ISO 19011 standards. For the verification to be performed efficiently, the verification
body usually guarantees the confidentiality of the information shared, providing a report that only states if the entity
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passes or fails compliance against the requirements. Nevertheless, whenever possible, CAA reserves the right to carry out
spot checks of the verification work. For instance, CAA representatives may accompany the verification body randomly on-
site visits or take other steps to audit the verification process. It may also spot check certain documents that can be made
available to CAA.
CAA’s verification approach includes a reporting review step, to be performed quarterly, to verify different data sources. An
example would be spot bale audits or comparing a CRPF’s outbound weight with the inbound information from a
corresponding end market. Verification will be performed on 100% of outbound tonnage from CRPFs and PRO depots, with
the exclusion of the de minimis level from DEQ.
Random Bale Auditing
To complete the robust chain of custody control through the material flow management system, CAA will randomly audit
the journey of materials through the recycling system. Two types of random tracking will be performed:
Tracking from the curbside, to determine if household packaging ultimately ends up in a commodity bale or in landfill.
As part of this effort, CAA will work with CRPFs to coordinate with their measurement of material capture rates to
meet standards set in rule
Tracking from the CRPF, to determine the fate of loads of specific material managed by brokers
The approach to tracking from CRPFs will be informed by a risk analysis that will be evaluated according to several criteria,
including but not limited to:
Shipment destination: Bales more likely to be sent to overseas markets will be prioritized
Number of entities handling material: Bales handled by the highest number of entities (i.e. different brokers) will be
prioritized
Past audit results: Bales most likely to be sent to recyclers whose audit results have demonstrated minor or major
non-conformance compliance on chain of custody documentation will be prioritized
Number of end markets: Bales that do not have a high number of responsible end markets will
be prioritized
Based on initial assessments of the criteria the above, CAA will likely prioritize the random tracking of the following
commodities:
Mixed paper (grade 54)
Cartons (grade 52)
CAA envisions using up to 33 trackers per year:
Eight for material collected at the curb (one for each of the eight CRPFs expected to be part of the program)
Up to 20 for mixed paper bales (one for each potential broker)
Up to five for cartons bales (one for each potential broker)
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CAA will undertake the work to affix the tracker devices at the curb or in the bales according to a schedule to be defined.
CAA will then verify:
If products end up in landfill before or after the CRPF process
If loads and bales are compliant with the shipment documents, informing DEQ of any form of non-compliance
CAA is currently working with different tracking device providers to select the best device, both for overall tracking integrity
and to help prevent any potential risks around recycling safety.
Supporting Responsible End Markets
CAA’s proposed budget includes a dedicated fund for end market development initiatives. The fund will be financed
through producer fees and be approximately 3-5% of expected commodity values.
Following internal pre-assessment of existing markets, CAA has identified several commodities expected to require market
improvement to satisfy RMA requirements for REMs. CAA does not currently anticipate a need for market improvement for
commodities that are not specifically listed below:
Mixed paper (grade 54)
Cartons (grade 52)
Glass
Mixed plastics
Flexible PE plastics
Polystyrene
PET thermoforms
CAA will maintain active market development programs for commodities and materials listed above and will take
reasonable and practicable steps to facilitate the sale of collected materials to responsible end markets. CAA’s ability to
facilitate the flow of materials to responsible end markets is predicated by the voluntary agreement of those entities that
control the flow of those materials. Actions to support REM development may include:
Providing technical assistance, brokerage services, and/or information on responsible end markets to materials
marketers
Purchasing and reselling materials that otherwise are not being sold to responsible end markets (under certain
conditions)
Providing wherever possible a supply guarantee to reclaimers so they can secure investments. CAA will focus on taking
ownership of commodities lacking end markets
Working in close collaboration with existing investors and market development program managers, such as The
Recycling Partnership and Closed Loop Partners
Working in close collaboration with public sector market development programs, such as those in California and
Washington
Assessing leverage to promote recycled content in products to pull market demand
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Specific actions/strategy will be developed for each commodity/material during the program plan review period and will be
included in the revised program plan submission.
Producer Exemptions Under 459A.869 (13)
Under the RMA, producers can demonstrate that certain products are exempt from covered product requirements when
those materials are not collected under an Opportunity to Recycle program, are not separated from other materials at a
commingled recycling processing facility, and are recycled at a responsible end market.
Although demonstrating conformity with 459A.869 (13) is not a formal PRO obligation, CAA will work with producers and
recyclers where applicable to ensure that materials collected in relation to this potential covered product exemption are
being recycled at REMs. This may include additional tracking and reporting requirements administered by CAA.
Responsible End Market Development Guiding Principles
The planned responsible end market development program will be guided by four key principles:
1. Partnership. CAA will undertake investments in market development activities in partnership, where possible,
with other parties (e.g. the private sector, local governments, and state and federal interests)
2. Link to targets. CAA’s market development investments will be linked to material specific targets. The emphasis
will be on market development opportunities that support end markets for targeted materials at the lowest
overall cost
3. No cross-subsidization. CAA, wherever possible, will avoid cross-subsidization of material specific market
development. For example, glass producers will be responsible for funding glass market development activities
that are approved by the CAA Board. Where investments benefit a range of materials, costs will be allocated
across all benefiting materials
4. Competitive proposals. Where feasible, CAA will implement a request for proposal/competitive bid process for
allocating market development funds. CAA will identify its market development priority areas and will invite
interested parties to submit proposals to meet CAA’s requirements at the lowest cost. The final decisions
regarding market development investments will rest with the CAA Board
Furthermore, CAA has defined a series of principles under which it will take practicable actions to ensure the integrity of
REMs:
CAA will take actions according to type of non-conformance (e.g. CAA will not take action for disqualification non-
conformance)
CAA will take practicable actions in priority at North American entities and will limit its actions overseas
CAA may consider financial levers under specific considerations, in the form of financial de-risking measures
CAA will not take actions if:
o Other REMs already exist for the relevant material
o The entity processes a low volume from Oregon
o The entity is not financially stable
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vii. Upholding Oregon’s Materials Management Hierarchy
CAA will uphold Oregon’s materials management hierarchy, specifically with regard to the third principle: recycle material
that cannot be reused, with preference given to recycling pathways, methods and responsible end markets that result in
the greatest reduction of net negative impacts on human well-being and environmental health.
CAA has identified the previously named end markets as representing the highest and best use of their respective materials
because they represent the lowest environmental impacts of all end markets analyzed by DEQ LCAs.
Material-Specific Strategies
Based on existing information and on DEQ analysis for specific end markets, glass, cartons and polystyrene require unique
materials management strategies. CAA will work on selecting specific end markets for each of those materials, and the
organization may compare the solutions through an LCA that follows ISO 14040 Standard (LCA principles and framework) to
identify those with the better environmental outcomes.
Strategy for Glass
Glass will have to be processed by a glass beneficiation plant before it is sent to the final user. However, the capacities of
the accessible beneficiation plants in Oregon or nearby states are limited. Therefore, CAA will support the development of
production capacity to diversify potential markets for recovered glass, through supply agreements.
For instance, CAA could offer long-term glass volume assurance to help de-risk the investment in a glass processing facility
designed to process depot glass. This facility could supply the traditional glass container and fiberglass manufacturing
markets, as well as other markets, such as abrasives, water filtration media, and pozzolan. An LCA may be performed
according to the targeted end markets.
In the short term, considering the current lack of processing capacities, CAA will continue to explore end markets that can
use glass in aggregate form, such as road bedding or ornamental mulch, comparing them with other options while taking
into consideration the materials management hierarchy).
Strategy for Cartons
CAA will work in close collaboration with the Carton Council to partner with specific end market entities that are involved in
pulping activities, such as tissue production, notably in North America (e.g. Kimberly-Clark de México, S.A.B. de C.V.,
Sustana Fibers, and Tissue Depot formerly known as Great Lakes Tissue).
Strategy for Polystyrene
In accordance with DEQ’s LCA on polystyrene, CAA will prioritize end markets that utilize mechanical recycling over non-
mechanical recycling.
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d. Education and Outreach
In this subsection of the plan, CAA details how it plans to conduct education and outreach activities in support of USCL and
PRO Recycling Acceptance list materials, as well as the statewide promotional campaign.
Due to the nature and timing of start-up activities required for education and outreach (previously an interim coordination
task), CAA has integrated the requirements for that activity within this section. CAA and its partners plan to consult with
local governments and their service providers, ORSAC, DEQ, and community-based organizations to garner feedback
throughout the development of educational materials and plan formulation process.
i. Goals for Education and Outreach
1. Effectively build widespread recycling awareness among all Oregon waste generators in the scope of the RMA,
including residents living in single-family homes and multifamily communities, as well as commercial businesses,
institutions, and non-governmental organizations. Awareness efforts will leave these waste generators with:
a. An understanding of the Uniform Statewide Collection List, highlighting recent revisions to the list
and an understanding of the PRO-Depot collection list, with an emphasis on newly added or
removed items
b. An awareness of SIMs and how residents, municipalities, and counties will interact with these
materials
c. Knowledge of which materials will be collected at curbside versus which materials will be handled at
depot drop-off points
d. Access to information about the location of depots and instructions for how to properly prepare
materials for drop-off at those locations
2. Develop educational materials that are culturally responsive to diverse audiences across this state, including
people who speak languages other than English and people with disabilities
3. Deliver support and messaging proven to effectively increase participation and capture of recyclables. The
education and outreach will contribute substantially to the established goal for increasing the plastics recycling
rate (25% by 2028, 50% by 2040, and 70% by 2050), thereby contributing to the RMA’s goal of maximizing the
use of existing infrastructure
4. Include a systematic focus on and complement programmatic efforts to reduce contamination of recyclable
material streams
Accomplishment of these education and outreach goals ladder up to the overall program plan goals, in particular Objective
3 (improve public participation, understanding, and equity in the recycling system) and Objective 2 (increase the diversion
of recyclable materials from disposal).
CAA proposes to conduct annual assessments to measure effectiveness of the campaigns and progress toward the goals
outlined above.
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ii. CAA’s Education and Outreach Plan
CAA and partners, in consultation with ORSAC, will develop educational resources and promotional campaigns to promote
the USCL, as well as depot recycling programs. CAA will coordinate and fund the distribution of education and outreach
materials through statewide promotional campaigns following the first establishment of the USCL and after each revision of
the USCL, but not more frequently than once per calendar year.
Supporting Widespread Awareness and Understanding
This section outlines CAA’s proposed approach to building widespread consumer awareness and understanding of the USCL,
the depot recycling network and other recycling services available to them.
Audience Research
The target audiences for education and outreach efforts under the RMA are described broadly below. Residential audiences
can be further segmented by demographic characteristics. A keystone workstream will be to complete in-depth audience
research to effectively develop and deploy messaging that resonates with each group.
Single-family household residents
Multifamily households residents
o Multifamily property management
Residents that will utilize drop-off/depots
Commercial businesses, institutions, and non-governmental organizations
Audience research will consist of the following activities:
Statewide Quantitative Survey: Gather attitudes, perceptions and opinions on current recycling practices, and the
current system including understanding and satisfaction
Qualitative Interviews:
o Explore knowledge and attitudes surrounding the recycling of certain materials
o Identify gaps in recycling knowledge and points of confusion
o Gather feedback on concepts/messaging in terms of relevance and motivation
o Research to be conducted in English, Spanish, Chinese, Korean, Arabic, Russian, Vietnamese,
and Ukrainian
Anticipated audience considerations include:
4.2 million residents, living across 1,642,451 households
120,704 employer establishments (single physical locations at which business is conducted or where services or
industrial operations are performed; companies or enterprises may consist of more than one establishment)
Translations and transcreations to the following language groups: Simplified Chinese, Traditional Chinese, Korean,
Arabic, Russian, Vietnamese and Ukrainian
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Responsive communications strategies to serve an increasingly diverse population
Accounting for gaps in rural vs. urban use of internet to access government services
An estimated 35% of Oregon’s recycling is generated by the commercial sector, thus substantial investment is needed
to effectively capture recyclables from this sector
Developing Messaging
Leveraging key insights from behavioral science research and best practices in motivational messaging for effective
outreach, CAA and its partners propose to develop key messages tailored to different audiences in Oregon, which will likely
include Portland Metro Region, communities outside of the Metro region with more than 4,000 residents, and rural
communities.
Messaging Best Practices
CAA proposes to leverage proven best practices in motivational messaging to build participant confidence, improve
recycling behaviors among residents, and increase capture of recyclable materials. Motivational messages will be paired
with instructional messaging, tailored to target audiences. Key messages that will be communicated to the public include
but are not limited to:
An explanation of the USCL
An explanation of recycling services, including depots and how to sign up for/access services
Accepted materials vs. not accepted materials
Instructions for preparing materials for recycling
Information on the importance of not placing contaminants in curbside recycling bins and carts
Key messages will be clear and free of jargon
Consultation and Testing
Campaign messaging may incorporate the best practices described above but should be tested and refined to ensure local
relevance and cultural sensitivity. CAA proposes to evaluate and adjust its messaging based on a statewide quantitative
survey, focus groups, and consultation with Oregon recycling program staff local CBOs.
Change Management
As the RMA is implemented, there will be differing changes to accepted materials lists across the state, and education and
outreach will play a critical role in alleviating the burden and confusion of these changes on key audiences. For instance, as
infrastructure and responsible end market development goals are met, the USCL and depot recycling lists may evolve.
Additionally, some communities may be exempt from implementing the USCL on the effective date and will come into
compliance over time.
Importantly, the effects of these changes may be experienced unevenly across the state. For some communities, updates to
the USCL could create feelings that materials are being taken away, and for others, it will be clear that materials are being
added. The overall communications strategy must account for the implications of these perceptions.
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Material-Specific Considerations
Message development will account for the considerations identified in the Materials Strategy section above with regard to
SIMs to the fullest extent possible.
For plastics in particular, the expectation is that the majority of resin types, with perhaps the exception of plastic films and
expanded polystyrene (not collected curbside), may end up in curbside containers. All efforts will be made through
education and outreach to limit contaminants and contamination, and advance collection of all plastics through the depot
network where appropriate.
Delivering Messaging
CAA and partners propose adopting the following best management practices, where appropriate, for delivering
communications and messaging to effectively capture attention and motivate appropriate recycling behaviors. Effective
strategies will vary depending on the target audience, and are grouped as such:
General Best Practices:
Behavioral research has not found general “awareness” campaigns to be effective in driving behavior change to
increase recycling. Beyond ensuring that residents are aware of recycling in their community, efforts should focus on
why and how to recycle
To capture resident attention and motivate appropriate recycling behaviors, information should be provided to the
resident close to where the behavior will occur – most likely, at home. This is what makes direct mailing effective as
well as equitable in reaching communities with lower internet accessibility rates
Recent research suggests that information should only include up to five categories of accepted and unaccepted
materials with images and clear language – any more is overwhelming to the resident. CAA will develop a strategy for
clearly and succinctly communicating the USCL to customers, while ensuring that they also have access to detail
guidance where needed
Residents need to make the choice to recycle each day, which requires sustained effort. At least one annual mailer is a
best practice as a minimum level of recycling education
A dedicated recycling landing page on local government websites with relevant recycling information for all user
groups is a strong step to help funnel searches from residents looking for information online
All information should be presented using clear language.
Direct mailings with a top issue (one item that is a top contaminant) are helpful in reducing contamination, especially
when paired with cart tags
Recycling messaging delivered by multiple mailers has been observed to significantly increase recycling participation
in one pilot study
Ongoing research findings imply that multiple interventions (e.g. mailers AND cart tags AND in-person outreach) may
be required to meaningfully increase recycling
Delivering messaging by cart tag is memorable and has proven effective at increasing recycling tons in several pilot
studies
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Multifamily Recommendations:
When working with multifamily properties, education and support needs to be provided to residents and property
managers. Materials should be written with both audiences in mind, with separate pieces for managers and residents
Property managers need to be provided with information on regulations, best practices for recycling, how to set up
recycling at the property, and resources to educate residents about how to recycle properly
In-unit recycling bins or totes are a promising strategy for increasing multifamily resident participation, but further
research is needed to understand the impact of this tool
Signs posted near or on recycling containers can help to increase the clarity of what is accepted in the recycling
stream. Portland’s free signs are a great example of a helpful tool
Behavioral scientists recommend introducing new concepts at points of change in people’s
lives – such as a move. A move-in packet that includes recycling information is a helpful tool for
new residents
PRO Depot/Drop-Off Recommendations:
CAA and its partners will ensure that in conjunction with messaging aimed at building awareness of the USCL, educational
collateral and the statewide campaign will promote the depot network, including site locations and instructions for
preparing materials. In addition, once customers arrive at the depot, it is important that they are provided with clear
guidance and instructions.
Clear signage at the drop-off location (both on containers and at the facility entrance) can help drive correct behavior
Specific messaging provided around confusing and hard-to-recycle materials, such as film, will help residents correctly
sort their recyclables
A single-issue postcard can be used to highlight materials that are common contaminants
“Oops” tag handouts can be given to all patrons on-site, not just those bringing contamination
Person to person engagement on-site will help residents understand what to recycle and that recycling exists at the
site
Recommendations for Commercial Businesses, Institutions, and Non-Governmental Organizations:
Create technical assistance resources to help businesses throughout the state, especially outside of the Portland
Metro area to:
o Recycle covered materials
o Ensure internal collection bins
o Establish guidelines and a minimum recycling service standard for recycling service by
business type
Make recycling signs and instructions available to businesses
o Create recycling sign portal with downloadable signs, or available for order and mailed to the business
o All signs should clearly identify recyclable materials in no more than five categories and include the top five
common contaminates in a “no” category
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Ensure Recycling is convenient for employees to access. Co-location of recycling and garbage containers is the most
convenient setup within a business, both inside the businesses and for external containers
Tailor messaging and support provided to businesses depending on size and generator type. Each of these generator
types face different barriers to recycling, have different recycling systems in place and generate different types of
recyclable materials:
o Institutions: healthcare, university, schools
o Franchise and chain businesses
o Independent small businesses
o Restaurants, retail and manufacturing
Developing Educational Materials
CAA will fund and coordinate the development of the following educational resources, which will communicate:
Materials identified for recycling as described in the USCL.
Requirements to properly prepare materials for recycling
The importance of not placing contaminants in commingled recycling collection
Information about depot recycling, including locations and instructions for preparing materials for drop-off
Educational Materials for Local Governments and Service Providers
Educational materials will be made available in digital and print formats for local governments. Materials will be translated
and transcreated into Spanish, Simplified Chinese, Traditional Chinese, Korean, Arabic, Russian, Vietnamese and Ukrainian.
Materials will be developed and made available in an electronic format via an online portal to local governments and their
authorized service providers for customization to local conditions. Customization options will allow local governments to
easily adapt the materials below to communicate their individualized phase-in timeline to their local public. Customization
is also necessary in allowing for adaptation as accepted materials lists change over time due to end market dynamics and
other factors.
Specific collateral will include:
Photos/illustrations of accepted items and photos/icons of key contaminants
Sample text for informative, motivational, and instructional messaging
Handouts and/or mailers, including postcards, brochures, full-page flyers, door hangers, and magnets
Social media toolkits and digital media materials
Signage for depots, commercial and multifamily recycling enclosures
Decals for roll carts
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Plans for an Online Portal
CAA proposes to provide an online portal for local governments and their designated service providers (and any other
entities such as commercial businesses, if planned) to easily access, customize, print and mail educational collateral at no
cost.
Users of the portal would be able to:
Access templates for the various educational materials listed above that has been strategically designed based on best
practices to effectively deliver recycling messaging
Accommodate educational materials for relevance to different types of recycling programs, especially curbside pick-
up and drop-off programs
Produce coordinated educational materials that is thematically aligned for cohesive recycling education and outreach
across the state
Customize materials in seven additional non-English languages spoken in Oregon
Easily customize materials to reflect their local contact information
Customize materials to accommodate the different bin colors across programs
CAA has built support for local governments and designated service providers in the utilization of the portal into its staffing
plans.
Communicating Directly with the General Public
CAA will maintain a website for Oregon residents to learn about recycling by accessing information on the RMA, the USCL,
collection points and depots, and in-home recycling best practices. CAA will also explore opportunities to implement
responsive customer service tools via its website.
CAA will include messaging on its public-facing website that is aimed at building public confidence in the recycling system
and the RMA. Messaging will include information about the PRO’s requirement to ensure materials are transferred to
responsible end markets and its methodology for doing so. Additionally, CAA will make life cycle assessments conducted by
producers to meet obligations of the RMA accessible on this website and will accompany these postings with clear and
jargon-free explanatory language to ensure this information is accessible to all members of the public.
Additionally, CAA will provide material for local governments to include on their websites, allowing local governments to
include more detailed information about accepted and not accepted material. In this way, local governments will continue
to serve as a resource for residents that want to learn more about recycling in their locality.
iii. A Description of the Statewide Promotional Campaign
CAA and partners propose to employ a phased approach to the statewide campaign that will focus on (1) communicating
statewide changes to the recycling system in 2025 and introducing new resources, and (2) maintaining awareness
throughout 2026 and 2027, while driving increased participation and capture to meet goals set by the RMA.
Throughout both phases of the education and outreach plan, CAA and partners will be focused on delivering messaging and
collateral that builds awareness among Oregon residents and organizations and effectively introduces the USCL list. The
organization will leverage proven motivational, empathetic messaging in bold, bright colors that will appeal to recyclers
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who need more encouragement (based on our audience segmentation), pairing that outreach with detailed instructions for
customers to participate successfully in the new system.
Phase One/Year 1: Program Launch
Dates: Begins July 1, 2025, extending as recommended throughout the calendar year.
Phase Description: “Change is here!” Introduction of the USCL and depot recycling program. Getting the right information
to the right audiences to educate and encourage them to recycle and increase awareness.
Anticipated Channels: Meta, YouTube, display ads, streaming audio, radio, digital out of home, printed mailers/handouts
tailored to key audiences.
Key Insight: Based on 2023 pilots, display ads were a top source of impressions and clicks, driving website traffic at a
higher rate than the rest of the tactics and showed the highest click-through rate (CTR) of the channels. Display
average CTR is 800% higher than the average industry benchmarks, making this a great potential channel for Phase 1
Special Audience Considerations:
CAA proposes to explore the option of creating (not simply translating) an original Spanish language campaign that would
parallel the English statewide campaign
CAA recommends specific materials for multifamily/apartment complex management companies that will need to prepare
for and communicate changes to their residents.
Similarly, commercial businesses that offer office or public space recycling, should receive “change is coming”
messaging/packets and support for setting up new systems
Desired Outcomes:
Drive audiences to key PRO resources (i.e., the PRO’s website)
Increase awareness of new recycling guidelines, including both the USCL and depot network
Increase public confidence in Oregon’s recycling program
Begin to drive increased participation
Phase Two/Years 2 and 3: Continued Engagement Phase / Material-Specific Supports
Dates: January 2026 through December 2027
Phase Description: Deliver support to effectively engage frequent, infrequent, and non-participating audiences and achieve
increased capture of target materials. It is also possible that during these subsequent years, additional changes will be
made to the USCL and depot accepted material lists, and therefore elements of this phase will need to be focused on
communicating those changes and managing customer expectations.
Anticipated priority channels:
Leverage moments of change (e.g. recycling welcome kits for residents who fill out change of address forms)
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CBO partnerships, especially for equitable outreach
Ads: Google search, Meta, native, phone texts, YouTube, CTV/OTT (streaming TV)
Desired Outcomes:
Continue to drive audiences to key PRO resources (e.g., the PRO’s website)
Continue to build confidence in Oregon’s recycling program
Achieve increased participation in local recycling programs and PRO depots
Increase the capture of recyclable materials, with a focus on underperforming target materials
Campaign Applications and Channels
CAA proposes the following campaign, intended to be deployed in the phased approach described above:
o Advertising assets: Video, radio, banner, social, outdoor, print, search and community media ads.
o Recycling signage/decals for depots, enclosures and carts
o Print materials: Up to three brochures or full-page flyers as well as a mailer, cart tag and a door hanger
iv. A Culturally Responsive Approach
CAA will ensure that educational materials and campaigns are culturally responsive to diverse audiences across this state,
pursuant to ORS 459A.893(3). This includes, at a minimum:
Including people who speak languages other than English and people with disabilities
Ensuring materials are printed or produced in languages other than English and are accessed easily and at no cost to
local governments and users of the recycling system
Translation and Transcreation
CAA and its partners propose to translate and transcreate all education and outreach materials into those languages spoken
in Oregon by at least 1,000 people over the age of five who spoke English less than very well according to the most recent
American Community Survey.
In-language content will be transcreated, not simply translated. CAA and partners will engage linguists and multicultural
experts to ensure materials resonate with intended audiences by taking into account language, but also cultural relevancy.
For example, materials for different multicultural communities would be designed with images of recyclable items that are
most commonly found in the households of the community that is being targeted. CAA understands that under ORS
251.167, information on the most-commonly spoken languages in the state of Oregon and its counties is updated
periodically for the purpose of disseminating accessible information on voting to the public. CAA will use this information in
formulating and updating its plan to fulfill these accessibility requirements.
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Translations and transcreations include up to ten digital ads, recycling enclosure signs, three brochures or full-page flyers,
and up to three print designs (either for a postcard, mailer, door hanger or similar sized piece).
Co-Creation
Co-creation will be employed for development of campaign materials and multifamily outreach. Co-creation gives
community members a chance to participate in campaign design through community-level listening sessions to deepen
mutually beneficial relationships. Other connective strategies could be use of an advisory board, active liaisons, or
trusted advisors.
Accounting for Future Diversity
The U.S. Census Bureau considers Oregon among the states rapidly becoming more diverse with time. Any outreach plans
developed to educate and inform the public about recycling should strive to be responsive to future changes to Oregon
resident demographics.
Partnerships with Community-Based Organizations
To achieve an inclusive and equitable education and outreach program, CAA plans to engage community-based
organizations (CBOs) as advisors to its education and outreach efforts, as well as implementation partners.
Designed for Accessibility
Educational materials created for the campaigns will follow ADA compliance and best practices as well as the principles of
universal design, where products, services or environments are designed so that anyone – no matter their age or ability –
can use that design with minimal or no accommodations. Examples include:
Considering color blindness and legibility when selecting color palettes, fonts, text size and imagery. This could include
avoiding small print and reverse type and leveraging color blindness testing tools for designers
Ensuring all elements meet or exceed the Web Content Accessibility Guidelines 2.1 AA (WCAG) requirements
Building accessible features into electronic versions of collateral that are intended for the general public so they
include “alt text” for images and all copy and visuals are “screen reader ready”
Using plain language and using simple sentences with relevant examples
Making use of imagery, icons and other visuals rather than large blocks of text to more quickly and easily
communicate information and demonstrate processes
Providing materials in a range of formats to reach across digital access and literacy gaps (e.g. digital ads as well as
television, radio, print, and outdoor ads and offering detailed information via websites as well as printed mailers and
brochures)
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v. Schedule Including Proposed Timing of Start-up Approach
CAA and its partners propose to develop educational collateral and the subsequent implementation strategy of the
statewide promotional campaign in a deliberate and phased approach. In parallel, CAA anticipates working on a
second draft program plan submission for September 2024.
The visual timeline for this proposed implementation plan can be found in the preliminary program implementation
timeline featured in Appendix M.
April –
June 2024:
Quantitative survey of Oregon residents, analysis, and reporting of results and key findings
Develop campaign strategy based on survey results and existing best practices
Preliminary concepting for the campaign
Kick off engagement with CBOs and local governments to consult on strategy
Work with ORSAC to set a presentation schedule through July 1, 2025
Confirm the material approval schedule with OR DEQ through July 1, 2025.
Late-June 2024:
Proposed Activity: Consult with ORSAC Education and Outreach Committee to review and provide feedback on the
draft campaign concept prior to testing.
July-September 2024:
Conduct qualitative audience research to test the campaign concepts
Develop USCL instructions/communications strategy, including key terms
Local government review of USCL instructions/communications strategy, including key terms
Early- or mid-October 2024:
Proposed Activity: Detailed report on audience research and campaign concept recommendation presented to ORSAC,
with materials to be provided at least 2 weeks prior
October 2024 – January 2025
Conduct qualitative audience testing to inform transcreation of outreach materials
Produce batch 1 materials (those required for Feb 1 distribution): USCL guide, cart label, style guide, messaging
timeline, newsletter article, web domain/QR code
Local governments to review batch 1 materials over two 2-week periods
Initial drafting of batch 2 materials (those required for April 1 distribution): Social toolkit, press release, newsletter
article, website with 'change is coming' messaging, print materials - USCL mailer/poster, postcard, bill insert,
depot/enclosure signage, available in agreed-upon languages
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Local governments to review batch 2 materials over two 2-week periods
Develop media planning strategy and establish hotsheet of advertising specifications
January 2025:
Proposed Activity: Present batch 1 materials to ORSAC
Submit batch 1 materials to DEQ for approval
Key Deliverables by February 1, 2025
The following guidance documents and editable design files will be available to local governments and service providers
for download:
1. Photos of all materials on the USCL, materials being removed from lists around the state, and contaminants of
concern, in both low and high resolution
2. An in-mold label graphic for roll carts
3. A style guide to help ensure residents experience a unified aesthetic and feel whenever and wherever they
receive recycling information in the state (see attached example of Metro Multifamily Decals and Signage
Playbook) that includes fonts, colors, as well as a vetted list of terms (e.g., when to use “bins” versus “carts,”
“recycling” vs “recyclable materials,” etc.) in agreed-upon languages
4. A recommended phased messaging timeline for local governments and service providers to adhere to
5. A Customizable newsletter-style article with “change-is-coming" messaging (i.e., change is coming July 1 and
why, look for more information in June)
6. A QR code to public-facing website with an identifiable and memorable domain name that local governments
and service providers can use to direct their residents/customers to more information
February – April 2025
Complete production of batch 2 materials for April 1 distribution.
Initial drafting of batch 3 materials (those required by June 1) - Website strategy, design, development and QC to have
live, updated with downloadable materials.
Initial production of batch 4 materials (those required by July 1) in English - Ad materials - video, radio, banner, social,
native, OOH, print, search.
Local governments to review batch 4 English materials over two 2-week periods
Upon approval of English materials, transcreated materials will be developed
PR planning, messaging and materials development (early milestone is 'change is coming' release)
Initiate business association outreach
Initiate mail house coordination
Design, build and test education and outreach electronic portal
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Key Deliverables by April 1, 2025
Electronic Portal launches by 4/1/25 to support outreach efforts conducted by local government and service providers. The
following materials will be available for download via electronic portal:
1. Social media toolkit with change-is-coming messaging in agreed-upon languages
2. Example and customizable brochure in agreed-upon languages that is simple, clear, and free of jargon that also
serves as mailer/poster and includes:
a. Basic preparation information (“empty and dry”)
b. Top 3-5 contaminants to keep out
c. Limited Yes/No poster that can be posted near receptacles and includes a QR code to the public-
facing website with comprehensive list of accepted items and contaminants
3. Additional example and customizable resources, including social media toolkit, newsletter, postcard, billing
insert, press release, available in agreed-upon languages, that deliver the following messages:
a. The system is changing July 1 and why
b. Benefits of the new system
c. How to participate—action steps
4. Example and customizable container stickers and depot/enclosure posters and signage in agreed-upon
languages, available in different sizes developed through consultation with local government
April – June:
Complete production of batch 3 materials for June 1 release.
Ongoing business association outreach
Ongoing mail house coordination
PR planning, messaging and materials development (early milestone is 'change is coming' release)
PR materials development (early milestone is 'change is coming' release).
Initiate media negotiation and coordination
Key Deliverables by June 1, 2025
The following print materials will be available for local governments and service providers to order for delivery by June 1,
available in different sizes developed through consultation with local governments in agreed-upon languages, made of
waterproof materials that are appropriate for indoor and outdoor use:
1. Signage for depots and commercial and multifamily recycling enclosures
2. Stickers for roll carts/containers
A live public-facing website with memorable domain name, populated with change-is-coming messaging will also be
available by June 1. Information posted to the site will explain/include the items below. Information will be
available/accessible in all agreed-upon languages:
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1. The Oregon recycling system is changing July 1, and why
2. The benefits of the new system
3. How to participate—action steps
4. A downloadable poster to hang near receptacles that includes:
a. Basic preparation information (“empty and dry”)
b. Limited Yes/No list
c. QR code to the website itself with comprehensive list of accepted items and contaminants
5. A complete Yes/No list for materials, closer to
https://www.oregon.gov/deq/recycling/Documents/rmaMatAccept.pdf, but using customer-friendly
terminology
6. Detailed preparation information and list of common contaminants
Key Deliverables by July 1, 2025
Formal campaign launch
All other USCL educational resources made available
2026-2027
Campaign continues as described in the campaign section of the education and outreach plan
vi. Relevant experience
Given its widespread reputation as a leader in recycling education, The Recycling Partnership has been a partner to CAA in
developing plans for the education and outreach aspects of the program plan. CAA will also consult with The Recycling
Partnership as a potential partner to execute the education and outreach plan. CAA believes the team tasked with
delivering this work needs to have:
Industry Knowledge – A deep understanding of the recycling and waste management sector, including knowledge of
current trends, challenges, and opportunities. The qualified firm will have considerable experience with deploying
recycling education and outreach campaigns that measurably improve the performance of recycling programs
Communication Expertise – Proven experience in developing comprehensive communication strategies that resonate
with diverse audiences. The firm will show demonstrated proficiency in utilizing various communication channels,
including traditional media, social media, and digital platforms
Stakeholder Engagement – Experience identifying and engaging with key stakeholders, including local governments
and recycling service providers. This experience should extend to building partnerships and collaborations to enhance
the reach and impact of campaigns
Campaign Development – Previous success in developing and implementing large-scale, statewide campaigns. The
goal is outreach that leverages creativity and innovation to craft compelling messages and materials that effectively
convey the campaign's goals
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A Data-driven Approach – Utilization of data and analytics to inform the development of materials and to measure
the success of outreach interventions
Cultural Sensitivity – Understanding of the cultural diversity within the state, ensuring that the campaign is inclusive
and resonates with various demographic groups
Adaptability – Flexibility to adapt strategies based on feedback, changing circumstances, and emerging trends
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Financing
a. Membership Fee Structure and Base Fee Rates
i. Product Speciation for the Fee Structure
CAA proposes a product speciation list of 62 materials, grouped by eight material categories as described below. This list
was developed based on our understanding of the RMA requirements, our experience with EPR programs in other
jurisdictions, and the USCL and PRO accepted material lists developed by DEQ as a part of rulemaking. We also considered
its potential for “nestability” with other EPR programs, such as California, to enable producer reporting synergies between
Oregon and other state programs.
Printing and Writing Paper
Newspapers
Newsprint (inserts and circulars)
Magazines, Catalogs and Directories
Paper for General Use
Other Printed Materials
Plastic – Rigid
PET (#1) - Bottles, Jugs and Jars (Clear/Natural)
PET (#1) - Bottles, Jugs and Jars (Pigmented/Color)
PET (#1) - Thermoformed Tubs
PET (#1) - Thermoformed Containers, Cups, Lids, Plates, Trays
PET (#1) - Tubs
PET (#1) - Other Rigid Items (including containers)
HDPE (#2) - Bottles, Jugs and Jars (Clear/Natural)
HDPE (#2) - Bottles, Jugs and Jars (Pigmented/Color)
HDPE (#2) - Pails and Buckets
HDPE (#2) - Tubs, Nursery (plant) pots and trays
HDPE (#2) - Package Handles, Lids
HDPE (#2) - Other Rigid Items (including containers)
PVC (#3) - Rigid Items
LDPE (#4) - Bottles, Jugs and Jars
LDPE (#4) - Lids
LDPE (#4) - Other Rigid Items
PP (#5) - Bottles, Jugs and Jars
PP (#5) - Thermoformed Containers, Cups, Plates, Trays (non-nursery (plant))
PP (#5) - Thermoformed Lids
PP (#5) - Thermoformed Tubs, Nursery (plant) Pots and Trays
PP (#5) - Lids
PP (#5) - Tubs, Pails and Buckets, Nursery (plant) Pots and Trays
PP (#5) - Other Rigid Items
PS (#6) Expanded/Foamed Hinged Containers, Plates, Cups, Tubs, Trays, and
Other Foamed Containers
PS (#6) White Expanded/Foamed Cushioning and Void Fill
PS (#6) Colored Expanded/Foamed Cushioning and Void Fill
PS (#6) Rigid Non-Expanded
PLA, PHA, PHB - Rigid Items
Other/Mixed Rigid Plastic
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Glass and Ceramics
Glass Bottles and Jars and Other Containers
Ceramic - All Forms
Metal
Aluminum Containers
Aluminum Foil and Molded Containers
Aluminum Aerosol Containers
Aluminum Other Forms
Steel Containers
Steel Aerosol Containers
Steel - Other Forms
Metal - Small Format
Pressurized Cylinders
Paper/Fiber
Aseptic and Gable-top Cartons
Kraft Paper
Corrugated Cardboard
Corrugated Cardboard (Tertiary/transport) Non-
consumer
Paperboard
Polycoated Paperboard
Other Paper Laminates
Other Paper Packaging
Paper - Small Format
Plastic – Flexible
HDPE (#2)/LDPE (#4) Flexible and Film Items
HDPE (#2)/LDPE (#4) (Pallet Wrap) non-consumer
PP (#5) Flexible and Film Items
PLA, PHA, PHB - Flexible and Film Items
Plastic Laminates and Other Flexible Plastic Packaging
Plastic – Other
Plastic - Small Format
Plastic containers for motor oil, antifreeze, or other
automotive fluids, pesticides or herbicides, or other
hazardous materials (flammable, corrosive, reactive,
toxic)
Wood and Other Organic Materials
Wood and Other Organic Materials
Table 14
ii. Development of the Base Fee Algorithm
In the fall of 2023, CAA began consultations with its Founding Members to develop a national fee-setting methodology to
be deployed to all EPR enacted states. While the methodology development will continue in 2024, the Founding Members
developed a set of guiding principles to guide the development of the fees. The guiding principles underpinning the fee-
setting methodology are:
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CAA Fee-Setting Guiding Principles
1. Harmonization: Fee rates should be developed using a national fee-setting methodology
that is consistent across states unless state-specific laws or conditions require adjustments. Fee structures will
vary in each state due to state-specific inputs and statutory requirements.
2. Fairness: Producers supplying covered materials to end users must contribute to the costs of the
recycling system, including those who use materials not collected for recycling or are not recycled.
3. Material-Specific Costs: Fee rates will reflect material-specific management costs in each state using the
best available data.
4. Commodity Revenue: Fee rates will reflect state-specific commodity revenues, and these revenues
will be attributed to the corresponding material categories that earned them.
5. Ecomodulation: Fee-setting will account for measurable environmental objectives and state-mandated
ecomodulation policies using CAA’s ecomodulation principles (which are under development).
6. Responsible End Markets: Fee-setting will factor in the development and maintenance of viable
responsible markets with any associated costs borne by the material category and as required by state EPR laws.
7. Clarity: Fee-setting materials and consultations will be prepared and conducted in a manner that
clearly communicates to producers the principles, methodologies and approach that Circular Action Alliance is
using to determine fee rates.
These principles provide guidance for the development of a fair, transparent and effective fee allocation method for
producers. For covered materials that are neither collected nor recycled, producers will still incur fees to cover the cost of
the recycling system in accordance with the Fairness principle.
Interim Fee-Setting Methodology
As part of the fee-setting development process, CAA evaluated past and present frameworks used in other jurisdictions that
have implemented EPR for packaging and paper products. CAA arrived at an interim method to set the preliminary base
fees for the Oregon program plan submission. This methodology is considered interim because further fee-setting
considerations, such as the development of the graduated fee algorithm, will be advanced in subsequent program plan
amendments. Given the complexity of preparing producers for implementation of ecomodulation, CAA believes further
consultation will be required with stakeholders in light of DEQ’s proposed LCA impact rule concepts.
The interim fee method allocates the estimated material management costs to covered materials based on their share of
supply tons. This upholds the generally accepted “polluter pays principle” in EPR literature whereby materials with large
supply quantities pay for a large share of system costs. Material cost variation exists by incorporating material-specific
indices generated by an Oregon-based Activity-Based Costing model into the fee allocations. The indices represent the
varying costs that each material drives in the recycling system as it is being managed throughout the reverse supply chain
from collection to transfer and consolidation, and then transportation to processing facilities. These are used to
approximate the relative cost proportionality of covered materials managed in the program to avoid arbitrary cross-
subsidization outcomes and to ensure that the statute requirement under ORS 459A.884(3)(b) is satisfied.
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Program generated revenues are attributed to the materials that earned those revenues to reduce their share of material
management costs.
The base fee schedule will be updated annually at a minimum, to reflect changes to producer supply tons, system
operations and costs. The base fee schedule meets the state-mandated requirement under ORS 459A.884(3)(a), where the
average base fee rate for covered materials that are not accepted for recycling must pay higher average fees than those
materials that are accepted for recycling in Oregon.
Summary
The interim fee methodology ensures fairness for producers by differentiating material fees based on a material’s
supply, cost and revenue profiles
Materials with the highest supply quantities and management costs pay the highest share of costs
Materials generating the most commodity revenues benefit from the largest reduction to costs
Materials that are recycled at high rates do not pay a higher share of costs relative to lower performing materials. This
ensures that the core fee principles of Fairness, Material-Specific Costs and Commodity Revenues are upheld
Separate Allocations for USCL and PRO Recycling Acceptance List Materials
In the Oregon program, there are three separate groups of covered materials: USCL, PRO recycling acceptance list, and
materials not accepted for recycling. The first two groups have distinct management systems and funding obligations, e.g.
the PRO is obligated to fund the expansion of on-route collection of USCL materials but not the actual collection services of
USCL materials, whereas for materials on the PRO recycling acceptance list, the PRO must develop a depot network to
receive these materials and then transfer them to a sorting facility or end market. To avoid cross-subsidization of the fees
between these groups, the allocation of materials management costs is done within cost boundaries between these
material groups.
While materials not accepted for recycling do not incur actual material management costs, they contribute their portion of
fees based on their share of supply tons multiplied by cost indices of similar materials. Specifically Identified Materials
(SIMs) and other strategic materials targeted for investments are assigned investment costs directly based on their needs.
Metrics and Other Data Inputs Used to Set Fees
In developing the preliminary fees, CAA relied on estimates and data modeling of critical data inputs provided by CAA
project team members with expertise in this field. Once the Oregon program launches, CAA will use actual supply and
recycling data to inform fee-setting.
Allocation of Non-Material Management (Indirect) Costs
Non-material management costs include program operations and administration, program development and regulatory
costs. These costs have different cost drivers than material management costs and are often borne by all covered materials.
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As a result, these costs are allocated to materials using a consistent but different approach than material management
costs.
Flat Fees
In accordance with ORS 459A.884(6), CAA proposes tiered uniform fees for low volume producers with gross revenues of
less than $10m or covered materials sold for use in Oregon of less than 5 metric tons as follows:
Tiered Flat Fee Structure (for producers with gross revenues of at least $5m and up to $9.99999m)
Tier Based on Annual Supply Tons
Flat Fee (Base Case)
Flat Fee (High Case)
1 to 2.5 tons
$600
$800
Over 2.5 tons up to 4.99999 tons
$1,300
$1,700
Table 15
Publisher In-Kind in Lieu of Paying Fees (Print and Online Advertising)
In accordance with ORS 459A.884(7), CAA shall accept the value of print and online advertising services in lieu of all or a
portion of fees payable by newspaper or magazine publishers. Once the fees are determined, CAA will work with the
publishers to arrange for advertising products and services of similar value to offset CAA’s education and outreach
expenditures. The portion of fees payable in cash by publishers will be negotiated.
Confidentiality
As per OAR 340-090-0710(2) and with support from DEQ, CAA’s fee-setting methodology is considered proprietary and
confidential information. The detailed methodology will be included as part of a confidential addendum to the Program
Plan submission.
iii. Preliminary Base Fee Schedule Ranges
In advance of conducting the Oregon Recycling System Optimization Project, CAA developed a range of preliminary
program cost estimates to inform preliminary base fees for publication in the Program Plan. Presenting a range of
anticipated program costs is reasonable given the absence of program data and uncertainty with estimates at this early
stage.
The fee range was developed using a base case and high case scenario with the base case being conservative and the high
case reflecting potentially higher costs due to high variability and uncertainty of cost estimates. Once the Oregon program
launches, CAA will use actual program data to inform the program budget and resulting fees.
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Preliminary Base Fees (Material Category Level)
Program Year 2025
Base Case
High Case
Covered Material Category
Fee Rate
Revenue Budget $
Fee Rate
Revenue Budget $
Printing and Writing Paper
2.0 ¢/lb
$6,800,000
3.0 ¢/lb
$7,100,000
Paper/Fiber
6.0 ¢/lb
$35,100,000
11.0 ¢/lb
$45,000,000
Plastic - Rigid
24.0 ¢/lb
$48,900,000
43.0 ¢/lb
$61,300,000
Plastic - Flexible
37.0 ¢/lb
$118,300,000
71.0 ¢/lb
$158,900,000
Plastic - Other
27.0 ¢/lb
$2,600,000
49.0 ¢/lb
$3,300,000
Glass and Ceramics
14.0 ¢/lb
$9,200,000
24.0 ¢/lb
$11,000,000
Metal
8.0 ¢/lb
$2,900,000
13.0 ¢/lb
$3,300,000
Wood and Other Organic Materials
4.0 ¢/lb
$1,700,000
6.0 ¢/lb
$1,700,000
Total
15.0 ¢/lb
$226,000,000
26.0 ¢/lb
$292,000,000
Table 16
Given the preliminary nature of these fee estimates, CAA strongly advises against relying on these estimated fees to budget
producers’ compliance costs in Oregon. With the completion of the Oregon Recycling System Optimization Project, CAA will
be in an improved position to refine the fee range and likely expand the base fee schedule to reflect the proposed 62 fee
reporting categories in the second Program Plan submission.
A final fee schedule will be released once the Program Plan is approved and more accurate cost and supply data are
captured to replace estimates.
iv. Producer Fee Incentives, Other Than Graduated
Fee Adjustments
Oregon’s Recycling Modernization Act mandates that the average fee rate for covered materials that are not accepted for
recycling be higher than the average fee rate for covered materials that are accepted for recycling, as outlined in ORS
459A.884(3)(a). This statutory requirement is arguably a fee incentive that is implemented within the base fee structure,
outside of Graduated Fees.
v. Meeting the Statutory Requirement
In accordance with ORS 459A.884(3)(a), the preliminary base fees for both base and high scenarios satisfy the requirement
for the average base fees for covered material not accepted for recycling to be higher than the average base fees for
covered materials that are accepted for recycling in Oregon. These are shown in the table on the next page.
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Avg. Fee
Base Case
High Case
USCL
6 ¢/lb
10 ¢/lb
PRO
27 ¢/lb
50 ¢/lb
N/ A
31 ¢/lb
57 ¢/lb
15 ¢/lb
26 ¢/lb
Table 17
As the materials not accepted for recycling tend to be costlier to manage than USCL and PRO recycling acceptance list
materials, their resulting average fee rate is higher than that of materials that are accepted for recycling.
In addition, the fee methodology incorporates a discretionary state-adjustment factor to ensure that this condition is met.
It is activated only when the average fee of not accepted materials is lower than the average fees of accepted materials. To
satisfy the state-mandated condition, this factor shifts material management costs from the group of accepted materials to
non-accepted materials using the “goal seek”
12
function in Microsoft Excel, to generate a positive delta between the
average base fees of not accepted materials and accepted materials. Once transferred, the costs are allocated amongst the
non-accepted materials based on their material management cost proportions. Below are the calculation steps for the
state-adjustment factor:
1. One hundred percent of the material management costs are allocated by material specific supply tons using the
material cost indices generated from activity-based costing.  The non-material management costs are allocated
by the material management cost allocation ratio.
2. The average fees of accepted and not accepted material is calculated, as shown in the below table. If the
accepted material fee is lower than the not accepted material fee, then the requirement is met and no further
action is required.
3. However, if the accepted material fee is higher than the not accepted material fee, as in the below example
where the fee per ton for not accepted materials is at $88.98 and accepted material is at $103.24 (which is
lower by $14.26), then the requirement is not met.
4. In the next step an optimized percent (8%) of material management cost is assigned to not accepted materials
to make their fees higher than accepted materials. Excel goal seek function (Newton-Raphson method) is used
to calculate the optimized percent to create a positive difference between accepted and not accepted materials.
The remaining 92% of material management cost is allocated using the supply tons and material cost index.
5. The non-material management costs are allocated by the new material management cost allocation ratio after
the state-adjustment factor calculation.
6. The new fee per ton will meet the requirement as demonstrated in the tale below:
12
Technically known as the Newton-Raphson method.
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The numbers mentioned in the example are for illustrative purposes only.
Material Type
Average
Fee per Ton
Average Fee per Ton
with State-Adjustment
Factor
Accepted
$103.24
$95.10
Not Accepted
$88.98
$96.10
Difference
-$14.26
$1.00
Table 18
This factor and its application are designed so that:
Only the minimum required costs are redistributed from accepted materials to non-accepted materials to ensure
minimal cost impact on producers in the non-accepted group because they exert no control over whether their
materials are accepted or not, and
There is no need to determine arbitrary costs to assign onto non-accepted materials because the model algorithm will
calculate the minimum costs required to be transferred
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b. Graduated Fee Algorithm and Methods
i. The Algorithm and Accompanying Descriptive Text for the Proposed
Graduated Fee Structure
As per ORS 459A.875(2)(a)(F), the Oregon program shall encourage producers to make continual reductions in the
environmental and human health impacts of covered materials. This is to be administered through a graduated fee
structure as described in ORS 459A.884, that can be used to adjust fees for producers who make or have made impactful
changes to the ways in which they produce, use and market covered materials in Oregon. According to DEQ’s latest
“Guidance on Ecomodulated Fees,” while the law requires PRO(s) to consider at a minimum the five factors
13
listed in the
statute, it does not require any of those factors to be included in the fee schedule.
14
CAA fully supports the notion of developing a graduated fee structure to incentivize producers to
continually reduce environmental and human health impacts and commits to implementing a fee
methodology that meets these regulatory requirements.
As of the submission of this program plan, CAA does not have a specific eco-modulation proposal developed for review.
Given the challenges associated with implementing eco-modulation concepts (see below), CAA believes that eco-
modulation proposals should be sequenced in the following manner:
1. Interim voluntary eco-modulation options should be developed for producers for implementation as soon as
possible after the start of the program on July 1, 2025;
o CAA would propose developing the details of these interim or voluntary eco-modulation fee adjustments in
consultation with producers and other stakeholders to inform subsequent program plan amendments with
the goal of alignment on these fee adjustments prior to the start of the program.
2. Parallel to the development of interim voluntary eco-modulation options CAA, will work with producers and
other stakeholders to develop permanent membership fee incentives to reduce environmental outcomes. In
CAA’s view, in order to ensure the effectiveness of graduated fees to establish appropriate price signals that
balance action and fairness, CAA considers it imperative to allow adequate time to assess the potential impacts
of different approaches, criteria and the required underlying data. In addition, CAA believes that successful
implementation requires flexibility to consider how best to structure the graduated fees within the fee-setting
13
The five factors listed in 459A.884(4) are (a) The post-consumer content of the material, if the use of post-consumer content in the covered product is
not prohibited by federal law; (b) The product-to-package ratio; (c) The producer’s choice of material; (d) Life cycle environmental impacts, as
demonstrated by an evaluation performed in accordance with ORS 459A.944; and (e) The recycling rate of the material relative to the recycling rate of
other covered products.
14
DEQ (2024). Guidance on Ecomodulated Fees - Plastic Pollution and Recycling Modernization Act (SB 582, 2021), pg. 3.
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methodology, including appropriate linking of the level of impacts to the level of bonuses and penalties, the
timeframes for their application and the appropriate application within and possibly across material groups.
Challenges with implementing graduated fees as of July 1, 2025
To ensure successful implementation of ecomodulation adjustments, CAA recommends further stakeholder consultation
related to the development of graduated fee algorithms. Challenges with implementation at the start of the program
include the following:
Supply data underpinning fees and fee rates is highly uncertain
Accurate supply data (quantities of each material supplied) is a critical variable used to set fees and to establish appropriate
price signals and determine the most effective criteria and structure of the methodology. Both the base fees and graduated
fees will be directly tied to the reported supply data. As producers have not yet reported supply data, the estimates of
material supplied tons used for preliminary base fees are very uncertain. Based on experience with implementing EPR
programs in other jurisdictions, the data will be highly variable in the initial years of the program. Experience has shown
that it will take years for producers (and their suppliers) to become familiar with reporting requirements, material category
and product mapping, and to establish reliable systems to compile their data.
Further complicating this, the number of producers that will fall within low volume exemption rules or paying flat rates is
currently unknown. With exemptions from reporting the quantities supplied, it will take time for CAA to compile reliable
data.
Program costs are uncertain
As with supply data, reliable program financing is critical to the reliability of resulting price signals from both base and
graduated fees. Some program obligations are currently being confirmed and refined. Cost estimates for meeting the range
of obligations are therefore uncertain at this time. CAA will continue to refine program cost estimates prior to Program Plan
implementation.
LCA rules are being finalized
The rules and standards for conducting LCA studies and for assessing and comparing their results (as per ORS459A.884 and
ORS 459A.944) are not finalized and indeed some related to plastics are new. In this emerging context, proposing
appropriate criteria and levels for fee graduation is challenging and possibly unfruitful. Finalizing graduated fee structure
proposals needs to be coordinated with potential LCA impact reduction criteria and reporting requirements. Otherwise,
producers may begin to plan for potential fee adjustment assessments which are subsequently subject to significant
changes or refinements to criteria.
LCA data and the results of LCA studies are limited
Detailed and robust LCA data and the results of LCA studies are limited. Until CAA’s Program Plan has been approved, CAA
will not be in a position to raise the funds or have the capacity to undertake the necessary analyzes to determine the likely
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or possible level of improvement, nor assess the levels of incentives that would be practical and result in the desired
environmental outcomes. The corresponding uncertainty with base fee rates compounds this challenge.
Data for other potential factors that could be considered is also limited
Similarly, the data for most factors either suggested by DEQ for consideration (as per ORS459A.884) or that CAA considers
potentially important to improving the environmental impact and cost-effectiveness of the program (e.g. post-consumer
recycled content, designs causing operational problems), have not yet been compiled, are limited, or are not yet identified.
CAA believes that changes to material attributes may have environmental and/or program benefits, but to date it has not
yet had the capacity or opportunity to undertake the research and analysis necessary to fully assess the relative merits,
program implications, or levels of incentives that would result in the desired outcomes.For example, CAA believes that
some incentives related to post-consumer recycled content might be developed and used judiciously in a reasonable
market development action plan as the program evolves, as it has in other jurisdictions.
Flexibility and time will allow CAA to recommend the most impactful criteria for ecomodulation and program improvement,
both of which are important to the program’s success and consistent with the spirit of the RMA.
Given these considerations, CAA believes the desired outcomes of an effective long-term ecomodulation scheme to reduce
environmental impacts will be more effectively implemented with additional input from RMA stakeholders and additional
planning by CAA and its producers.
CAA also supports the implementation of eco-modulation factors in the producer fee schedule as contemplated under the
RMA. While CAA understands the critical nature of, and fully supports establishing rules governing the clear and rigorous
standards by which LCA studies are implemented and compared, it believes that the process for adjusting fees in relation to
LCA results should be developed as part of the PRO Program Plan. This will provide the required flexibility to optimize the
graduated fee structure over time. CAA strongly recommends that LCA rules do not define how the graduated fees should
be implemented in relation to LCA results beyond what is already required through the statute. CAA welcomes the
opportunity to establish a systematic process to work with DEQ and other stakeholders to ensure the graduated fees are
implemented as soon as possible following the start of the program.
Interim Eco-modulation Options
While the full assessment of long-term graduated fee adjustments, in CAA’s view, requires additional data and better
information about actual material base fee rates to develop, in the short term, there are a number of fee adjustment
options which could be implemented to offer producers incentives to improve environmental outcomes. These interim fee
adjustment options could potentially be implemented closer to the start of the program provided that the overall financial
implications associated with the adjustments were limited. For example, CAA could consider providing producers with a
limited bonus for disclosures of voluntary LCAs that would be available before the data necessary to develop more
comprehensive eco-modulation fee structures was available.
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Proposed Program Plan Amendment for Graduated Fees
At the time of drafting this initial submission, CAA proposes to use LCA results as a basis for graduated fee adjustments.
Either those from the 25 largest producers by market share that must be submitted to DEQ by December 31, 2026, as per
ORS 459A.944, or voluntary LCAs submitted by producers, subject to applicable rule concepts with regards to LCA criteria
and their comparison. Similarly, where supported with evidence, CAA may consider modulating material base fees using
specific design attributes. In both cases, CAA will propose the criteria by which it will apply the data on LCAs and any
recommended attributes to establish graduated fees.
Specifically, CAA expects that the Program Plan amendment outlining the graduated fee structure will provide detailed
information on the following items:
the set of criteria for which bonuses will be available and penalties will be applied, and how they will be used to adjust
the fees (i.e. LCA criteria, other factors such as recycled content, either within material categories or if applicable,
across material categories
the range and magnitude of each ecomodulation bonus and penalty
the timeframe for which bonuses and penalties for specific materials or producers are applicable
the administration process by which CAA will accept, assess and qualify approve requests for ecomodulation bonuses
ii. Methods by which the PRO will Accept and Consider Requests for
Ecomodulation Credits
Conceptual Approach to Determining Graduated Fee Structure
CAA anticipates the probable approach to calculating graduated fee rates, after determining base fee rates, to be as
follows:
Determine eligibility and level of bonuses and applicability of penalties based on:
o Reported producer supply by reporting category
o Reported environmental attributes and impact data (criteria yet to be determined)
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Determine which bonuses and penalties apply within each material category and if applicable, across material
categories according to criteria yet to be determined
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The factors and criteria for bonus eligibility and penalties and their levels will be determined before implementation in the 2028 program year in
consultation with DEQ and producers.
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Determine the values of bonuses and penalties to be issued with the intent of balancing the level of incentives and
disincentives for each material category
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Determine the total value of bonuses and penalties including those between material categories where applicable
Publish graduated fee structure
Include graduated fee adjustments on producer base fee invoices where applicable
If on the other hand, graduated fee rates must be calculated using either forecasted producer supply data or estimated
data for the applications for bonuses and for penalties, additional contingencies and possibly specific reserves will need to
be incorporated into the fees and fee rates to address potential bonuses and penalties. This is likely to result in both higher
fee rates in general to account for contingencies and establishing reserves, as well as more variable fee rates as CAA
manages the variability between forecast and actual data. Moreover, it is likely that bonuses will be funded inequitably
among producers because the distribution of fees to cover contingency and reserves likely will be different than the actual
distribution of bonuses and maluses. It will require considerably more challenging accounting to ensure the most
appropriate price signals and minimize inequities.
Consideration of Recycling Rate as a Factor for Ecomodulation
As part of the development of the base fee methodology, CAA considered including a factor to account for the recycling
rate (one of the factors identified in ORS 459A.884(4), namely the “recycling rate of the material in relation to the recycling
rate of other materials”). In that approach, a portion of total gross costs of managing covered products in Oregon would be
allocated to individual materials according to their relative recycling rate, such that the materials with higher recycling rates
would be assigned a smaller portion of the cost and vice versa.
CAA considered this option in conjunction with a corresponding allocation of a portion of the gross costs based on the
quantities of material recycled and the associated cost. The recycling rate term was intended in part to mitigate the impact
of the recycling cost term that tended to increase the fees for materials recycled to a greater extent relative to those that
are recycled to a lesser extent and the creation of a perverse signal that costs can be lowered by selecting materials that are
recycled less or substituting materials with a low recycling rate for those with a higher rate. CAA did not carry forward this
option, which would have required declaration as an “alternative membership fee structure” pursuant to ORS 459A.884(5).
CAA is not proposing to use the recycling rate as a factor in the graduated fee structure at this time.
Furthermore, within the definition of material categories that CAA is proposing, one individual producer’s package is so
similar to the next producer’s package within the same fee category that there is no expected difference in recycling rates
among covered materials in the same category that could be rewarded or penalized. For this reason, CAA is not proposing
to use recycling rates in its graduated fee structure at this time.
However, as part of the process to implement graduated fees, CAA anticipates investigating further the merit and feasibility
of using recycling rate within a covered material category, potentially relative to potential targets, either theoretical or
established in regulations as a factor in graduated fees. However, obtaining data on an individual producer’s covered
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The factors and criteria for bonus eligibility and penalties and their levels will be determined before implementation in the 2028 program year in
consultation with DEQ and producers.
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material recycling rate to document the difference in recycling rate from other covered materials in the same category is
anticipated to be challenging.
Consideration of Post-Consumer Recycled Content for Ecomodulation
ORS 459A.884(4) also lists the post-consumer content of a material as one of the factors that a PRO may consider in
establishing criteria for the graduated fee schedule.
It is generally recognized that the incorporation of post-consumer content in any particular packaging, paper product, or
food service ware item will lead to reduced environmental impacts compared to the same covered product that is made
entirely of virgin material. Under these conditions, a producer’s choice to design packaging with higher recycled content
typically would yield lower environmental impacts. Thus, if a producer had already made the decision to use a particular
material type for a packaging application, incorporating higher percentages of recycled content would lead to a positive
outcome.
One of the challenges that CAA would have to consider in using post-consumer content in determining graduated fees and
the criteria for applying it is the timing associated with the use of post-consumer content. The graduated fee schedule is
intended to incentivize change and improvements. Therefore, while several packaging materials and types already have
some and even significant portions of post-consumer recycled content, the desired outcome is positive change, i.e.
increased content and associated environmental benefit. For incentives to be beneficial then, CAA will need to establish
criteria, including a timeframe, that measure and reward such changes.
Initiatives to use post-consumer recycled material in products and packaging have been used successfully to strengthen
local markets for recycled material and increased commodity revenue. CAA believes that incentives to improving post-
consumer recycled content might be developed and used judiciously in a reasonable market development action plan as
the program evolves, as it has in other jurisdictions.
As such, CAA anticipates further investigating the suitability of using this factor in its future proposal for a graduated fee
structure.
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c. Alternative membership fee structure (if applicable)
CAA is not considering developing an alternative fee structure at this time.
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d. Adequacy of Financing
In accordance with ORS 459A.875(2)(i), CAA is required to establish fees that adequately fund the program operations,
ensuring the fulfillment of the RMA requirements and enabling program implementation. These fees shall cover the
expected management costs of materials, including collection service expansion, depot network setup and CRPF
compensation as well as REM and other strategic development costs. The fees will also cover departmental
reimbursements, administrative fees, PRO operations and program reserves.
For the first year of the program, CAA developed a range of program cost estimates that informed the amount of producer
fees to be generated.
Under the base case scenario, CAA expects to generate $226 million in producer fees to cover estimated program
costs of $219 million.
Under the high case scenario, CAA expects to generate $292 million in producer fees to cover estimated program
costs of $287 million.
Note that the discrepancy between forecasted fee revenues and program cost budgets is due to fee rate rounding.
Program Reserves and Contingencies
CAA is committed to striking an appropriate balance between maintaining a healthy balance sheet while also running an
efficient organization with high value for fees for participating producers. Guided by a corporate reserves policy, CAA has
established a reserve target and a funding strategy based on the working capital needs, risk mitigation and other financial
needs of the Oregon program.
As per ORS 459A.875(2)(m), the preliminary fee budgets under the two scenarios include provisions for program reserves
and contingencies. Under the base case scenario, the provision is budgeted at $46 million and under the high case scenario,
the provision is budgeted at $70 million.
These reserve levels reflect the amounts to be raised in the first year of fees. These will accumulate over two and half years
to reach the reserves target by the end of the 2027 program year, which is being considered as steady-state. The reserve
target reflects six months of projected annual variable operating costs under a steady-state program year in 2027.
The initial reserve targets referenced in the program plan budget, and rate of accumulation, will be further evaluated
before next version of the program plan submission.
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Equity
There is no one-size-fits-all solution to recycling because motivators and barriers vary across age, region, race, ethnicity and
other factors.
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In particular, CAA recognizes that the following factors may influence equity and outcomes in the Oregon
recycling system:
Lack of access to infrastructure and/or practical knowledge about how to recycle properly
Functional barrier of preparing items to recycle (cleaning, emptying, breaking down items)
Ability and disability (for example, color blindness might affect a resident’s ability to understand educational
materials)
Knowledge barriers (for example, residents might not feel confident in their abilty to recycle properly)
Recycling programs not being set up for full community participation
Investment in relevant resources and tools as well as information shared differently across the resident population
Language barriers
How community members see themselves represented in the education and outreach materials (visuals, language,
staff handing out resources)
Geography/location and practical considerations tied to location
CAA’s Proposed Approach to Equity
CAA’s approach to equity is to strive toward meeting our program goals while being as fair and inclusive as possible in
providing access to recycling services and recycling information in Oregon.
To help meet this objective, CAA has sought the expertise of the community-based organization (CBO) Trash for Peace in
developing the equity components of this plan. If selected, CAA will continue to work with Trash for Peace and other CBOs
in operationalizing its plan in Oregon.
To assess and review equity issues during program plan implementation CAA will consult regularly with the ORSAC and the
DEQ to ensure that CAA’s activities in Oregon align with the equity requirements of the RMA and CAA’s goals for equity.
CAA also proposes some specific equity approaches corresponding to key aspects of its operations plan:
Equity in the Establishment of a PRO Depot Network
CAA proposes to explore a number of approaches to ensure its depot network is tailored to the varying needs of different
Oregonians.
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https://recyclingpartnership.org/equitable-recycling-outreach
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First, the depot network will adhere to statutory and regulatory requirements around convenience standards. Meanwhile,
program leaders will identify opportunities to provide collection for people with mobility challenges, including considering
funding for at-home collection, store drop-off, and neighborhood collection events.
Because transportation is an equity issue, CAA proposes to prioritize events and mobile collections that bring recycling
closer to communities that must travel farther distances to existing recycling depots.
Furthermore, CAA will work to identify any depot sites on tribal lands, and once identified, CAA will prioritize contracting
with these sites.
Program leaders will also explore how compensation plans for collection point staff can be made fair and equitable. And
CAA will explore partnerships with community groups that collect PRO depot materials but may not qualify for permits or
meet the definition of “depot” or “drop off center.”
Equity in Responsible End Markets
CAA will work to ensure that new markets for materials collected in Oregon are developed in ways that minimize risks to
public health and worker health and safety.
For materials CAA owns, and wherever possible, CAA will also explore options to:
Provide opportunities to businesses that are small businesses, veteran owned businesses, owned by a disadvantaged
class, are not-for-profit businesses, or are B Corp certified
Provide opportunities to businesses with affirmative labor practices, such as hiring preferences for underserved
groups, providing living wages, or utilizing organized labor
Equity in Education and Outreach
As described in the Education and Outreach section above, CAA plans to ensure that educational materials and campaigns
are culturally responsive to diverse audiences across Oregon by:
Translating and transcreating all education and outreach materials into Spanish, Simplified Chinese, Traditional
Chinese, Korean, Arabic, Russian, Vietnamese and Ukrainian
Applying a co-creation approach to give community members a chance to participate in campaign design through
community-level listening, Partnering with CBOs as advisors to education and outreach development, as well as
implementation partners
Designing for accessibility, ensuring all collateral follows ADA compliance and best practices as well as the principles of
universal design, where products, services or environments are designed so that anyone – no matter their age or
ability – can use that design with minimal or no accommodations
Accounting for disparities in access to information technology, ensuring rural audiences are engaged as well as urban
populations
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Equity in PRO Administration
When contracting work to third parties, CAA will develop an approach that provides opportunities to businesses that have
certification under the Oregon Certification Office for Business Inclusion and Diversity (COBID) as minority-owned
businesses, women-owned businesses, service-disabled veteran-owned businesses, or emerging small businesses. CAA will
utilize the COBID website to obtain information on these potential business partners.
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CAA Management and Compliance
In this section, CAA describes its plans for day-to-day management of the program, communications, data gathering, and
reporting processes; managing producer compliance; and related policies and procedures. This section directly addresses
CAA’s Objective 4 for this program plan: “Create a system that fulfills the needs and regulatory requirements of the PRO, its
members, and all other relevant stakeholders.”
CAA is committed to upholding the highest standards of ethics, integrity, and compliance with all relevant local, state, and
federal laws and regulations. CAA recognizes the importance of adhering to legal requirements to ensure the trust and
confidence of our stakeholders, including the Oregon Department of Environmental Quality (DEQ), producers, partners,
employees, service providers, local municipalities, and the state of Oregon as a whole.
a. Overall Day-to-Day Management
CAA will provide management of the program’s overall day-to-day program operations, steward services, finance and
administration, and local government and community activities, utilizing key qualified personnel dedicated to the Oregon
program. Collaboration with CAA National and additional CAA state program personnel will occur to ensure all programs are
functioning in the most consistent and efficient manner. The CAA management team will conduct activities in accordance
with defined policies and procedures.
CAA will staff the program with dedicated resources responsible for the success of the overall program. The CAA National
office will also provide support where applicable.
The following resources will be the main points of contact and responsible for program compliance:
Primary Contact
Name: Doug Mander
Position: Oregon Program Manager
Phone: (416) 346-2294
Email: [email protected]
Secondary Contact
Name: Shane Buckingham
Position: EPR Program Planning Lead
Phone: (647) 210-5527
Email: [email protected]
A full list of CAA Oregon team members and their roles will be maintained on the staff page on the website. CAA will notify
DEQ within 30 days of key personnel changes related to the Oregon program.
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b. Communications
In this subsection, CAA describes its planned approach to communication and coordination with key stakeholders as part of
the implementation of this plan. It also outlines a proposed approach to gathering data and key metrics to inform the
measurement of key outcomes, and how key metrics will address elements of the annual reporting structure required by
the RMA.
CAA Plans for Communication and Coordination
CAA understands the effective collaboration and communication with Oregon recycling stakeholders is critical to CAA
successfully meeting RMA obligations and delivering on anticipated recycling system improvements.
CAA proposes several multi-stakeholder coordination and communication activities and welcomes feedback from Oregon
DEQ regarding these proposals. Note that the frequency of each activity will, by necessity, fluctuate to reflect the program’s
evolving needs. A set cadence for each effort will be determined that is agreeable to the relevant stakeholders and reflects
the program’s ongoing needs.
CAA will engage with other stakeholders not specifically highlighted here as necessary.
General Communications
CAA’s website already features a professionally designed and maintained section dedicated to Oregon and the Recycling
Modernization Act. This online resource is currently geared toward potential producers, but it will be expanded to target
additional audiences, including sections tailored to Oregonians (waste generators), service providers, local governments,
and others.
CAA expects it will employ other effective communication tools as demand for information is established in both format
and frequency.
Oregon DEQ
CAA will establish meetings between relevant CAA representatives and Oregon DEQ. CAA and Oregon DEQ would select the
appropriate project team members to be included on the recurring event, and each party would be expected to invite
others when relevant for specific discussion items identified in advance. This step builds on the strong communication ties
that have already been developed between CAA and DEQ.
CAA will also communicate updates and data to DEQ through required reports and according to recommendations
developed in consultation between CAA/DEQ and ORSAC.
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Oregon Recycling System Advisory Council (ORSAC)
CAA will appoint a single point of contact for ORSAC, and CAA will have standing attendance at ORSAC meetings and offer
the opportunity for consultation as needed.
CAA expects to engage in a regular series of meetings with ORSAC and DEQ to review implementation issues that could
arise after submission of this first program plan.
Local Governments and Service Providers
CAA will undertake a significant amount of communication and coordination activity with local governments and their
service providers as part of the proposed Oregon Recycling System Optimization Project.
As detailed in the “Collection and Recycling of USCL Materials” section of this plan, CAA intends to utilize an online portal to
process local government and service provider funding requests under different local government reimbursement
programs. These programs will be supported by dedicated CAA operations staff that will facilitate stakeholder participation.
CAA will also provide an online portal for local governments and their designated service providers to easily access,
customize, print and mail education and outreach collateral at no cost, as described in the “Education and Outreach”
section of this plan.
CAA will also host dedicated webinars to support program implementation, and local governments and service providers
will be a key audience for these communication efforts.
In addition, CAA will plan to connect with and inform local government stakeholders through connections with groups such
as the Association of Oregon Counties and the League of Oregon Cities.
Commingled Recycling Processing Facilities (CRPFs)
CAA will form a CRPF working group to establish a forum for interaction with processors and also to provide technical
assistance, review relevant program timelines and requirements, discuss investment opportunities, and more. CAA will
continue to cultivate relationships with processors on an individual level as well in an effort to understand needs and
shifting realities at the materials processing level.
CAA will establish standing meetings with the Oregon Refuse & Recycling Association (ORRA), a statewide trade group that
serves as a key conduit to processing entities.
Producers
CAA has been hosting a monthly Producer Working Group (PWG) since 2023 and will continue to do so. The PWG offers a
forum for information-sharing and discussion among companies with producer obligations, providing practical guidance on
producer-specific topics such as deadlines, requirements, reporting, and more.
PWG members also have access to the Producer Working Group Library, which includes past PWG meeting summaries and
materials.
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In addition, CAA’s website features a Producer Resource Center, which is regularly updated.
For producers, the CAA portal will enable secure registration and password protected login, transaction and balance history,
and reports and notices. It will also allow producers to submit their production volumes to CAA for annual fee calculations
via data exchange, structures file upload, or direct entry.
Trade Associations
The Association of Oregon Recyclers (AOR) is an important stakeholder relationship, as AOR membership spans the entire
materials management industry in Oregon. CAA will participate in the organization’s annual conference (including
presenting at the discretion of AOR’s conference planning committee) and collaborate on educational forums and/or
webinars for AOR members. CAA is open to other forms of engagement that mutually benefit CAA and AOR.
As mentioned earlier, ORRA is another important stakeholder relationship, with ORRA members accounting for a large
portion of the solid waste management sector in Oregon. Ongoing communication and relationship-building within ORRA
will be a key focus for CAA.
Other PROs and Multi-PRO Coordination
Given developments prior to the program plan submission deadline, CAA submitted this program plan with the expectation
that it is the only PRO submitting an RMA PRO program plan at this time. If additional PROs indicate an interest in
submitting program plans, CAA will work with DEQ and those prospective PROs to develop an interim coordination process
as required by the RMA framework.
With respect to program plan development tasks, CAA is tracking all program development costs that should be shared with
future PROs if they join the Oregon RMA program prior to CAA’s recovery of those start-up costs from membership fees.
CAA will include a breakdown of 2024 start-up costs in the proposed 2024 Annual Report anticipated by DEQ in its Phase II
RMA rule concepts. CAA’s 2025 Annual Report will also identify program development start-up costs incurred in 2025 prior
to the start of the program that will need to be recovered from producer fees once the program starts on July 1, 2025.
CAA will then track the recovery of these start-up costs over time so that in the event a new prospective PRO emerges, DEQ
and CAA can identify remaining program start-up costs applicable to that new PRO at the time of its proposed entry into the
RMA program.
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c. Reporting
Metrics and Data Collection
Many aspects of this plan will require tracking of key outcomes and metrics to measure the achievement of program goals
articulated in the “Program Goals” section. CAA will use its interactions with key stakeholders to collect data relevant to the
objectives, goals, expected outcomes, and key metrics discussed in that section. CAA will establish survey, reporting, and
other data collection mechanisms for routine program measurement. CAA will develop standardized reporting templates to
ensure consistency of records and provide clear guidelines to all stakeholders required to report data to CAA.
CAA will also ideally receive critical information from DEQ on key elements, in particular related to inbound contamination,
capture rate and outbound bale quality at CRPFs. CAA may in some instances pursue studies or other data-gathering
exercises to collect essential information. It will use this data and corresponding analytics to report annually to DEQ on plan
implementation and goal achievement. CAA will also use this performance information to update its goals, to adjust its
plan, and to suggest or recommend overall adjustments to RMA implementation. CAA’s intention is to use the submittal of
its five-year plan updates as the main mechanism for altering program goals.
Producer Reporting
CAA will provide participant producers with access to a secure online reporting portal to facilitate the submission of annual
supply data. This reporting portal will allow for CAA to capture and aggregate the information that must be submitted to
Oregon in the PRO Annual Report, as well as the applicable individual producer data where required.
CAA will monitor the effectiveness of this reporting portal and make adjustments as necessary to improve efficiency and
accuracy. CAA will also provide necessary training and support to all producers and relevant stakeholders on the reporting
portal's use.
Annual Reporting
CAA will submit Annual Reports to Oregon DEQ no later than July 1 of each program year, starting in 2026. CAA’s Annual
Report will contain all information required by 459A.887(2)(a), OAR 340-090-0660(1)(a), OAR 340-090-0670(4), and OAR
340-090-0700(1)(d). It will be written and presented in a manner that can be understood by the general public. The Annual
Report will be delivered each year to Oregon DEQ as a searchable electronic file.
CAA will follow the outline for annual reporting proposed in DEQ’s management directive including the following elements.
PRO Description: Total amount, by weight and type of material, of covered products sold or distributed in or into this state
by participating producers in the prior calendar year
Goals of the Program: Description of progress toward meeting topline goals in relation to identified program plan
outcomes and metrics along with any recommendations to improve recovery and recycling outcomes.
Program Operations: Summary of program operations including:
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Progress toward implementing local government recycling system service expansions and improvements
o Progress toward meeting PRO Recycling Acceptance List material collection targets and convenience and
performance standards
o Measures taken to address the recycling of specifically identified materials
o Summary of performance in relation to fulfilling responsible end market (REM) obligations including:
▪ A summary of quarterly disposition reports and evaluation of adequacy of REMs
▪ A summary of actions taken in support of REMs
▪ A summary of certification and verification results
o A description of actions taken in relation to upholding progress in relation to achieving the statewide plastic
recycling goal
o A summary of education and outreach activities
o Results of any in-person site inspections, material tracking or other audits conducted during the reporting
year, including whether any major safety or environmental management practices were not properly
followed and, if so, the corrective actions taken
Financing and Budget: Annual reports would include:
A summary of the financial status of CAA, including annual expenditures, revenues and assets
A description of the membership fee schedule, along with information on the number of producers that received fee
adjustments and total fee revenues and an evaluation of the effectiveness of membership fee adjustments in reducing
the environmental and human health impacts of covered products
A complete accounting and summary of payments requested by local governments and local governments’ service
providers and paid by CAA related to:
o Service expansion requests
o Transportation funding
o Contamination reduction funding
o Roll cart funding
o Contamination reduction evaluation funding
A summary of payments requested by local governments or local governments’ service providers that were denied or
reduced by CAA
A summary of payments made CRPFs
A summary of all other payments made to satisfy CAA’s obligations under ORS 459A.860 (Legislative Findings) to
459A.975 (Rules), including but not limited to payments made to support responsible recycling of specifically
identified materials (SIMs), as described in ORS 459A.917
Finally, annual reports will include any additional information required by RMA rules and statute. Reports will detail
updates around organizational compliance and include findings from an independent accountant’s audit of CAA’s financial
statements.
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d. Managing Compliance
To encourage the compliance of all stakeholders with the RMA, CAA will offer robust support and training to educate
producers about program plan requirements. Any material changes to program plan requirements impacting stakeholders
will be communicated to producers.
Records pertaining to CAA’s implementation and administration of its producer responsibility program will be retained in
accordance with applicable law and with CAA’s records retention policy.
CAA is committed to maintaining open lines of communication with state and local rule makers and will actively seek
clarification on any regulations deemed unclear. Internal controls will be designed to promote adherence to regulatory
standards.
Producer Compliance
Per ORS 459A.869(8), CAA will establish a searchable registry on its website disclosing all CAA’s compliant members and the
identities of any members determined to be non-compliant members through DEQ enforcement processes alongside the
reasons for their non-compliance. In instances where a member or non-member organization is potentially non-compliant
with the program plan and/or the RMA, CAA will notify DEQ and the allegedly delinquent producer of the deficiency and
provide the producer and opportunity to respond and to cure the delinquency as applicable.
CAA will endeavor to monitor compliance by producer members by conducting periodic operational and record audits,
utilizing an audit cycle that will be a mix of on-site and desk top audits. The desk top audit and on-site audits will assess the
same criteria. When a desk top audit is performed rather than an on-site audit, documentation via photos, promotional
efforts, and compliance documentation will be requested. All the same documentation will be gathered by the CAA staff
when conducting an on-site audit. In the event of a non-compliant finding, CAA will send a notification to DEQ after certain
internal compliance processes and timelines have passed.
Designated CAA personnel will be assigned to providers to cultivate relationships with providers and foster on-going
communication, trust, and transparency to identify and address issues as soon as possible.
Preventive Measures
CAA is undertaking several producer education activities prior to the start of the program plan designed to educate
producers of their obligations under the RMA in Oregon. This includes direct outreach to producers, informational
webinars, and engagement with relevant trade associations to disseminate broad awareness of the new program
requirements. CAA will also develop additional outreach materials to facilitate producer packaging reports required by the
program as the RMA moves closer to implementation.
These preventative measures are intended to support the processes outlined below for notifying DEQ, ORSAC, and
producers of potential non-compliance.
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Membership Rules
CAA will develop a Membership Rules Schedule related to fee payments and reporting requirements. Membership rules will
specify producer reporting and fee payment obligations, and may address such issues such as membership reporting
obligations, voluntary reporter agreements, reporting timelines and categories, errors in reports, membership-initiated
adjustment requests, billing process, timing of fee payments, penalties and interest associated with late payments,
verifications audits process, and compliance process along with a timeline by which a non-compliant member would be
referred to the DEQ for potential disciplinary action and/or dispute settlement.
Compliance Process
Below are components of a compliance process that could be incorporated into the Membership Rules:
Duty to Pay Required Fees - CAA may impose financial penalties and interest on members for failure to pay invoices in
accordance with membership rules
Retention of Records - CAA members will be required to retain records to substantiate and verify the accuracy of the
information submitted in their reports for a to-be-determined period of time following the submission, and such
records will be subject to inspection by CAA
Duty to Comply with Requests for Documentation - Upon written request from CAA, members shall provide
documentation in support of their reports to CAA. This may include specific data, calculation methodologies, and/or
audit reports, among other items.
Duty to Provide Access - Members will be required to grant access during business hours to CAA or its authorized
representatives to inspect and review records relevant to information submitted in their reports as maintained in
accordance with the Retention of Records policy
Duty to Cooperate with a Verification Audit - At the request of CAA, members must cooperate with CAA’s verification
process, described in the “Responsible End Markets” of this plan. This may include providing requested
documentation, data, records, and reports within a reasonable timeline of such requests, providing confirmation from
a senior officer with authority to confirm and oversee reporting, and providing access to the member's business
premises.
Notification of Non-Compliance
For non-compliance related to a producer who is or was a member of CAA in accordance with RMA requirements, but
which failed to comply with membership reporting and/or fee payment requirements, CAA Membership Rules would
include notification to DEQ after certain internal compliance processes and timelines had passed.
CAA would notify the DEQ of any members that are not in good standing (this may include a membership suspension and
process), subject to a time frame outlined in the Membership Rules. For example, members who had failed to report and/or
pay fees within the specified time frame could be:
Suspended by CAA and considered members not in good standing, following requisite due process of the reasons for
the suspension and the steps necessary to remove the suspension or become in good standing
Reported to DEQ to take such corrective action as DEQ deems necessary or appropriate
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CAA would also propose that in a multiple PRO situation, a searchable online database be maintained where PROs could
confirm whether producers were members of an approved PRO and in compliance with RMA requirements.
Obligated Producers under the RMA
CAA membership reporting review and assessments may identify situations where there is a dispute between producers
about which entity is an obligated producer with respect to a particular material application. In such circumstances, CAA
may consult with DEQ regarding the interpretation of RMA “obligated producer” provisions to ensure that the application
of the RMA to producers is consistent with DEQ’s intentions.
CAA may also become aware of producers that are not CAA members but that appear to be obligated producers under the
RMA. CAA will conduct outreach to encourage such producers to register with a PRO to fulfill their obligations under the
RMA. In such situations, however, CAA may not necessarily have access to information that would confirm whether a non-
member producer is actually obligated under the RMA. If such producers fail to take action, CAA would refer these
producers to DEQ, along with the information that led it to believe the producer was obligated under the RMA, for DEQ to
take such action as it may deem necessary
Non-Compliance with LCA Requirements
Failure of a CAA member to conduct and report on required LCA requirements in the case of the 25 largest producers in the
state is also a potential RMA compliance issue. Given the unique nature of LCA process and related rules, CAA would
propose to develop specific compliance reporting processes and protocols related to this issue that would likely be different
than processes and protocols in place to address violations of CAA producer reporting and fee payment requirements. CAA
would propose to develop a specific membership compliance process and policy related to producer LCA requirements and
would consult with DEQ regarding timelines and steps that would be taken to regain compliance.
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e. Dispute Resolution (Local Governments and CRPFs)
A number of areas under the RMA will require dispute settlement processes to address potential disagreements between
CAA and local governments and other stakeholders that are receiving funding from CAA under various RMA programs.
In many cases, standard commercial dispute settlement mechanisms, such as an agreement by the parties to refer a dispute
to a third-party arbitrator, can be utilized to resolve such disputes. As noted in other program plan sections, CAA is
proposing to finalize the details of various funding programs through further consultation with relevant stakeholders. This
would include a review of proposed dispute settlement procedures for each program funding area. Based on the results of
stakeholder consultation and input, CAA will provide a more detailed description of the dispute settlement procedures for
individual funding programs as part of its anticipated program plan revisions to be submitted in September 2024.
As also noted earlier, program funding in relation to local government service expansion requests may involve more difficult
dispute resolution issues than those normally associated with typical commercial contracts as there may be different
interpretations about what qualifies as costs associated with the expansion and provision of recycling collection service for
covered products. CAA is proposing that one of the objectives of the Oregon Recycling System Optimization Project
(ORSOP) will be to identify possible areas of disagreement between local governments and CAA regarding eligible funding
requests. Once more clarity on individual local government funding requests is received, CAA is proposing to create a
working group consisting of representatives from CAA, local governments, and DEQ to attempt to mediate disagreements
over service funding requests between the approval of the second program plan and the start of the program plan on July
1, 2025. This process would be intended to minimize potential disagreements between CAA and local governments prior to
the processing of individual local government service expansion requests once the program begins as of July 1, 2025.
Given that some funding request eligibility issues may require a resolution of the interpretation of the RMA and its
implementing rules, parties would retain the right to address issues through legal mechanisms in the event that CAA and
local governments and the DEQ cannot align on the same understanding of what the RMA requires.
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f. General Policies, Procedures, and Practices
CAA will regularly monitor the state of operations for the entirety of the program. CAA recognizes that defined and
consistently executed policies, procedures, and practices are critical for ensuring the well-being of its personnel and the
integrity of data provided to various stakeholders.
CAA has developed national and state specific (where applicable) policies, procedures, and practices to enable consistent
handling of activities while providing services required to operate key aspects of the program. The policies, procedures, and
practices are defined to address specific tasks and to ensure the below concepts are addressed where applicable.
Consistent with best practices, CAA anticipates that it will periodically review and update its policies, procedures, and
practices as determined to be necessary or appropriate.
i. Management of Contracts
CAA will maintain appropriate records of contracts that have been entered into in writing pertaining to the Oregon
Recycling Modernization Act. Prior to execution, written contractual agreements between CAA and relevant parties will
undergo appropriate internal review in accordance with CAA’s business practices and policies.
ii. Workplace Safety and Conduct
CAA is committed to maintaining a safe work environment. In order to provide a safe and healthy work environment,
personnel will be required to take appropriate and reasonable precautions by complying with established safety and
workplace conduct standards. CAA is committed to providing proper equipment, procedures, and training in safe practices
to aid in awareness and prevention of potential individual and community safety issues. Employees will be encouraged to
familiarize themselves with their safety and conduct responsibilities, to follow safety and conduct practices at all times, and
to make every effort to prevent accidents and injuries. Failure to adhere to safety and conduct rules could result in disciplinary
action, up to and including termination of employment.
CAA will promptly and thoroughly investigate all reports of suspected nonconformance by personnel with safety or conduct
requirements.
CAA will comply with all applicable laws pertaining to workplace safety.
iii. Protection of Confidential Information
CAA will adopt an information security plan that outlines appropriate technical, physical, and organizational measures
designed to protect against unauthorized or accidental access, destruction, loss, alteration, or disclosure of nonpublic
information subject to confidentiality undertakings.
The information security program will address native encryption of all data, event monitoring, audit trails, and other
relevant topics. When information is no longer needed or required to be maintained by organizational policy or applicable
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law, CAA will securely dispose of all data and records in accordance with its records retention policy and information
security program requirements.
All personnel will be required to periodically undergo appropriate training on their responsibilities for protecting
confidential information.
iv. Successful and Timely Delivery
CAA will establish contractual agreements with service providers that outline the requirements and expectations designed
to foster the successful and punctual achievement of project objectives by contractors.
Communication will be maintained with all contractors, with verbal and written notifications issued if timelines are not met
or project outcomes are delayed. Additionally, contractors will be asked to submit status reports as deemed necessary by
CAA.
CAA will request the contractual capability to inspect contractors and conduct quality checks to ensure that projects meet
the standards of the program. Furthermore, CAA will offer comprehensive training and support to all contractors to ensure
they understand and meet CAA’s expectations.
v. Retention of Information
Per ORS 459A.962, CAA will retain records related to the implementation and administration of its producer responsibility
program plan for at least five years and have them available for inspection by DEQ upon request. CAA will designate a
records custodian who will be responsible for the administration of the records retention policies. These documents will
facilitate the creation of the annual report elements specified in ORS 459A.878 and addressed in the “Reporting” section of
this plan. The annual report will be submitted to DEQ on July 1 of each year.
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g. Closure Plan
CAA financing proposals include the development of program reserve targets equivalent to at least six months of
variable operating expenses. Reserves ensure that CAA has the necessary resources for a transition period in the
event CAA ceases operations as a PRO in Oregon.
Potential closure scenarios related to CAA operations in Oregon involve several potential scenarios, which may include but
are not limited to:
1. A decision by the CAA Board of Directors to cease operations in Oregon
2. Failure to maintain membership representing 10% market share or other qualifying criteria of a PRO as is
required by the RMA
3. Changes in relevant laws, regulations, or other RMA program requirements
With respect to Scenario 3 above, CAA assumes that a change to the statutory and/or regulatory framework requiring CAA
to cease operations in Oregon would likely be accompanied by conditions that provide notification and timing of required
program termination dates. As such, this closure plan will focus on the other two possible closure scenarios.
In the case of an internal CAA decision to cease operations in Oregon (Scenario 1 above), CAA will endeavor to give its
producers, service providers, DEQ, the ORSAC, local governments and other RMA stakeholders a minimum of six months
notice that it intends to cease operations as a PRO in Oregon. CAA would also endeavor to align such a decision, if suitable
under the circumstances, with the renewal dates associated with RMA Producer Plans.
In the case of Scenario 2 above, where CAA closure is due to a failure to maintain membership representing the required
10% market share or other qualifying criteria, CAA would implement a closure plan that aligns with timelines related to
closure of operations associated with OAR 340-090-0730.
A notice of closure would include the intention for the termination of CAA’s Oregon program, the anticipated CAA program
termination date, and an outline of the steps CAA would take to wind up its operations in Oregon in an orderly fashion.
The CAA closure plan will include the following information:
Key steps and activities CAA will undertake before and after the termination date to ensure:
o That RMA obligations have been maintained during the wind up of activities
o That service providers, local governments, and other stakeholders are given adequate notice of the wind up
of individual CAA programs and contractual arrangements
Implementation timelines, key steps and cut off dates for various program operations (final day to submit
transportation compensation claims, for example)
Communications plan and stakeholder notifications
A closure financial plan and budget, including the process to ensure resolution of any liabilities and resolution of tax
and other financial issues
A plan to disburse any remaining assets and reserves once all financial and operational obligations have been
addressed
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Please note that in order to cease operations, CAA will have to conduct a number of activities after the termination date for
the CAA RMA program. This would include final payments required under the RMA for activities that took place prior to the
termination date.
Once CAA completes the steps required under the closure plan, it will provide notice to DEQ of the completion of the
closure plan.
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Certification and Attestation
a. Contents
i. Contact Information
Authorized
Representative:
Charles Schwarze
Title:
Chair
Address:
20 F Street NW, Suite 700,
Washington, D.C. 20001
Phone Number:
336-840-9860
Email Address:
info@circularaction.org
ii. The Prospective PRO’s Employer Identification Number
The Employer Identification Number for Circular Action Alliance is 92-3197259.
iii. Proof of the Prospective PRO’s Status as a Nonprofit
Documents showing proof of Circular Action Alliance’s status as a nonprofit, 501(c)3 organization able to operate in Oregon
are located in the Appendices as follows:
Circular Action Alliance’s bylaws of incorporation as a nonprofit corporation: Appendix H
Circular Action Alliance’s 501(c)3 determination letter from the Internal Revenue Service: Appendix I
Circular Action Alliance’s proof of status in Oregon (proof of registration as a charitable organization with the Oregon
Department of Justice): Appendix J
Circular Action Alliance’s proof of registration as a foreign corporation with Oregon’s Secretary of State: Appendix K
Circular Action Alliance’s revised bylaws: Appendix L
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iv. Certifying Statement
I hereby declare under penalty of false swearing (Oregon Revised Statute 162.075
i
and
ORS 162.085
ii
) that the above information and all of the statements, documents and
attachments submitted with this plan are true and correct.
Charles Schwarze – Circular Action Alliance Chair
Date: March 31, 2024
Signed
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Appendices
The following appendices are available in separate documents:
Appendix A: Definitions
Appendix B: List of Member Producers and Market Share Calculation
Appendix C: CAA Organizational Structure
Appendix D: Stakeholder Engagement
Appendix E: Itemized Budgets by Program Year
Appendix F: PRO Depot Lists and Coverage
Appendix G: Detailed Fee-Setting Methodology (confidential)
Appendix H: CAA Articles of Incorporation
Appendix I: 501(c)3 Letter of Determination
Appendix J: Proof of Registration as a Charitable Organization
Appendix K: Proof of Registration – Foreign Corporation
Appendix L: CAA Revised Bylaws
Appendix M: Preliminary Program Implementation Timelines
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Oregon
Program Plan
Appendices
(2025 – 2027)
Oregon
Program Plan
(2025 – 2027)
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Oregon Program Plan Appendices
(2025 – 2027)
Table of Contents
Appendix A: Definitions ............................................................................ 3
Appendix B: List of Member Producers and Market Share Calculation ................. 10
List of Member Producers ........................................................................................ 10
CAA Oregon Market Share Calculation Methodology.......................................................... 11
Appendix C: CAA Organizational Structure .................................................. 15
Appendix D: Stakeholder Engagement ........................................................ 20
Appendix E: Itemized Budgets by Program Year ............................................ 23
Appendix F: PRO Depot Lists and Coverage.................................................. 28
Appendix G: Detailed Fee-Setting Methodology (confidential) .......................... 29
Appendix H: CAA Articles of Incorporation .................................................. 30
Appendix I: 501(c)3 Letter of Determination ................................................ 48
Appendix J: Proof of Registration as a Charitable Organization........................ 51
Appendix K: Proof of Registration – Foreign Corporation ................................ 53
Appendix L: CAA Revised Bylaws ............................................................... 55
Appendix M: Preliminary Program Implementation Timelines ........................... 64
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Appendix A:
Definitions
Below are the definitions used in ORS 459A.863, along with additional terms that have been used in this program plan.
(1) “Brand” means any mark, word, name, symbol, design, device or graphical element, or a combination thereof,
including a registered or unregistered trademark, that identifies a product and distinguishes the product from
other products.
(2) “Collection rate” means the percentage of a specific material that is collected for recycling calculated by
dividing the tonnage collected into the tonnage generated on an annual basis.
(3) “Commingled recycling” means the recycling or recovery of two or more materials that are mixed together and
that generally would be separated into individual materials at a commingled recycling processing facility in
order to be marketed.
(4a) “Commingled recycling processing facility” means a facility that:
(A) Receives source separated commingled recyclable materials that are collected commingled from a
collection program providing the opportunity to recycle; and
(B) Separates the recyclable materials described in subparagraph (A) of this paragraph into marketable
commodities or streams of materials that are intended for use or further processing by others.
(4b) “Commingled recycling processing facility” does not include:
(A) Scrap metal recycling facilities;
(B) Scrap automotive or appliance recycling facilities;
(C) Full-service redemption centers or dealer redemption centers, as those terms are defined in ORS 459A.700,
and recycling facilities owned and operated by a distributor cooperative established under ORS 459A.718;
(D) Recycling facilities handling covered electronic devices, as defined in ORS 459A.305;
(E) Recycling processing facilities that process only noncommingled, source separated recyclable material from
commercial entities;
(F) Recycling processing facilities that recover commingled recyclable material primarily from the construction
and demolition debris waste stream;
(G) Recycling depots;
(H) Recycling reload facilities; or
(I) Limited sort facilities, as defined by rule by the Environmental Quality Commission.
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(5) “Community Based Organization” means a public or private nonprofit organization that has demonstrated
capability in representing or meeting the needs of a specific community or a significant segment of a
community.
(6) “Contaminant” means:
(a) A material set out for recycling collection that is not properly prepared and on the list of materials accepted
for recycling collection by a recycling collection program; or
(b) A material shipped to a recycling end market that is not accepted or desired by that end market.
(7) “Contamination” means the presence of one or more contaminants in a recycling collection or commodity
stream in an amount or concentration that negatively impacts the value of the material or negatively impacts a
processor’s ability to sort that material.
(8a) “Covered product” means:
(A) Packaging;
(B) Printing and writing paper; and
(C) Food service ware.
(8b) “Covered product” does not include:
(A) A beverage container, as defined in ORS 459A.700.
(B) Bound books.
(C) Napkins, paper towels or other paper intended to be used for cleaning or the absorption of liquids.
(D) Rigid pallets used as the structural foundation for transporting goods lifted by a forklift, pallet jack or
similar device.
(E) Specialty packaging items that are used exclusively in industrial or manufacturing processes, including but
not limited to:
(i) Cores and wraps for rolls of packaging sold by a mill to a packaging converter or food processor;
and
(ii) Trays, whether designed for a single use or multiple uses, used for the transport of component
parts from a parts supplier to a manufacturer that assembles those parts.
(F) Liquified petroleum gas containers that are designed to be refilled.
(G) A material that the producer demonstrates is exempt under section ORS 459A.869.
(H) Pallet wrap or similar packaging used to secure a palletized load if added by a person that is not the
producer of the palletized covered products.
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(I) Packaging related to containers for architectural paint, as defined in ORS 459A.822, that has been collected
by a producer responsibility organization under the program established under ORS 459A.820 to 459A.855.
(J) Any item that is not ultimately discarded inside this state, whether for purposes of recovery or disposal.
(K) Items sold on a farm or used on a farm, including items used for farm use, as defined in ORS 215.203, or for
processing on a farm, provided that an item used on a farm is not subsequently sold at a retail establishment
that is not located on a farm.
(L) Items used by a nursery licensed under ORS 571.055 that generates the majority of the nursery’s revenue
through the sale of nursery stock, as defined in ORS 571.005, provided that the items are not sold through
retail sales.
(M) Packaging and paper products sold or supplied in connection with:
(i) Prescription drugs as defined in ORS 689.005;
(ii) Nonprescription drugs as defined in ORS 689.005;
(iii) Drugs marketed under a brand name as defined in ORS 689.515; or
(iv) Drugs marketed under a generic name as defined in ORS 689.515.
(N) Packaging and paper products sold or supplied in connection with drugs that are used for animal
medicines, including but not limited to parasiticide drugs for animals.
(O) Packaging and paper products sold or supplied in connection with:
(i) Infant formula as defined in 21 U.S.C. 321(z);
(ii) Medical food as defined in 21 U.S.C. 360ee(b)(3); or
(iii) Fortified oral nutritional supplements used for individuals who require supplemental or sole
source nutrition to meet nutritional needs due to special dietary needs directly related to cancer,
chronic kidney disease, diabetes, malnutrition, or failure to thrive, as those terms are defined as by
the International Classification of Diseases, Tenth Revision, or other medical conditions as determined
by the commission.
(P) Wine and spirit containers for which a refund value is established under Oregon law.
(Q) Packaging for products:
(i) That are required under 40 C.F.R. 156.140, or other federal regulation pertaining to toxic or
hazardous materials, to state on the label or container that the packaging should not be recycled or
should be disposed of in a manner other than recycling; or
(ii) Identified by the commission by rule as product that is required by law to state on the label or
container that the packaging should not be recycled or should be disposed of in a manner other than
recycling.
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(R) Any other material, as determined by the commission by rule, after consultation with the Oregon Recycling
System Advisory Council.
(9) “Desk audit” means an analytical process that is conducted using data or information readily available on the
computer that does not entail additional on-site or field-based research or analysis.
(10) “Ecomodulate/Ecomodulation” means the utilization of positive and negative incentives (bonuses and
maluses) in producer responsibility packaging fees designed to encourage or achieve specific environmental
outcomes, such as reducing overall material usage, enhancing recyclability, reducing package to product ratios,
or increasing recycled content.
(11) “Food service ware” means paper or plastic plates, wraps, cups, bowls, pizza boxes, cutlery, straws, lids, bags,
aluminum foil or clamshells or similar containers:
(a) That are generally intended for single-use; and
(b) That are sold to a retailer or a dine-in food establishment or a take-out food establishment, regardless of
whether the item is used to prepackage food for resale, is filled on site for food ordered by a customer or is
resold as is.
(12) “Generator” means a household, business, or other entity that utilizes and then discards packaging or printed
materials to be managed as waste or as reusable, refillable or recyclable material.
(13) “Large producer” means a producer that is among the 25 largest producers of covered products based on
market share.
(14) “Licensee” means a person that is licensed by a brand and manufactures a covered product or a packaged
item under that brand.
(15) “Litter” means waste that is improperly placed so as to be a nuisance or aesthetic, health or environmental
concern.
(16) “Local government” means:
(a) A city;
(b) A county; or
(c) A metropolitan service district.
(17) “Local government’s service provider” means:
(a) A collection service franchise holder under ORS 459A.085;
(b) Any person authorized by a city or county to provide recycling collection services described in subsection
(25)(a) to (d) of this section; or
(c) Any person authorized by a metropolitan service district to provide recycling collection services described
in subsection (25)(d) of this section.
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(18) “Market share” means a producer’s percentage of all covered products sold in or into this state during a
specified time period, as calculated in accordance with methods established by the commission by rule.
(19) “Mechanical recycling” means a form of recycling that does not change the basic molecular structure of the
material being recycled.
(20) “Metropolitan service district” means a metropolitan service district established under ORS chapter 268.
(21) “Nonprofit organization” means an organization or group of organizations described in section 501(c)(3) of
the Internal Revenue Code that is exempt from income tax under section 501(a) of the Internal Revenue Code.
(22) “Opportunity to recycle” has the meaning given that term in ORS 459A.005.
(23a) “Packaging” means:
(A) Materials used for the containment or protection of products, including but not limited to paper, plastic,
glass or metal or a mixture thereof;
(B) Single-use bags, including but not limited to shopping bags; and
(C) Nondurable materials used in storage, shipping or moving, including but not limited to packing materials,
moving boxes, file boxes and folders.
(23b) “Packaging” does not include:
(A) Food service ware; or
(B) Sharps, as defined in ORS 459.386.
(24) “Parent facility” means a preexisting permitted or other larger facility that may also host a potential PRO
depot.
(25) “Person” has the meaning given that term in ORS 459.005.
(26) “Printing and writing paper” includes, but is not limited to, newspaper, magazines, flyers, brochures, booklets,
catalogs, telephone directories and paper used for copying, writing or other general use.
(27) “Processor” means a person that owns or operates a commingled recycling processing facility.
(28) “Producer” means a person that is determined to be the producer of a covered product under ORS 459A.866.
(29) “Producer responsibility organization” means a nonprofit organization established by a producer or group of
producers to administer a producer responsibility program.
(30) “Producer responsibility program” means a statewide program for the responsible management of covered
products that is administered by a producer responsibility organization pursuant to a plan approved by the
Department of Environmental Quality under ORS 459A.878.
(31) “Recyclate” means recycled material that is used in the manufacturing of new packaging or other products.
(32) “Recycling collection” means the act or process of gathering recyclable materials by:
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(a) On-route residential collection from the generator at the place of generation;
(b) On-site nonresidential collection from the generator at the place of generation;
(c) Multifamily on-route residential collection from each multifamily dwelling that has five or more units;
(d) Recycling depots at a disposal site or another designated location that is more convenient to the
population being served and expanded depots as described in ORS 459A.007; or
(e) Other collection methods included in an approved producer responsibility program plan.
(33) “Recycling depot” means a location where recyclable materials are accepted from the public or commercial
businesses and transported to a location for processing or to an end market.
(34) “Recycling rate” means the percentage or ratio of a material or set of materials that is collected and processed
for recycling divided into the amount of that material or set of materials that is generated.
(35) “Recycling reload facility” means a facility other than a recycling depot where recyclable materials are
received, consolidated and made ready for transport to another location for processing or to a responsible end
market.
(36) “Recycling system” means all aspects of the programs and participants that have a role in Oregon’s statewide
recycling structure, including producers of products sold in or into Oregon, generators of recyclable materials,
governments that regulate materials management programs, businesses that collect and process recyclable
materials and persons that receive recyclable materials to convert to new feedstock or products.
(37) “Responsible end market” means a materials market in which the recycling or recovery of materials or the
disposal of contaminants is conducted in a way that benefits the environment and minimizes risks to public
health and worker health and safety.
(38) “Responsible management” means the handling, tracking and disposition of covered products from the point
of collection through the final destination of the collected material in a way that benefits the environment and
minimizes risks to public health and worker health and safety.
(39) “Responsible recycling” means the handling of covered products for recycling and removal of contaminants by
a certified or permitted processor and disposition to a responsible end market.
(40) “Reverse logistics” means the process of returning discarded materials that were distributed to generators
back through a supply chain to reuse, refillable or manufacturing end uses.
(41) “rPET” designates PET (polyethylene terephthalate) resin derived from discarded PET that has been collected,
sorted, and processed into feedstock for the purpose of manufacturing new packaging or other products.
(42) “Small producer” means a producer that:
(a) Is a nonprofit organization;
(b) Is a public body, as defined in ORS 174.109;
(c) Has a gross revenue of less than $5 million for the organization’s most recent fiscal year;
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(d) Sold in or into Oregon less than one metric ton of covered products for use in this state in the most recent
calendar year;
(e) Is a manufacturer of a beverage sold in a beverage container, as those terms are defined in ORS 459A.700,
that sold in or into Oregon less than five metric tons of covered products, including but not limited to
secondary and tertiary packaging for beverage containers, for use in this state in the most recent calendar
year;
(fA) Is a restaurant, food cart or similar business establishment that primarily sells to members of the public
food that is generally intended to be consumed immediately and without the need for further preparation,
either on or off the premises; and
(fB) Is not a producer of food service ware as described in ORS 459A.866; or
(g) Operates a single retail sales establishment, has no online sales and is not supplied or operated as part of a
franchise or a chain.
(43) “Specifically identified material” means a material or covered product identified by the department under
ORS 459A.917.
(44) “Transcreation” means text that is made coherent and understandable in another language, not simply
translated word for word.
(45) “Uniform statewide collection list” means the list of materials established in accordance with the
requirements of ORS 459A.914 (4).
(46) “Wasteshed” means a designated area where material is physically generated and managed for disposal,
reuse, refilling or recycling.
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Appendix B:
List of Member Producers and
Market Share Calculation
List of Member Producers
CAA’s 20 Founding Members are:
1. Amazon
2. Clorox
3. Colgate-Palmolive
4. Danone
5. Ferrero US
6. General Mills
7. Keurig Dr Pepper
8. Kraft Heinz
9. L’Oréal
10. Mars, Incorporated
11. Mondelez
12. Nestlé USA
13. Niagara Bottling, LLC
14. PepsiCo
15. Procter & Gamble
16. SC Johnson
17. Target
18. The Coca-Cola Company
19. Unilever United States
20. Walmart
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CAA Oregon Market Share Calculation Methodology
CAA took the following steps to calculate an estimate of CAA’s member companies supply to the Oregon Market.
Estimate of CAA Producer Member Supply (Numerator)
To estimate the numerator, CAA reached out to our 20 member companies and asked them to provide the total tons of
packaging they supplied into Oregon in 2022. The 20 member companies, named in the “PRO Description” section of
the plan, represent an array of consumer-packaged goods firms that hold significant market share nationally across an
array of consumer products that are under the scope of Oregon’s Recycling Modernization Act.
CAA provided instructions to these companies on the types of packaging to include and exclude (e.g., exclude
packaging covered under Oregon’s Bottle Bill). Once this data was received, CAA made minor adjustments to ensure all
data was in the same unit (pounds). Some member companies were only able to provide national data. For the
companies that provided national data, we used U.S. Census Data to calculate the percentage of the U.S. population
living in Oregon and applied that percentage to the companies’ national data to extrapolate a supply estimate for
Oregon.
Based on data received from its current member companies, CAA estimates that these companies supplied at least
102,000 to 122,000 tons of covered product packaging to the Oregon market in 2022.
Please note: CAA anticipates that the scope of obligated covered product packaging for purposes of producer supply reports will
become clearer for producers once related RMA rulemaking processes are completed and CAA develops more detailed educational
and resource materials. As such, these initial tonnage reports may be underestimating actual member supply tonnage.
Estimate of Total Print and Packaging Generation in Oregon (Denominator)
Oregon DEQ provided access to data developed for DEQ by the consulting firm Cascadia Consulting Group, Inc. that was
used to estimate impacts of infrastructure improvements and various material collection scenarios. CAA used this data
to produce an estimate of the overall covered paper product and packaging supply to Oregon for the purpose of
calculating a market share denominator.
Please Note: Although this data represents the best available diversion data at this time for the purposes of estimating total covered
product supply, more accurate information will become available when all producers generate supply reports as the Program Plan
begins operations. Total state covered product supply based on producer supply reports may be significantly lower than this initial
estimate.
Utilization of this dataset required a set of “reduction” elements to account for materials which are not covered
products under the RMA, including Bottle Bill materials, some industrial or other non-consumer facing materials, and
materials produced by “small producers.” These factors were deployed against the denominator estimate to reduce
the overall number.
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The Cascadia dataset includes the material volumes generated from residential and commercial sources in 2017 and
projected for 2026, for a total of 50 materials. Forty of those materials are considered to be print and packaging
related. Note that the data suggests that ~35% of materials are generated from residential routes while ~54% are
generated from commercial routes. See table below.
Total Print and
Packaging
Tonnage
2017
2026 (Projected)
Change
1,476,000
1,630,000
154,000
Share of Total Percent
Single-family Residential
(on route)
29%
27%
-2%
Multifamily Residential
(on-route)
7%
6%
0%*
Commercial (on-route)
31%
31%
0%
Other Commercial
22%
24%
2%
Self-Haul (excl. Bottle
Bill)
7%
7%
0%
Bottle Bill
5%
5%
0%
TOTAL
100%
100%
0%
Table i
Between 2017 and 2026, volumes are projected to increase by 154,000 tons or 10.4%. Cardboard, PE film and HDPE
tubs are expected to increase the most during this period (on a percentage basis) while newspaper, printing and
writing paper are expected to decrease the most.
The average year-over-year percent change in volumes for each material over the 10-year period was applied to the
2017 baseline and escalated to the 2022 year, which is the year for which producer supply data is being requested. This
results in total generated tons of 1,561,000 tons.
In accordance with the scope of the Oregon program, further analysis was undertaken to reduce the total estimated
tons to account for exemptions and exclusions.
1
The following reductions were estimated from the Cascadia dataset
and applied to the estimated tonnage in 2022:
1
Based on definitions under ORS 459A.863(6).
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Exclusions
Reduced Tonnage
Reason and Assumptions
Non-Recoverable Material
2
121,973
Beverage Containers on Deposit
3
141,965
Tonnage of PET, HDPE, AL, steel, glass beverage containers
on deposit were reduced
Out-of-Scope (Non-Consumer Facing
Packaging)
4
207,053
Tonnage associated with industrial/office paper, shipment
packaging materials (OCC, film), industrial OCC and specialty
packaging used in manufacturing was reduced. Assumed
10% of print paper, 25% of paper packaging and 20% of
flexible plastics (film). It is unclear to what extent the
Cascadia dataset had excluded for commercial material
recovery.
Small Producers’ Materials
5
150,473
Tonnage associated with packaging materials generated by
small producers and free riders. The de minimis thresholds
are <$5m in gross revenues or up to one ton of packaging
supplied. Assumed 15% reduction to overall net tons based
on Ontario experience.
Contamination/Moisture Adjustment
to Collected Materials
85,268
Tonnage associated contamination and moisture in the
collected materials will not be reported by producers as
supply. Assumed 10% reduction to overall net tons.
TOTAL
727,143
Table ii
The net tons of generated total printing and writing paper, packaging and food service ware materials in the scope of
the program is approximately 834,000 tons. This estimate suggests a per capita generation rate of 357 pounds per
capita. A reasonable range would be between 792,000 to 876,000 tons.
For validation purposes, The Recycling Partnership (TRP) applied this methodology on three other data sources arrived
at directionally similar results:
1. combining published DEQ 2016 waste composition data with statewide recycling data
2. extrapolating from single-family data in a 2019 Portland Metro capture study, and
3. extrapolating from TRP’s capture study database of household material
2
Cascadia defines ‘non recoverable material’ as material which is not covered under the RMA.
3
Based on beverage container definition, under ORS 459A.700.
4
Based on product exclusions under ORS 459A.863(6)(b). Note the volume of ICI commercial packaging that will be out of scope under
the program may be significantly higher than these initial estimates.
5
Based on ORS 459A.863(32) Volume of material associated with small producers will be difficult to accurately assess until all producers
are reporting supply into the Oregon market.
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Resulting Market Share Estimate
Dividing the range of numerator estimates by the range of denominator estimates results in an estimate of current CAA
member companies covered product market share supply by weight in Oregon of between 12% and 15%. CAA
anticipates a significant increase in membership that will add to the total CAA market share prior to program plan
implementation.
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Appendix C:
CAA Organizational Structure
As noted in the program plan, Circular Action Alliance (CAA) is a nonprofit organization established to
fulfill producer obligations related to EPR statutes in a number of states, including Oregon. CAA has
utilized the services of The Recycling Partnership (TRP) to support the development of the Oregon
program plan. An organizational chart is included on the following pages.
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CIRCULAR ACTION ALLIANCE
1
CAA Overall Organizational Structure
CAA Project Lead
Project Sponsor
Ron Soreanu
Chief Executive Officer
TBD – New Hire
Board and Project
Administrator
Susan Towle
Administration Lead &
Senior Strategic Advisor
Jeff Meyers
Chief Information Officer
Patrick Benson
Governance
EPR Program Planning
Lead
Shane Buckingham
National Board
External Groups
Human Resources
Committee
Governance
Committee
Interim Chief Financial
Officer
Kashif Ali
Finance
Consultant
Ashley Reid Smith
See next page
The Recycling
Partnership
(3rd Party) See
next page
Communications &
Recruitment Director
Olivia Barker
Director Front
Office Product
Owner
Piotr Prussak
Director IT /
Info Security
Jeff Gray
Procurement
Manager
Karen Bieri
Stakeholder
Engagement &
Recruitment
Ali Briggs-Ungerer
Comms &
Stakeholder
Engagement
Advisor
Sidney Roth
Regulatory &
Stakeholder
Relations Advisor
John Hite
Communications
Advisor
Mark Carpenter
Stakeholder
Engage., Comms
Advisor &
Recruitment
Michael Harris
Stakeholder
Engagement &
Comms Advisor
Christine Yeager
Human Resources
Lead
TBD – New Hire
Finance, Audit and
Investment
Committee
Executive Assistant
Joyce Polintan
CAA Project Team
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CIRCULAR ACTION ALLIANCE
2
CAA EPR Program Planning Structure
EPR Program Planning
Lead
Shane Buckingham
EPR Project Manager
CA and CO
Susie Minchella
Fee-Setting Manager
Alex Chan
Governance
Recycling Operations
Manager
Francis Veilleux
National Board
Responsible End
Markets Manager
Pierre Benabidès
Technical Advisor
Tim Buwalda
Technical
Advisor
Dan Lantz
The Recycling
Partnership
(3rd Party)
Oregon Program
Manager
Doug Mander
Eco-Modulation
Specialist
Thomas Etien
Data Analyst
Sukalyan Talukdar
Technical
Advisor
Scott Mouw
REMs Project
Manager /
Technical Advisor
Trina Matta
Technical Advisor
Guy Perry
See next page
EPR Program Team
Colorado Program
Manager
Pete Hargreave
California Program
Manager
Shane Buckingham
Policy Advisor
Dave Lefebvre
Technical Advisor
Chris van Rossem
Policy Advisor
Betsy Dorn
Policy Advisor
Isabelle Faucher
Procurement
Specialist
Rob Cook
Recycling System
Advisor
Dave Yousif
Main Program
Manager
Susan Bush
EPR Project Manager
Fee Setting
Stephanie Anselm
EPR Project Manager
Tina Caputo
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CIRCULAR ACTION ALLIANCE
3
CAA Oregon Program Planning Structure
EPR Program Planning
Lead
Shane Buckingham
Fee-Setting
Manager
Alex Chan
Governance
Recycling
Operations
Manager
Francis Veilleux
National Board
Responsible End
Markets Manager
Pierre Benebidès
Technical
Advisor
Tim Buwalda
Technical
Advisor
Dan Lantz
Local
Government
Outreach
Kim Holmes
Data Analyst
Sukalyan
Talukdar
Technical
Advisor, Local
Government
Nick Isbister
(starting May
2024)
EPR Program Team
Oregon Board
Materials
Management
Ali Blandina
Technical
Advisor
Scott Mouw
REMS Project
Manager /
Technical Advisor
Trina Matta
Education &
Outreach
Louise Bruce
Project
Assistant
Alex Stockler
Oregon Program
Manager
Doug Mander
Technical
Advisor
Dan Leif
Communications
Amanda Kelley
Finance
CFO
Kashif Ali
Producer Recruitment
& Communications
Advisors
Olivia Barker, John Hite
Information Technology
CIO
Patrick Benson
Legal
Venable (3
rd
Party)
Human Resources
TBD
Cross-Functional Team - National Resources
Project Administration
Susan Towle
Joyce Polintan
OR Project Manager
and Technical Advisor
Steph Kersten-Johnston
(TRP)
Oregon
Executive Director
(TBD)
Stakeholder
Engagement &
Recruitment
Ali Briggs-Ungerer
Stakeholder
Engagm’t, Comms
Advisor &
Recruitment
Michael Harris
Stakeholder
Engagement &
Comms Advisor
Christine Yeager
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Appendix D:
Stakeholder Engagement
During the development of this program plan, CAA and its partners have engaged and consulted with a large number of
relevant stakeholders. While insights from some have been included within the narrative of the plan, others preferred their
perspective to remain unofficial at this stage.
Local Governments, Service Providers (select groups and existing depot operators)
Metro Regional Governments (group) – multiple
engagements across different topic areas
City of Salem and service providers
Columbia County Government
Deschutes County Government with Cities and
service providers
Lane County Government with Cities and service
providers
Marion County Government with Cities and
service providers
Lincoln County Government with Cities and
service providers
Milton-Freewater and DEQ regional rep
City of Corvallis
Rogue Disposal (dba Waste Connections),
Thompson Sanitary, Dahl Disposal, Pendleton
Sanitary
Tillamook County Government with Cities and
service providers
Washington County and all cities in the IGA
Waste Management
Recology of Oregon
Waste Connections
Republic Services
Dahl Disposal Services
North Lincoln Sanitary
Thompson Sanitation
Southern Oregon Sanitation
Brandt’s Sanitary Service
Royal Refuse
Loren’s Sanitation Services
Dalh & Dahl, Inc
Valley Recycling
Nestucca Valley Recycling
Sutherlin Sanitary
Humbert Refuse
Roseburg Disposal Company
Pacific Sanitation
Suburban Garbage Service
Pride Disposal and Recycling Company
Apex Recycling and Disposal
D&O Garbage Service, Inc
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City Sanitary Service
Cascade Disposal Co.
South Umpqua Disposal Company
Valley Recycling and Disposal
Potential Additional Depot Material Partners
Habitat ReStore
St. Vincent de Paul
BRING
Mattress Recycling Council
PaintCare
Metro HHW program
Ridwell
OBRC
James Recycling
Ground Score
The Arc of Portland
End Markets and Other Material-Related Stakeholders
D6
DirectPack
Denton Plastics
Merlin Plastics
ORPET
Indorama
Royal Interpack
Reynolds Foil
Gottlieb
Household and Commercial Products Association
(HCPA)
Recycle Aerosol
NORPAC
Carton Council of North America
Sonoco
Cascade
Nucor
PakTech
Association of Plastics Recyclers (APR)
Indorama
RRS
CMI
The Recycling Partnership
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CRPFs
EFI Recycling
Far West Recycling
Garten Services
Eco Sort
Pioneer Recycling Services
Walla Walla Recycling
Other
Oregon Refuse & Recycling Association (ORRA)
Trash for Peace
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Appendix E:
Itemized Budgets by Program Year
Preliminary Program Cost Estimate Ranges over Three Years of Operations
CAA developed a range of preliminary program cost estimates to be published in the Program Plan. Presenting a range of
anticipated program costs is reasonable given the absence of program data and uncertainty with estimates at this early
stage.
To inform these estimates, the CAA project team relied on best available data on covered material volumes, current
understanding of future system needs and costs in advance of completing the Oregon Recycling System Optimization
Project. Insights were also drawn from EPR programs in other jurisdictions. Given the high degree of uncertainty associated
with these estimates, a conservative base case and high case scenario were developed.
Base Case
Pre-Program + 2025
FY2026
FY2027
Local Government Collection
Services Expansion
$ 53,900,000
$ 143,100,000
$ 158,900,000
Contamination Reduction Programming
$ 13,100,000
$ 13,100,000
$ 13,100,000
Transportation Reimbursement
$ 4,800,000
$ 12,600,000
$ 9,500,000
Others
$ 1,100,000
$ 1,200,000
$ 1,200,000
Payments to CRPFs
$ 25,300,000
$ 50,400,000
$ 76,600,000
PRO Materials Management (Depots)
$ 33,900,000
$ 54,100,000
$ 56,800,000
REM Development and Verification
$ 2,900,000
$ 3,200,000
$ 3,200,000
Special Material Investments incl. SIMs
$ 7,750,000
$ 2,000,000
$ 2,000,000
Education and Outreach
$ 10,400,000
$ 7,500,000
$ 7,600,000
Regulatory
$ 8,150,000
$ 9,417,000
$ 15,600,000
PRO Management and Administration
$ 11,800,000
$ 10,300,000
$ 11,050,000
Program Reserves
$ 45,500,000
$ 27,300,000
$ 18,200,000
Total Budget
$ 219,000,000
$ 335,000,000
$ 374,000,000
Table iii. Preliminary program plan cost estimates – base range.
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High Case
Pre-Program + 2025
FY2026
FY2027
Local Government Collection
Services Expansion
$ 70,070,000
$ 186,030,000
$ 206,570,000
Contamination Reduction Programming
$ 13,100,000
$ 13,100,000
$ 13,100,000
Transportation Reimbursement
$ 6,240,000
$ 16,380,000
$ 12,350,000
Others
$ 1,430,000
$ 1,560,000
$ 1,560,000
Payments to CRPFs
$ 32,890,000
$ 65,520,000
$ 99,580,000
PRO Materials Management (Depots)
$ 44,070,000
$ 70,330,000
$ 73,840,000
REM Development and Verification
$ 3,770,000
$ 4,160,000
$ 4,160,000
Special Material Investments incl. SIMs
$ 10,000,000
$ 2,600,000
$ 2,600,000
Education and Outreach
$ 12,800,000
$ 9,750,000
$ 9,880,000
Regulatory
$ 8,150,000
$ 10,871,000
$ 16,500,000
PRO Management and Administration
$ 14,200,000
$ 13,390,000
$ 14,430,000
Program Reserves
$ 70,000,000
$ 42,000,000
$ 28,000,000
Total Budget
$ 287,000,000
$ 436,000,000
$ 483,000,000
Table iv. Preliminary program plan cost estimates – upper range.
Description of Budget Category Estimate Methodology
Local Government Collection Services Expansion
Local government collection services expansion covers the anticipated costs of funding local government recycling service
expansions and improvements. This includes capital requirements for on-route service, depot and reload facility upgrades
and expansions. It also includes eligible operating costs relating to existing local government depot operations and reload
facilities.
Data included in the 2023 Needs Assessment was not detailed enough to support accurate estimates of local government
service expansion requests. For example, the number of new trucks associated with local government information in the
Assessment could be interpreted to be as high as 1,500. Based on assumptions regarding an increase in material volumes in
many jurisdictions and the anticipated expansion of on-route services in select jurisdictions, CAA assumed a requirement
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for approximately 200 trucks with a price of $400,000 per vehicle. With respect to depots and recycle reload facilities, CAA
assumed both an expansion of existing facilities and the sourcing of approximately 30 new facilities over the course of the
first Program Plan. CAA capital asset costs have not been amortized in these estimates.
Some estimates are fixed because they depend on known parameters with known allocations. In other cases, the
calculations are based on assumptions subject to significant variability based on interpretation or unknown parameters.
The base case reflects a preliminary estimate of costs based on current information while the high estimate represents the
margin of error that exists given the lack of information available. Based on existing information, there is a high level of
uncertainty regarding these estimates, the eligibility of various local government funding requests and the timing of
expenditures. CAA will be in a substantially improved position to estimate these costs once the Oregon Recycling System
Optimization Project is complete.
Contamination Reduction Programming
CAA has assumed a funding requirement equivalent to the $3 per capita cap created under the RMA. This includes
contamination measurement such as periodic assessments and evaluations.
Transportation Reimbursement
Based on preliminary information, CAA has assumed that local governments and their service providers will transport
approximately 128,000 tons of material that is eligible for transportation subsidies on an annual basis. Transportation cost
estimates were based on industry hauling rates published by the American Transportation Research Institute (ATRI) for the
year 2023. These rates were applied to distances between wastesheds and the closest commingled recycling processing
facility available for processing (where transportation distances were greater than 50 miles). CAA also factored some
facility handling costs into this estimate.
Others
Others represents an initial estimate of the program to cover the price premium to ensure post-consumer content in roll
carts.
Payments to CRPFs
These costs relate to anticipated CAA payments to CRPFs (that are reflective of commodity revenues), compensate them for
receiving and sorting covered materials, disposing of contaminants and residue, managing material cost fluctuations and
implementing facility improvements required to meet CRPF RMA requirements.
Estimates of CAA payments to CRPFs were largely based on volume estimates and fee rates for the Processor Commodity
Risk Fee (PCRF) and the Contamination Management Fee included in Study Results Processor Commodity Risk Fee
Contamination Management Fee: March 7, 2024 Final Report by Crowe. These estimates will be revised once RMA rules
related to the calculation of these amounts are finalized.
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PRO Materials Management
These costs relate to CAA’s obligation to establish a depot system to manage PRO materials from collection to recycling.
These costs reflect the estimated funding requirements based on Oregon system needs to operate PRO depots, set up
collection events and activate curbside collection of certain PRO materials. The exact number of collection points required
to meet the RMA convenience standards will be determined through the program development process. This may result in
additional required collection points to meet DEQ standards.
In developing this preliminary estimate, CAA assumed that approximately 85% of existing depot locations would be
interested in operating as a collection partner for PRO Recycling Acceptance List materials. CAA also assumed that certain
PRO Recycling Acceptance List materials would continue to be collected through curbside collection programs. Depot cost
estimates were based on CAA cost modeling informed by the costs of managing similar materials through depots in other
jurisdictions and cross-referenced with material volume and cost estimate information from Overview of Scenario
Modeling: Oregon Plastic Pollution and Recycling Modernization Act.
There is high level of uncertainty with respect to these cost estimates and the number of existing depots that will actually
choose to partner with CAA in collecting PRO acceptance list materials. CAA will be in a significantly improved position to
estimate these costs once the Oregon Recycling System Optimization Project is completed.
REM Development and Verification
REM development and verification costs were budgeted based on an estimate of the number of audits to be conducted
during the course of the program (~200-250) along with required REM infrastructure and potential costs associated with
CAA actions taken to address REM compliance. Individual audits were estimates at $10,000 per audit, confirmed by two
standard developers using a third-party verification body to undertake audits. The estimated number of audits was
determined by listing all potential buyers of different commodities. REM development and verification costs were
estimated separately for USCL and PRO Recycling Acceptance List materials.
Special Materials Investments including SIMs
These costs relate to CAA estimates of investments (research, trials, studies, etc.) earmarked to improve the recycling of
SIMs and other materials. CAA has identified 11 materials that are candidates for investments and their associated costs of
initial studies and field trials. PET thermoforms and glass are two high focus materials at present. This preliminary estimate
may be adjusted as further outreach with producers and other stakeholders focuses on potential recycling changes for
additional covered product materials.
Education and Outreach
These costs represent CAA’s estimates of the cost to the deliver the RMA mandated statewide education and outreach
program to support local government communications activity related to the collection of USCL materials as well as driving
awareness among residents about the acceptance of PRO materials at PRO depots. The budget was developed with The
Recycling Partnership (TRP) which has extensive experience in the design and delivery of recycling communications.
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Estimates include research, creative development and distribution of materials as well as multilingual translations. On
average, the proposal costs close to $2 per capita.
Regulatory
Regulatory costs include the Program Plan review fee, annual administrative fees payable to DEQ and potential CAA
contributions to the Waste Prevention and Reuse Fund. As per ORS 459A.941, CAA’s initial estimate has assumed annual
contributions equivalent to 10% of its annual expenditures based on a rolling three-year average, starting in 2026. These
estimates will be revised once RMA rules related to the calculation of these amounts are finalized.
PRO Management and Administration
These estimates reflect CAA’s initial estimate of PRO administration and operational costs in Oregon necessary to
administer various RMA programs. This includes Oregon PRO office expenses, staffing, overhead, and services support
received from National CAA. This includes pre-program start-up and program development costs. These costs were
reviewed by a third-party public accounting firm.
Program Reserves
Program reserves estimates were established based on working capital and risk mitigation needs of the program, guided by
CAA finance policy. The proposed program reserves targets reflect six months of “variable” operating expenses under
steady-state program operations (assume 2027).
A portion of fees collected will contribute to build up to the reserves target.
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Appendix F:
PRO Depot Lists and Coverage
The separate appendix list of existing depots (Tab 1 of Appendix F Excel) was used to inform the mapping and convenience
standards efforts to inform the PRO Recycling Acceptance List section of this Plan.
This list makes no assumptions about facilities’ willingness to partner with CAA as no formal negotiations have taken place.
However, initial discussions with some existing depot operators have generally been encouraging. CAA has also been
maintaining a list of “back-up” locations which it plans to use as necessary to supplement provision in areas where
convenience standards may otherwise not be met, including suitably-sized hauler yards and facilities run by other
organizations CAA has informally approached, such as Habitat for Humanity Restore.
Tab 2 and 3 of Appendix F Excel represents the distribution of the collection points modeled for the Program Plan (by state
and county, and by city). It includes all collection points, including special events and the provision of curbside collection in
certain areas. The site locations and quantity are subject to change based on negotiations with local governments.
ID Region County Pmt # Facility Name Address City Zip
P50
Eastern BAKER 152 Baker Sanitary Landfill SE OF BAKER CITY BAKER CITY 97907
D73 Western
BENTON 306 Coffin Butte Landfill 29175 COFFIN BUTTE RD CORVALLIS 97330
D74 Western
BENTON N/A Corvallis Disposal 110 NE Walnut Blvd Corvallis 97330
ED28 Western
BENTON EVENT/DOORSTEP PHILOMATH
D75 Western
BENTON N/A First Alternative Coop 2855 NW Grant Ave Corvallis 97330
D51 Northwest
CLACKAMAS 480
KB Recycling Inc. Materials Recovery
Facility
9602 SE CLACKAMAS RD CLACKAMAS 97015-9731
D52 Northwest
CLACKAMAS 443 Canby Transfer & Recycling Center 1600 SE 4TH AVE CANBY 97013
D53 Northwest
CLACKAMAS 121
Clackamas County Garbage & Recycling
Transfer Station aka Sandy Transfer
Station
19600 SE CANYON VALLEY
ROAD
SANDY 97055
D54 Northwest
CLACKAMAS 350 Metro South Transfer Station 2001 WASHINGTON ST OREGON CITY 97045
H4 Northwest
CLACKAMAS Northwest Polymers 291 Commercial Pkwy. MOLALLA 97038
ED2 Northwest
CLACKAMAS EVENT/DOORSTEP GLADSTONE
PP2 Northwest
CLACKAMAS Red White and Blue 19239 SE McLoughlin Blvd. GLADSTONE 97027
PP3 Northwest
CLACKAMAS Goodwill Distribution Center 1740 SE Ochoco St. MILWAUKIE 9722
ED3 Northwest
CLACKAMAS EVENT/DOORSTEP WESTLINN
DB6
Northwest CLACKAMAS GOODWILL - HAPPY VALLEY
17366 SE SUNNYSIDE
ROAD
HAPPY VALLEY 97089
New
DB8
Northwest CLACKAMAS GOODWILL - LOWER BOONES FERRY
17150 BOONES FERRY RD
LOWR
LAKE OSWEGO
(OSWEGO)
97035-5214
New
DB12
Northwest CLACKAMAS GOODWILL - SANDY 37201 HIGHWAY 26 SANDY 97055 New
D55 Northwest
CLATSOP 382 Astoria Transfer Station 1790 Williamsport Road ASTORIA 97103
H5 Northwest
CLATSOP Recology yard 2320 SE 12th Pl. WARRENTON 97146
D56 Northwest
CLATSOP N/A Seaside Recycle Depot 855 Avenue S Seaside 97138
D57 Northwest
COLUMBIA 1323
Columbia County HHW & Transfer
Station 1601 RAILROAD AVENUE ST. HELENS 97051
ED4 Northwest
COLUMBIA EVENT/DOORSTEP SCAPPOOSE
D76 Western
COOS 1519 Beaver Hill Solid Waste Facility 55722 HWY 101
COOS BAY(will
cover Coquille)
97420
D77 Western
COOS 401
West Coast Recycling And Transfer Inc.
dba Public Disposal & Recycling
1210 S. BROADWAY ST. COOS BAY 97420
H6 Western
COOS Les Sanitary 3432 Cedar St. NORTH BEND 97459
DA13 Western
COOS Coquille Recycling Center SEC02,T28S,R13W COQUILLE 97423 New
D5 Eastern
CROOK 74 Crook County Landfill
5601 SW HOUSTON LAKE
RD
PRINEVILLE 97754
D6 Eastern
CROOK 482 Prineville Disposal Reload Station 1751 N MAIN ST PRINEVILLE 97754-9136
D78 Western
CURRY 414 Brookings Transfer Station
17498 CARPENTERVILLE
RD
BROOKINGS 97415
D8 Eastern
DESCHUTES 1315
Deschutes County Transfer Station and
Household Hazardous Waste Facility
61050 SE 27TH ST BEND 97702
H1 Eastern
DESCHUTES Bend Garbage and Recycling (Republic)
20835 Montana Way,
Bend, OR 97701
BEND 97701
H2 Eastern
DESCHUTES Cascade Disposal (WCN) 1300 SE Wilson Ave. BEND 97702
PP1 Eastern
DESCHUTES Central Oregon Community College
2600 NW College Way,
Bend, OR 97703
BEND 97703
D9 Eastern
DESCHUTES 430 Negus Transfer Station 2400 NE Maple Ave REDMOND 97756
H3 Eastern
DESCHUTES High desert Disposal (Republic) 1090 NE Hemlock Ave. REDMOND 97756
D10 Eastern
DESCHUTES 418 Northwest (Fryrear) Transfer Station 68200 Fryrear Rd SISTERS 97759
D11 Eastern
DESCHUTES 408 Southwest Transfer Station 54580 Hwy 97 LA PINE 97739
D7
Eastern DESCHUTES 417 Alfalfa Transfer Station WALKER ROAD BEND 97702
DB25
Eastern DESCHUTES GOODWILL - REDMOND 3399 S. HIGHWAY 97 REDMOND 97756 New
PP15 Western
DOUGLAS Sunrise Enterprises
126 W Douglas Blvd,
Winston, OR 97496
WINSTON 97496
H7 Western
DOUGLAS Southerland Sanitary Service 1050 S Calapooia St. SUTHERLIN 97479
D89 Western
DOUGLAS 464 Reedsport Transfer Station
300 REEDSPORT
TRANSFER STATION ROAD
REEDSPORT 97467
D90 Western
DOUGLAS 477 Roseburg Transfer Station 165 MCCLAIN WEST AVE. ROSEBURG 97470
D3 Eastern
GILLIAM 415 Condon Transfer Station BROWN LANE CONDON 97823
D12 Eastern
GRANT 471 Hendrix (Clark's) Transfer Station LUCE CREEK RD JOHN DAY 97845
D13 Eastern
HARNEY 1496 Burns-Hines Disposal Site (C&B Disposal) 53206 Monroe Ln. BURNS 97720
D14 Eastern
HOOD R IVER 347
Hood River Recycling & Transfer Station
+ Tri-County HHHW Collection Facility
3440 GUIGNARD DR HOOD RIVER 97031
ID Region County Pmt # Facility Name Address City Zip
D93 Western
JACKSON 483 Rogue Transfer Station & Mrf 8001 TABLE ROCK RD WHITE CITY 97503-1021
ED29 Western
JACKSON EVENT/DOORSTEP MEDFORD
ED30 Western
JACKSON EVENT/DOORSTEP MEDFORD
ED31 Western
JACKSON EVENT/DOORSTEP MEDFORD
ED32 Western
JACKSON EVENT/DOORSTEP PHOENIX
ED33 Western
JACKSON EVENT/DOORSTEP TALENT
D94 Western
JACKSON 475 Valley View Transfer Station 3000 N. VALLEY VIEW RD. ASHLAND 97520
H13 Western
JACKSON Recology Depot 220 Water St, Ashland. ASHLAND 97520
28
ED31 Western
JACKSON EVENT/DOORSTEP CENTRAL POINT
D95 Western
JACKSON N/A Southern Oregon Sanitation - Eagle Point 42 BALL RD. EAGLE POINT 97524 New
DB28
Western JACKSON GOODWILL - SOUTHERN OREGON 2077 LARS WAY MEDFORD 97501
D18 Eastern
JEFFERSON N/A Madras Sanitary Recycle Depot 1778 NW Mill St. MADRAS 97741
D98 Western
JOSEPHINE 492
Redwood Transfer Station (Souther
1381 REDWOOD AVE GRANTS PASS 97527-5519
D99 Western
JOSEPHINE N/A Republic Depot 1920 NW Washington Blvd GRANTS PASS 97526
D96 Western
JOSEPHINE 491
Josephine Recycling And Transfer Station (Republic Merlin)
1749 MERLIN ROAD GRANTS PASS 97526
D4 Eastern
KLAMATH 1712 Klamath Falls Landfill Transfer Station 801 OLD FORT RD. KLAMATH FALLS 97601
D20 Eastern
KLAMATH 47 Chemult Landfill 400 Chemult Dump Road CHEMULT 97731
D29 Eastern
KLAMATH 497 Rogue Klamath Transfer Station 4005 TINGLEY LN KLAMATH FALLS 97603
D31 Eastern
LAKE 1596 Thomas Creek Road Transfer Station
23980 THOMAS CREEK
ROAD
LAKEVIEW 97630
D108 Western
LANE 363 McKenzie Bridge Transfer Station 55805 MCKENZIE HWY BLUE RIVER 97413
D101 Western
LANE 383 Cottage Grove Transfer Station 78760 SEARS RD. COTTAGE GROVE 97424
D102 Western
LANE 384 Creswell Transfer Station 34293 E CLOVERDALE RD CRESWELL 97426-9417
D104 Western
LANE 289 Glenwood Central Receiving Station 3100 E. 17TH AVE. EUGENE 97403
Western
LANE Bring Recycling 4446 Franklin Blvd EUGENE 97403
D117 Western
LANE 458 Ecosort Material Recovery Facility 3425 E 17TH AVE EUGENE 97403-3200
PP16 Western
LANE Saint Vincent Depaul 888 Garfield St. EUGENE 97402
PP17 Western
LANE Saint Vincent Depaul 2890 Chad Dr. EUGENE 97408
PP18 Western
LANE Bottle Drop Redeption Center
2105 W Broadway,
EUGENE 97402
D103 Western
LANE 416 Florence Transfer Station 2820 RHODODENDRON DR FLORENCE 97439
PP20 Western
LANE Saint Vincent Depaul 333 Pacific Hwy W. JUNCTION CITY 97448
D115 Western
LANE 229 Vida-Leaburg Transfer Station
44041 CANAL LN (OFF
HWY. 126)
LEABURG 97489
D107 Western
LANE 253 Marcola Transfer Station
38935 SHOTGUN CREEK
ROAD
MARCOLA 97454
D109 Western
LANE 411 Oakridge Transfer Station
48977 KITSON SPRINGS
OAKRIDGE 97463
H8 Western
LANE International Paper Springfield Recycling 800 48th St, SPRINGFIELD 97478
PP19 Western
LANE Saint Vincent Depaul
4555 Main St, Springfield,
OR 97478
SPRINGFIELD 97478
D114 Western
LANE 274 Veneta Transfer Station 24444 BOLTON HILL RD VENETA 97487
D116 Western
LANE 225 Walton Transfer Station 18585 TRANSFORMER RD. WALTON 97490
D119 Western
LINCOLN N/A North Lincoln Sanitary Service 1726 SE Hwy 101 Lincoln City 97367
H9 Western
LINCOLN Dahl Disposal 235 SW Dahl Ave. WALDPORT 97394
D121 Western
LINCOLN 377
Thompson's Transfer and Disposal Inc.
("Agate Beach Transfer Station")
8096 NE AVERY ST. NEWPORT 97365
D123 Western
LINCOLN 425 Toledo Transfer Station 5441 US-20. TOLEDO 97391
D124 Western
LINN N/A Albany-Lebanon Recycling Depot 1454 Industrial Way SW ALBANY 97322
H10 Western
LINN Republic Albany Source Reduction Center
840 30th Ave SW, Albany,
OR 97321
ALBANY 97321
D125 Western
LINN 365 Sweet Home Sanitation Transfer Station 1325 18TH AVE. SWEET HOME 97386
ED34 Western
LINN EVENT/DOORSTEP LEBANON
Western
LINN EVENT/DOORSTEP *
D34 Eastern
MALHEUR 436 Ontario Sanitary Service Transfer Station 540 SE 9th Avenue ONTARIO 97914
Eastern
MALHEUR EVENT/DOORSTEP *
ID Region County Pmt # Facility Name Address City Zip
D126 Western
MARION 400 Marion Resource Recovery Fac 3680 BROOKLAKE RD NE SALEM 97303-9750
D127 Western
MARION 388 Gaffin Road Transfer Station 3250 DEER PARK RD SE SALEM 97301
D131 Western
MARION N/A Pacific Sanitation 3475 Blossom Dr NE Salem 97305
D133 Western
MARION N/A Suburban Garbage 6075 State St Salem 97317
D134 Western
MARION N/A Garten Recycling Center 3334 Industrial Way NE Salem 97303
D128 Western
MARION 1348
North Marion County Recycling
&Transfer Station
17827 WHITNEY LN NE WOODBURN 97071-9580
D130 Western
MARION N/A Loren's Sanitation 1141 Chemawa Rd N Keizer 97303
ED35 Western
MARION EVENT/DOORSTEP KEIZER New
D132 Western
MARION N/A
Republic Services of Marion County -
Silverton
830 McClaine Street Silverton 97381
DB57 Western
MARION Compost Oregon 8712 Aumsville Hwy AUMSVILLE 97325
D136 Western
MARION N/A D&O Garbage 1140 Boone Rd SE Salem 97306
P47
Western
MARION
502
Marion County Hshld HW Coll Fac
3230 DEER PARK DRIVE, SE SALEM 97301
New
D135 Western
MARION N/A Clayton Ward 3500 Mainline Drive NE Salem 97301
DB58 Western
MARION Regis High School 550 W Regis St. STAYTON 97383
D129 Western
MARION 381 Woodburn Recycle Center & TS 2215 N FRONT ST WOODBURN 97071-9732
D35 Eastern
MORROW 1261 North Morrow County Transfer Station 69900 FRONTAGE LANE BOARDMAN 97818
D37 Eastern
MORROW 406 South Morrow Transfer Station Lexington/Heppner Hwy 74 LEXINGTON 97839
29
P19
Eastern MORROW 394
Finley Buttes Regional Landfill
73221 Bombing Range
Road
Boardman 97818
D59 Northwest
MULTNOMAH 387 Environmentally Conscious Recycling-ECR 12409 NE SAN RAFAEL PORTLAND 97230
D60 Northwest
MULTNOMAH 501 Suttle Road Recovery Facility 4044 N SUTTLE RD PORTLAND 97217-7732
D62 Northwest
MULTNOMAH 1717 Far West Recycling 12820 NE MARX ST PORTLAND 97230-1067
D63 Northwest
MULTNOMAH 409 Metro Central Transfer Station 6161 NW 61ST AVE PORTLAND 97210-3675
ED14 Northwest
MULTNOMAH EVENT/DOORSTEP PORTLAND
ED15 Northwest
MULTNOMAH EVENT/DOORSTEP PORTLAND
ED16 Northwest
MULTNOMAH EVENT/DOORSTEP PORTLAND
ED17 Northwest
MULTNOMAH EVENT/DOORSTEP PORTLAND
PP4 Northwest
MULTNOMAH The Arc of Portland PORTLAND
PP5 Northwest
MULTNOMAH Ground Score PORTLAND
PP6 Northwest
MULTNOMAH James Recycling PORTLAND
PP7 Northwest
MULTNOMAH Bottle Drop Redemption Center
1176 N Hayden Meadows
Dr.
PORTLAND 97217
PP8 Northwest
MULTNOMAH Bottle Drop Redemption Center 555 NE 122nd Ave. PORTLAND 97230
D61 Northwest
MULTNOMAH 1392 Gresham Sanitary Service 2131 NW BIRDSDALE AVE GRESHAM 97030
PP10 Northwest
MULTNOMAH Gresham Habitat Restore 610 NE 181st Ave. GRESHAM 97230
PP11 Northwest
MULTNOMAH Mount Hood Community College 26000 SE Stark St. GRESHAM 97030
PP12 Northwest
MULTNOMAH Bottle Drop Redemption Center 1313 Powell Blvd GRESHAM 97030
ED18 Northwest
MULTNOMAH EVENT/DOORSTEP FAIRVIEW
PP13 Northwest
MULTNOMAH Bottle Drop 23345 NE Halsey St. WOOD VILLAGE 97060
H12 Northwest
MULTNOMAH Twelve Mile Disposal 2430 NW Marine Dr. TROUTDALE 97060
D137 Western
POLK N/A Republic Services - Dallas 1030 W. Ellendale Ave Dallas 97338
D138 Western
POLK N/A Brandt's Sanitary Service 158 Pacific Ave S Monmouth 97361
ED36 Western
POLK EVENT/DOORSTEP INDEPENDENCE
D139 Western
POLK N/A Valley Recycling & Disposal 2515 Salem/Dallas Hwy Salem 97304
P53
Eastern SHERMAN
440 Sherman County Transfer Station
OFF WELK RD, NEAR BIGGS
JUNCTION
BIGGS 97823
D66 Northwest
TILLAMOOK 395 Tillamook Transfer Station 1315 ECKLOFF RD TILLAMOOK 97141-9576
D67 Northwest
TILLAMOOK N/A City Sanitary Recycling Depot 2303 11st St. Tillamook 97141
D38 Eastern
UMATILLA N/A Milton-Freewater Recycling Depot 13 SE 9th
MILTON-
97862
D39 Eastern
UMATILLA 444 Pendleton Transfer Station REITH ROAD PENDLETON 97801
D41 Eastern
UMATILLA 429 Sanitary Disposal Transfer Station TAX LOTS 101 AND 107 HERMISTON 97838
D43 Eastern
UMATILLA N/A Umatilla Recycling Depot
No specific address: Yerxa
Umatilla 97882
D42 Eastern
UMATILLA N/A
Hemiston Recycling Depot (Sanitary
220 W. Harper Rd Hermiston 97838
D44 Eastern
UNION 442 Waste Pro Recovery Transfer Station HIGHWAY 30 LA GRANDE 97850
D46 Eastern
WALLOWA N/A Recycling Center 304 Fish Hatchery Lane Enterprise 97828
D47 Eastern
WASCO 462
The Dalles Transfer Station + Tri-County
1317 W 1ST ST THE DALLES 97058-3591
ID Region County Pmt # Facility Name Address City Zip
D72 Northwest
WASHINGTON 435 WRI Willamette Resources Inc TS/MRF 10295 SW RIDDER RD WILSONVILLE 97070
D68 Northwest
WASHINGTON 1280 Tualatin Valley Waste Recovery
3215 SE MINTER BRIDGE
HILLSBORO 97123
D70 Northwest
WASHINGTON 1718 Far West Recycling 6440 SE ALEXANDER ST HILLSBORO 97123
ED19 Northwest
WASHINGTON EVENT/DOORSTEP HILLSBORO
ED20 Northwest
WASHINGTON EVENT/DOORSTEP BEAVERTON
ED21 Northwest
WASHINGTON EVENT/DOORSTEP BEAVERTON
D69 Northwest
WASHINGTON 368 Forest Grove Transfer Station 1525 B ST FOREST GROVE 97116-2752
ED22 Northwest
WASHINGTON EVENT/DOORSTEP CORNELIUS
D71 Northwest
WASHINGTON 422 Pride Recycling Company
13910 SW TUALATIN
SHERWOOD 97140-9726
ED23 Northwest
WASHINGTON EVENT/DOORSTEP TIGARD
ED24 Northwest
WASHINGTON EVENT/DOORSTEP TUALATIN
ED25 Northwest
WASHINGTON EVENT/DOORSTEP ex
ED26 Northwest
WASHINGTON EVENT/DOORSTEP ex New
ED27 Northwest
WASHINGTON EVENT/DOORSTEP ex
DA61
Northwest WASHINGTON Aloha Garbage & Recycling 20525 SW Blanton st. Beaverton 97007 New
P37
Northwest WASHINGTON 403 Hillsboro Garbage and Disposal
4945 SW Minter Bridge
HILLSBORO 97045
DB91
Northwest WASHINGTON GOODWILL - TIGARD 13920 SW PACIFIC HWY TIGARD 97223-4839
D48 Eastern
WHEELER 472
Fossil Solid Waste Transfer Station And
17487 BLACK BUTTE,
FOSSIL 97830
D140 Western
YAMHILL 366 Newberg Transfer And Recycling Center 2904 WYNOOSKI RD. NEWBERG 97132
ED37 Western
YAMHILL EVENT/DOORSTEP LAFAYETTE
ED38 Western
YAMHILL EVENT/DOORSTEP SHERIDAN
H14 Western
YAMHILL Riverbend Landfill 13469 SW HIGHWAY 18 MCMINNVILLE 97128 New
D141 Western
YAMHILL 1258 Valley Recovery Zone 2200 NE ORCHARD AVE MCMINNVILLE 97128 Ne w
DB95
Western YAMHILL GOODWILL - MCMINNVILLE STORE 1371 N 99W MCMINNVILLE 97128
DB96
Western YAMHILL GOODWILL - NEWBERG 2310 PORTLAND RD NEWBERG 97132-1367
Sites 142
Events 31
Total 173
New 12
30
County Name
Certified July 1st,
2023 Population
Estimates (PRC)
Population Covered
by Existing Sites
(Based on 2020
Census)
Collection Points
Required (Base
Convenience
Standard)
State of Oregon 4,291,525 97.5% 113
Baker 16,927 73.6% 1
Benton 99,355 98.9% 3
Clackamas 424,043 99.8% 8
Clatsop 42,095 95.6% 2
Columbia 53,143 72.4% 2
Coos 66,945 97.9% 2
Crook 26,583 97.9% 1
Curry 24,439 70.3% 1
Deschutes 212,141 99.9% 6
Douglas 113,748 91.4% 3
Gilliam 2,062 50.3% 1
Grant 7,418 64.3% 1
Harney 7,600 80.6% 1
Hood River 24,406 93.9% 1
Jackson 222,762 98.9% 6
Jefferson 25,878 98.0% 1
Josephine 88,814 88.1% 3
Klamath 71,919 80.8% 2
Lake 8,562 63.1% 1
Lane 384,374 100.0% 10
Lincoln 51,930 99.3% 2
Linn 131,984 98.1% 4
Malheur 32,981 85.0% 1
Marion 352,249 99.5% 9
Morrow 13,010 97.3% 1
Multnomah 801,306 100.0% 14
Polk 90,553 98.3% 3
Sherman 1,917 50.0% 1
Tillamook 28,000 80.4% 1
Umatilla 81,842 98.6% 3
Union 26,335 84.7% 1
Wallowa 7,631 79.1% 1
Wasco 27,052 88.9% 1
Washington 610,245 99.9% 11
Wheeler 1,533 44.2% 1
Yamhill 109,743 99.4% 3
Notes:
@ Supported by events
© Supported by curbside collection and/or events
31
Collection Points
Required (Enhanced
Convenience
Standard)
Meets Base
Meets
Enhanced
Proposed
Optimized
Collection
Points
140 Passes Passes 173
1 Passes Passes 1
4 Passes Passes 4
10 Passes Passes 12
2 Passes Passes 3
2 Passes Passes 2
3 Passes Passes 4
1 Passes Passes 2
1 Passes Passes 1
8 Passes Passes 10
4 Passes Passes 4
1 Passes Passes 1
1 Passes Passes 1
1 Passes Passes 1
1 Passes Passes 1
8 Passes Passes 11
1 Passes Passes 1
3 Passes Passes 3
3 Passes Passes 3
1 Passes Passes 1
13 Passes Passes 18
2 Passes Passes 4
5 Passes Passes 5 @
2 Passes Passes 2 @
12 Passes Passes 15
1 Passes Passes 3
18 Passes Passes 20 ©
4 Passes Passes 4
1 Passes Passes 1
1 Passes Passes 2
3 Passes Passes 5
1 Passes Passes 1
1 Passes Passes 1
1 Passes Passes 1
14 Passes Passes 17 ©
1 Passes Passes 1
4 Passes Passes 7
32
County Name
(primary if multiple)
City Name
Certified July 1st,
2023 Population
Estimates (PRC)
Population Covered
by Existing Sites
(Based on 2020
Census)
Collection Points
Required (Base
Convience Standard)
Collection Points
Required (Enhanced
Convience Standard)
Meets Base
Meets
Enhanced
Proposed
Optimized
Collection
Points
Baker Baker City 10,102 100.0% 1 1 Passes Passes 1 *
Baker Greenhorn 3 0.0% 0 0 Passes Passes 0
Baker Haines 382 0.0% 0 0 Passes Passes 0
Baker Halfway 358 0.0% 0 0 Passes Passes 0
Baker Huntington 508 0.0% 0 0 Passes Passes 0
Baker Richland 166 0.0% 0 0 Passes Passes 0
Baker Sumpter 207 0.0% 0 0 Passes Passes 0
Baker Unity 40 0.0% 0 0 Passes Passes 0
Benton Adair Village 1,496 100.0% 0 0 Passes Passes 0
Benton Corvallis 61,669 100.0% 2 3 Passes Passes 3
Benton Monroe 763 100.0% 0 0 Pas ses Passes 0
Benton Philomath 5,823 100.0% 0 1 Passes Passes 1
Clackamas Barlow 140 100.0% 0 0 Pas ses Passes 0
Clackamas Canby 19,045 100.0% 1 1 Passes Passes 1
Clackamas Estacada 5,750 100.0% 0 0 Passes Passes 0
Clackamas Gladstone 12,140 100.0% 0 1 Passes Passes 1
Clackamas Happy Valley 26,799 100.0% 1 1 Passes Passes 1
Clackamas Johnson City 510 100.0% 0 0 Passes Passes 0
Clackamas Lake Oswego 41,396 100.0% 1 1 Passes Passes 1
Clackamas Milwaukie 21,341 100.0% 1 1 Passes Passes 1
Clackamas Molalla 10,335 100.0% 0 1 Passes Passes 1
Clackamas Oregon City 38,049 100.0% 1 1 Passes Passes 1
Clackamas Rivergrove 559 100.0% 0 0 Pas ses Passes 0
Clackamas Sandy 13,159 100.0% 0 1 Passes Passes 1
Clackamas West Linn 27,360 100.0% 1 1 Passes Passes 1
Clackamas Wilsonville 27,634 100.0% 1 1 Passes Passes 1
Clatsop Astoria 10,167 100.0% 1 1 Passes Passes 1
Clatsop Cannon Beach 1,555 100.0% 0 0 Passes Passes 0
Clatsop Gearhart 1,933 100.0% 0 0 Passes Passes 0
Clatsop Seaside 7,393 100.0% 1 1 Passes Passes 1
Clatsop Warrenton 6,462 100.0% 0 1 Passes Passes 1
Columbia Clatskanie 1,767 0.0% 0 0 Passes Passes 0
Columbia Columbia City 1,935 100.0% 0 0 Passes Passes 0
Columbia Prescott 82 100.0% 0 0 Passes Passes 0
Columbia Rainier 1,933 0.0% 0 0 Passes Passes 0
Columbia Sc appoose 8,254 100.0% 1 1 Passes Passes 1
Columbia St. Helens 15,009 100.0% 1 1 Passes Passes 1
Columbia Vernonia 2,426 0.0% 0 0 Passes Passes 0
Coos Bandon 3,866 100.0% 0 0 Passes Passes 0
Coos Coos Bay 16,533 100.0% 1 1 Passes Passes 1
Coos Coquille 4,052 100.0% 0 1 Pas ses Passes 1
Coos Lakeside 1,952 100.0% 0 0 Passes Passes 0
Coos Myrtle Point 2,508 100.0% 0 0 Passes Passes 0
Coos North Bend 10,769 100.0% 1 1 Passes Passes 1
Coos Powers 759 0.0% 0 0 Passes Passes 0
Crook Prineville 11,598 100.0% 1 1 Passes Passes 1
Curry Brookings 7,161 100.0% 1 1 Passes Passes 1 *
Curry Gold Beach 2,450 53.2% 0 0 Passes Passes 0
Curry Port Orford 1,181 0.0% 0 0 Passes Passes 0
Deschutes Bend 106,275 100.0% 4 4 Passes Passes 4 *
Deschutes La Pine 3,126 100.0% 0 0 Passes Passes 0
Deschutes Redmond 38,208 100.0% 2 2 Passes Passes 2
Deschutes Sisters 3,823 100.0% 0 0 Passes Passes 0
Douglas Canyonville 1,703 49.7% 0 0 Passes Passes 0
Douglas Drain 1,195 97.0% 0 0 Passes Passes 0
Douglas Elkton 193 0.0% 0 0 Passes Passes 0
Douglas Glendale 871 0.0% 0 0 Passes Passes 0
Douglas Myrtle Creek 3,626 100.0% 0 0 Passes Passes 0
Douglas Oakland 968 100.0% 0 0 Passes Passes 0
Douglas Reedsport 4,395 100.0% 0 1 Passes Passes 1 *
Douglas Riddle 1,248 100.0% 0 0 Passes Passes 0
Douglas Roseburg 24,258 100.0% 1 1 Passes Passes 1 *
Douglas Sutherlin 9,001 100.0% 1 1 Passes Passes 1
Douglas Winston 5,771 100.0% 0 1 Passes Passes 1
Douglas Yoncalla 1,078 0.0% 0 0 Passes Passes 0
Gilliam Arlington 670 0.0% 0 0 Passes Passes 0
Gilliam Condon 726 100.0% 0 0 Passes Passes 0
Gilliam Lonerock 25 0.0% 0 0 Passes Passes 0
Grant Canyon City town 687 100.0% 0 0 Passes Passes 0
Grant Dayville town 142 0.0% 0 0 Passes Passes 0
Grant Granite 33 0.0% 0 0 Passes Passes 0
Grant John Day 1,704 100.0% 0 0 Passes Passes 0
Grant Long Creek 179 0.0% 0 0 Pas ses Passes 0
Grant Monument 118 0.0% 0 0 Passes Passes 0
Grant Mount Vernon 563 100.0% 0 0 Passes Passes 0
Grant Prairie City 861 0.0% 0 0 Passes Passes 0
Grant Seneca 175 0.0% 0 0 Passes Passes 0
Harney Burns 2,730 100.0% 0 0 Passes Passes 0
Harney Hines 1,705 100.0% 0 0 Passes Passes 0
Hood River Cascade Locks 1,400 0.0% 0 0 Passes Passes 0
Hood River Hood River 8,577 100.0% 1 1 Passes Passes 1 *
County Name
(primary if multiple)
City Name
Certified July 1st,
2023 Population
Estimates (PRC)
Population Covered
by Existing Sites
(Based on 2020
Census)
Collection Points
Required (Base
Convience Standard)
Collection Points
Required (Enhanced
Convience Standard)
Meets Base
Meets
Enhanced
Proposed
Optimized
Collection
Points
Jackson Ashland 21,457 100.0% 1 1 Pass es Passes 1
Jackson Butte Falls town 440 100.0% 0 0 Passes Passes 0
Jackson Central Point 19,666 100.0% 1 1 Passes Passes 1 @
Jackson Eagle Point 9,955 100.0% 1 1 Passes Passes 1 *
Jackson Gold Hill 1,338 100.0% 0 0 Passes Passes 0
Jackson Jacksonville 3,197 100.0% 0 0 Passes Passes 0
Jackson Medford 90,887 100.0% 3 4 Passes Passes 4
Jackson Phoenix 3,773 100.0% 0 0 Passes Passes 1
Jackson Rogue River 2,472 100.0% 0 0 Passes Passes 0
Jackson Shady Cove 3,097 100.0% 0 0 Pas ses Passes 0
Jackson Talent 5,228 100.0% 0 1 Passes Passes 1
33
Jefferson Culver 1,666 100.0% 0 0 Pas ses Passes 0
Jefferson Madras 8,099 100.0% 1 1 Pas ses Passes 1
Jefferson Metolius 1,005 100.0% 0 0 Passes Passes 0
Josephine Cave Junction 2,163 0.0% 0 0 Passes Passes 0
Josephine Grants Pass 40,102 100.0% 2 2 Passes Passes 2
Klamath Bonanza town 401 0.0% 0 0 Passes Passes 0
Klamath Chiloquin 775 0.0% 0 0 Passes Passes 0
Klamath Klamath Falls 22,966 100.0% 1 1 Passes Passes 1 *
Klamath Malin 745 0.0% 0 0 Passes Passes 0
Klamath Merrill 867 0.0% 0 0 Passes Passes 0
Lake Lakeview town 2,476 100.0% 0 0 Passes Passes 0
Lake Paisley 248 0.0% 0 0 Passes Passes 0
Lane Coburg 1,475 100.0% 0 0 Passes Passes 0
Lane Cottage Grove 11,095 100.0% 1 1 Passes Passes 1
Lane Creswell 5,823 100.0% 0 1 Passes Passes 1 *
Lane Dunes City 1,454 100.0% 0 0 Passes Passes 0
Lane Eugene 177,339 100.0% 6 6 Passes Passes 6 *
Lane Florence 9,832 100.0% 1 1 Passes Passes 1
Lane Junction City 7,427 100.0% 1 1 Passes Passes 1
Lane Lowell 1,261 100.0% 0 0 Passes Passes 0
Lane Oakridge 3,235 100.0% 0 0 Passes Passes 0
Lane Springfield 63,078 100.0% 2 3 Passes Pass es 4
Lane Veneta 5,261 100.0% 0 1 Passes Passes 1 *
Lane Westfir 261 100.0% 0 0 Passes Passes 0
Lincoln Depoe Bay 1,569 100.0% 0 0 Passes Passes 0
Lincoln Lincoln City 10,372 100.0% 1 1 Passes Passes 1
Lincoln Newport 11,083 100.0% 1 1 Passes Passes 1
Lincoln Siletz 1,242 100.0% 0 0 Passes Passes 0
Lincoln Toledo 3,622 100.0% 0 0 Passes Passes 1
Lincoln Waldport 2,350 100.0% 0 0 Passes Passes 1
Lincoln Yachats 1,006 100.0% 0 0 Passes Passes 0
Linn Albany 57,997 100.0% 2 2 Passes Passes 2
Linn Brownsville 1,846 100.0% 0 0 Passes Passes 0
Linn Halsey 952 100.0% 0 0 Passes Passes 0
Linn Harrisburg 3,660 100.0% 0 0 Passes Passes 0
Linn Lebanon 20,329 100.0% 1 1 Passes Passes 1
Linn Lyons 1,203 100.0% 0 0 Passes Passes 0
Linn Mill City 2,066 0.0% 0 0 Passes Passes 0
Linn Millersburg 3,206 100.0% 0 0 Passes Passes 0
Linn Scio 949 100.0% 0 0 Passes Passes 0
Linn Sodaville 357 100.0% 0 0 Passes Passes 0
Linn Sweet Home 10,028 100.0% 1 1 Pas ses Passes 1
Linn Tangent 1,218 100.0% 0 0 Passes Passes 0
Linn Waterloo town 216 100.0% 0 0 Passes Passes 0
Malheur Adrian 159 0.0% 0 0 Passes Passes 0
Malheur Jordan Valley 133 0.0% 0 0 Passes Passes 0
Malheur Nyssa 3,363 100.0% 0 0 Passes Passes 0
Malheur Ontario 12,206 100.0% 1 1 Passes Passes 1
Malheur Vale 1,947 97.8% 0 0 Pas ses Passes 0
Marion Aumsville 4,227 100.0% 0 1 Passes Passes 1
Marion Aurora 1,119 100.0% 0 0 Passes Passes 0
Marion Detroit 134 0.0% 0 0 Passes Passes 0
Marion Donald 1,003 100.0% 0 0 Passes Passes 0
Marion Gates 552 0.0% 0 0 Passes Passes 0
Marion Gervais 2,789 100.0% 0 0 Passes Passes 0
Marion Hubbard 3,491 100.0% 0 0 Passes Passes 0
Marion Idanha 154 0.0% 0 0 Pass es Passes 0
Marion Jefferson 3,425 100.0% 0 0 Passes Passes 0
Marion Keizer 39,169 100.0% 2 2 Passes Passes 2
Marion Mount Angel 3,538 100.0% 0 0 Passes Passes 0
Marion Salem 182,726 100.0% 6 7 Passes Passes 7
Marion Scotts Mills 442 100.0% 0 0 Passes Passes 0
Marion Silverton 10,660 100.0% 1 1 Passes Passes 1
Marion St. Paul 435 100.0% 0 0 Passes Passes 0
Marion Stayton 8,295 100.0% 1 1 Passes Passes 1
Marion Sublimity 3,233 100.0% 0 0 Passes Passes 0
Marion Turner 2,882 100.0% 0 0 Passes Passes 0
Marion Woodburn 27,044 100.0% 1 1 Passes Passes 1
Morrow Boardman 4,437 100.0% 0 1 Passes Passes 1 *
Morrow Heppner 1,211 100.0% 0 0 Passes Passes 0
Morrow Ione 337 100.0% 0 0 Passes Passes 0
Morrow Irrigon 2,133 100.0% 0 0 Passes Passes 0
Morrow Lexington town 243 100.0% 0 0 Passes Passes 0
Multnomah Fairview 10,671 100.0% 0 1 Passes Passes 1
Multnomah Gresham 117,107 100.0% 2 3 Passes Passes 4
Multnomah Maywood Park 793 100.0% 0 0 Passes Passes 0
Multnomah Portland 648,097 100.0% 9 13 Passes Passes 13 ©
Multnomah Troutdale 17,005 100.0% 1 1 Passes Passes 1
Multnomah Wood Village 5,038 100.0% 0 0 Passes Passes 1
County Name
(primary if multiple)
City Name
Certified July 1st,
2023 Population
Estimates (PRC)
Population Covered
by Existing Sites
(Based on 2020
Census)
Collection Points
Required (Base
Convience Standard)
Collection Points
Required (Enhanced
Convience Standard)
Meets Base
Meets
Enhanced
Proposed
Optimized
Collection
Points
Polk Dallas 17,989 100.0% 1 1 Passes Passes 1
Polk Falls City 1,066 100.0% 0 0 Passes Passes 0
Polk Independence 10,274 100.0% 1 1 Passes Passes 1
Polk Monmouth 11,019 100.0% 1 1 Passes Passes 1
Sherman Grass Valley 155 0.0% 0 0 Passes Passes 0
Sherman Moro 369 0.0% 0 0 Passes Passes 0
Sherman Rufus 272 0.0% 0 0 Passes Passes 0
Sherman Wasco 417 0.0% 0 0 Passes Passes 0
Tillamook Bay City 1,646 100.0% 0 0 Pas ses Passes 0
Tillamook Garibaldi 837 100.0% 0 0 Passes Passes 0
Tillamook Manzanita 646 0.0% 0 0 Pas ses Passes 0
Tillamook Nehalem 290 0.0% 0 0 Passes Passes 0
Tillamook Rockaway Beach 1,538 100.0% 0 0 Passes Passes 0
Tillamook Tillamook 5,277 100.0% 0 1 Passes Passes 1
Tillamook Wheeler 428 0.0% 0 0 Pass es Passes 0
Umatilla Adams 404 100.0% 0 0 Passes Passes 0
Umatilla Athena 1,200 100.0% 0 0 Passes Passes 0
Umatilla Echo 638 100.0% 0 0 Passes Passes 0
34
Umatilla Helix 193 100.0% 0 0 Passes Passes 0
Umatilla Hermiston 20,322 100.0% 1 1 Passes Passes 1
Umatilla Milton-Freewater 7,490 100.0% 1 1 Passes Passes 1
Umatilla Pendleton 17,006 100.0% 1 1 Passes Passes 1
Umatilla Pilot Rock 1,332 100.0% 0 0 Passes Passes 0
Umatilla Stanfield 2,313 100.0% 0 0 Pas ses Passes 0
Umatilla Ukiah 219 0.0% 0 0 Pass es Passes 0
Umatilla Umatilla 7,810 100.0% 1 1 Passes Passes 1
Umatilla Wes ton 696 100.0% 0 0 Passes Passes 0
Union Cove 662 100.0% 0 0 Passes Passes 0
Union Elgin 1,911 0.0% 0 0 Passes Passes 0
Union Imbler 247 100.0% 0 0 Passes Passes 0
Union Island City 1,166 100.0% 0 0 Passes Passes 0
Union La Grande 13,558 100.0% 1 1 Passes Passes 1
Union North Powder 498 0.0% 0 0 Passes Passes 0
Union Summerville town 114 100.0% 0 0 Passes Passes 0
Union Union 2,182 100.0% 0 0 Passes Passes 0
Wallowa Enterprise 2,147 100.0% 0 0 Passes Passes 1
Wallowa Joseph 1,179 100.0% 0 0 Passes Passes 0
Wallowa Lostine 246 100.0% 0 0 Passes Passes 0
Wallowa Wallowa 812 0.0% 0 0 Passes Passes 0
Wasco Antelope 35 0.0% 0 0 Pass es Passes 0
Wasco Dufur 635 100.0% 0 0 Passes Passes 0
Wasco Maupin 435 0.0% 0 0 Passes Passes 0
Wasco Mosier 481 100.0% 0 0 Passes Passes 0
Wasco Shaniko 30 0.0% 0 0 Passes Passes 0
Wasco The Dalles 16,417 100.0% 1 1 Passes Passes 1
Washington Banks 1,910 100.0% 0 0 Passes Passes 0
Washington Beaverton 101,165 100.0% 2 3 Passes Passes 3 ©
Washington Cornelius 14,387 100.0% 1 1 Passes Passes 1
Washington Durham 1,938 100.0% 0 0 Passes Passes 0
Washington Forest Grove 27,551 100.0% 1 1 Passes Passes 1
Washington Gaston 674 100.0% 0 0 Passes Passes 0
Washington Hillsboro 110,874 100.0% 2 3 Passes Passes 3 ©
Washington King City 5,177 100.0% 0 0 Passes Passes 0
Washington North Plains 3,663 100.0% 0 0 Passes Passes 0
Washington Sherwood 20,868 100.0% 1 1 Passes Passes 1
Washington Tigard 55,868 100.0% 1 2 Passes Passes 2
Washington Tualatin 27,910 100.0% 1 1 Passes Passes 1
Wheeler Fossil 455 100.0% 0 0 Passes Passes 0
Wheeler Mitchell 137 0.0% 0 0 Passes Passes 0
Wheeler Spray town 201 0.0% 0 0 Passes Passes 0
Yamhill Amity 1,826 100.0% 0 0 Passes Passes 0
Yamhill Carlton 2,425 100.0% 0 0 Passes Passes 0
Yamhill Dayton 2,704 100.0% 0 0 Passes Passes 0
Yamhill Dundee 3,265 100.0% 0 0 Passes Passes 0
Yamhill Lafayette 4,714 100.0% 0 1 Passes Passes 1
Yamhill McMinnville 34,612 100.0% 1 2 Pas ses Passes 2
Yamhill Newberg 26,728 100.0% 1 1 Passes Passes 1
Yamhill Sheridan 5,987 100.0% 0 1 Passes Passes 1
Yamhill Willamina 2,301 100.0% 0 0 Passes Passes 0
Yamhill Yamhill 1,165 100.0% 0 0 Pas ses Passes 0
Notes:
* Site adjacent to city boundary
@ Supported by events
© Supported by curbside collection and/or events
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Appendix G:
Detailed Fee-Setting Methodology
(confidential)
Appendix G is confidential and has been shared with DEQ separately.
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Appendix H:
CAA Articles of Incorporation
Appendix H:
CAA - Articles of Incorporation
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
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


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





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
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
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Appendix I:
501(c)3 Letter of Determination
Department of the Treasury
Internal Revenue Service
Tax Exempt and Government Entities
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
Letter
947 (Rev. 2-2020)
Catalog Number 35152P
A
ppendix
I:
CAA
-
Determination
L
etter
49
50
51
circularactionalliance.org
Appendix J:
Proof of Registration as a Charitable Organization
ELLEN F. ROSENBLUM 100 SW Market Street
Attorney General Portland, Oregon 97201
FAX: (971) 673-1882
LISA M. UDLAND Telephone: (971) 673-1880
Deputy Attorney General TTY (800) 735-2900
charitable@doj.state.or.us
www.doj.state.or.us
DEPARTMENT OF JUSTICE
PORTLAND OFFICE
November 29, 2023
Circular Action Alliance
20 F Street NW, 7th Floor
Washington, DC 20001 Registration #64847
Re: Registration under the Charitable Trust and Corporation Act
and Required Annual Reports
Dear Officers/Directors:
This will acknowledge registration of your organization under the Charitable Trust and Corporation Act.
Your registration number with this office is 64847.
According to the above mentioned Act, annual reports (form CT-12, CT-12F or CT-12S) will be due no
later than four months and 15 days after the close of your accounting period. Our records indicate that
your accounting period ends on December 31st. Your annual reports will be due by May 15th of each
year. Reporting forms will automatically be sent to you. If you do not receive forms within 60 days prior
to the due date for filing your report, you can contact this office to obtain the prescribed forms or find
them at www.doj.state.or.us/charitable-activities/annual-reporting-for-charities/file-your-annual-report.
Depending on the date of your organization’s registration, the due date for its initial annual report may be
different than the usual due date described above.
Questions about annual reports should be directed to the Annual Report Specialist at (971) 673-1880.
Please note that our annual reports are in addition to and different from the annual reports that nonprofit
corporations must file with the Oregon Corporation Division, Office of the Secretary of State.
Please keep this letter with your permanent records as it contains your registration number.
Sincerely,
Wendy Lambo
Wendy Lambo
Charities Registrar
Charitable Activities Section
Appendix J:
CAA - Proof of Charitable
Organization in Oregon
52
53
circularactionalliance.org
Appendix K:
Proof of Registration – Foreign Corporation
Appendix K:
CAA - Proof of Registration Foreign Corporation in Oregon
54
55
circularactionalliance.org
Appendix L:
CAA Revised Bylaws
BYLAWS
of
CIRCULAR ACTION ALLIANCE
ARTICLE I
Name, Registered Agent, and Offices
Section 1.01. Name. The name of this corporation (hereinafter referred to as the
“Corporation”) shall be Circular Action Alliance.
Section 1.02. Registered Agent and Offices. The Corporation shall maintain in the
District of Columbia a registered agent. The Corporation may have offices inside or outside of the
District of Columbia as the Board of Directors of the Corporation (the “Board”) may designate or
as the business of the Corporation may require from time to time.
ARTICLE II
Purposes and Limitations
Section 2.01 Purposes and Limitations. The Corporation is organized as a nonprofit
corporation under the District of Columbia Nonprofit Corporation Act of 2010, as amended from
time to time (the “Act”), for the purposes as set forth in the Corporation’s Articles of Incorporation.
ARTICLE III
Members
Section 3.01 Membership Classes. The Corporation shall have one class of members
known as Founding Members. The Founding Members of the Corporation are those companies
who have been approved by the Board to be a Founding Member, agreed to support the purposes
of the Corporation and entered into a Membership Agreement with the Corporation. Founding
Members shall each be eligible to appoint one Director to serve on the Board and shall have no
other governance rights.
Section 3.02 Resignation and Termination of Membership. Membership in the
Corporation may be terminated by the member’s submission of written notice of membership
resignation or non-renewal to the Corporation, or by the Board for cause by the affirmative vote
of a majority of the Directors present at a meeting of the Board called for the purpose of
considering termination of the member and at which a quorum is present. Circumstances
constituting “cause” shall be solely determined by the Board, and includes but is not limited to (i)
failure to timely pay fees, membership dues, or assessments, (ii) failure or refusal to comply with
the Membership Agreement, or (iii) engaging in conduct that is detrimental to the reputation,
mission, or operations of the Corporation. Prior to terminating or expelling a member for cause,
Appendix L: CAA Bylaws
56
the member shall be provided prior notice of the proposed termination or expulsion and the reasons
therefor, and be provided an opportunity to be heard, orally or in writing as determined by the
Board using such reasonable procedures for hearing as determined by the Board, before the
effective date of the termination or expulsion.
Section 3.03 Effect and Timing of Termination and Resignation. The termination, non-
renewal, or resignation of membership shall not extinguish or relieve such member’s financial
obligations then accrued pursuant to Section 8.02, including unpaid dues, fees, assessments,
or other charges previously accrued, if any. The termination of membership shall take
effect immediately or as of a later date determined by the Board. The resignation of
membership shall take effect at the time specified in the notice of resignation, or, if no time is
specified, at the time such resignation is tendered. The non-renewal of membership will take
effect as of the expiration of the then-current term of membership at the time the notice of non-
renewal is provided.
ARTICLE IV
Board of Directors
Section 4.01. General Powers. The affairs of the Corporation shall be managed by
its Board. It shall be the Board’s duty to carry out the objectives and purposes of the
Corporation, and to this end the Board may exercise all powers of the Corporation, except such
powers reserved to the Members as provided in the Act, the Articles of Incorporation, or these
Bylaws.
Section 4.02. Election, Number, and Term of Office. The Board shall consist of
the number of Founding Members of the Corporation. Each Founding Member shall appoint
one person to serve as a Director, and such person shall serve as a Director until the member
appoints a different person to serve as the Director. Founding Member Directors shall serve one-
year terms of office and until their successors take office. Founding Member Directors may serve
consecutive terms of office.
Section 4.03. Board Meeting. The Board shall hold an annual meeting at a time and
place determined by the Board for the purpose of transacting such business as may properly
come before the meeting. The Board may also hold other regular Board meetings at such times
and places as may be determined by the Chair or the Board. Special meetings of the Board may
be called by or at the request of the Chair or at least 20% of the Directors of the Corporation and
shall be held at such time and place as set by the Directors calling the meeting.
Section 4.04. Notice. Notice of the place, if any, date, and time of each regular meeting
of the Board shall be given to each Director by mail, overnight courier, e-mail, other mode
of written communication or over the telephone not less than 24 hours before the time set for
such a meeting. Notice of the place, if any, date, and time of each special meeting of the Board
shall be given to each Director by mail at least two days before the special meeting, or by
telephone or electronic transmission (including e-mail) or delivery in person not later than the
day before the day of the meeting. Notice shall be deemed effective if given in person or by
telephone, mail addressed to such Director at such Director’s physical or e-mail address as it
appears on the records of the Corporation, or by other means of electronic transmission.
57
Notice may be waived in writing, prior to or after the meeting, by those Directors not
present. Attendance at a meeting in person shall constitute a waiver of notice of such meeting,
except where the Director attends such meeting for the express purpose of objecting, at the
commencement of the meeting, to the transaction of any business because the meeting was not
lawfully called or convened.
Section 4.05. Quorum and Manner of Acting. A majority of the Directors in office shall
constitute a quorum for the transaction of business at any meeting of the Board, provided, that if
less than a majority of the Directors are present at any meeting, a majority of the Directors present
may adjourn the meeting from time to time without further notice. The act of a majority of the
Directors then in office at a meeting at which a quorum is present shall be the act of the Board
except when a greater vote is required by the Act or by these Bylaws. Directors shall not be
permitted to vote by proxy.
Section 4.06. Teleconferencing. Any person participating in a meeting of the Board may
participate by means of telephone or video conference or by any means of communication by
which all persons participating in the meeting are able to hear one another, and otherwise fully
participate in the meeting. Such participation shall constitute presence in person at the meeting.
Section 4.07. Action by Unanimous Written Consent. Board action may be taken
without a meeting if all the voting Directors consent thereto in writing (including by electronic
transmission).
Section 4.08. Removal or Resignation of Directors. Any Director may be removed from
office with or without cause by the Board provided advance written notice of the intent to remove
is provided to the Founding Member whose Director is being removed. Any Director may resign
at any time by giving written notice to the Chair or the Secretary of the Corporation. Such
resignation shall take effect at the time specified in such notice, or, if no time is specified, at the
time such resignation is tendered.
Section 4.09. Vacancies. Any vacancy occurring in the Board, or any Directorship to be
filled by reason of an increase in the number of Directors, may be filled at any time in the same
manner in which regular appointments are made. A Director selected to fill a vacancy shall be
elected for the unexpired term of his or her predecessor in office.
Section 4.10. Compensation. Directors and Officers shall not receive any compensation
for their services as such; provided, however, that Officers and Directors are not precluded from
serving the Corporation in any other capacity and receiving reasonable compensation for such
service with the approval of the Board.
ARTICLE V
Officers
Section 5.01. Officers. The Officers of the Corporation shall be a Chair, Vice Chair,
Treasurer, Secretary, and President, and such other Officers as may be determined by the Board,
each to have such duties and authority as may be specified in these Bylaws or as shall be prescribed
by the Board. The offices of President (or if there is no President, then Chair) and Treasurer may
58
not be held by the same person; otherwise, the same individual may simultaneously hold more
than one office.
Section 5.02. Election and Term. The Officers of the Corporation shall be elected by the
Board at any meeting of the Board. Each Officer other than the President shall hold office for a
one-year term; provided, however, that Officers shall serve until their successors are duly elected
and qualified. The President shall serve at the pleasure of the Board. There shall be no limit on the
number of terms, consecutive or otherwise, that an Officer may serve.
Section 5.03. Removal or Resignation of Officers. Any Officer may be removed from
office at any time by the Board whenever in the Board’s sole judgment the best interests of the
Corporation would be served thereby. Any officer may resign at any time by giving written notice
to the Secretary of the Corporation. Such resignation shall take effect at the time specified in such
notice, or, if no time is specified, at the time such resignation is tendered.
Section 5.04. Vacancies. A vacancy in any officership, because of death, resignation,
removal, disqualification, or otherwise, may be filled at any time by the Board for the unexpired
portion of the term. Vacancies may be filled or new offices created and filled at any meeting of
the Board.
Section 5.05. Chair. The Chair shall preside at all meetings of the Board. If the
Corporation does not have a President, then the Chair shall also have the powers otherwise given
to the President of the Corporation and, subject to the control and direction of the Board, shall
supervise and control all the affairs of the Corporation until such time as a President is appointed.
The Chair in general shall perform all duties incident to the office of Chair and such other duties
as may be prescribed by the Board from time to time.
Section 5.06 Vice Chair. The Vice Chair shall assume the duties of the Chair in the
Chair's absence or incapacity and perform such other duties as from time to time may be assigned
by the Chair or by the Board.
Section 5.07. Treasurer. The Treasurer shall have charge and custody of and be
responsible for, all funds and securities of the Corporation; receive and give receipts for monies
due and payable to the Corporation from any sources whatsoever; and deposit all such monies in
the name of the Corporation in such banks, trust companies, or other depositories as shall be
selected in accordance with the provisions of these Bylaws. The Treasurer shall keep or cause to
be kept complete and accurate financial records of the Corporation and in general shall perform
all of the duties incident to the office of Treasurer and such other duties as from time to time may
be assigned by the Chair or by the Board.
Section 5.08. Secretary. The Secretary shall record or cause to be recorded the minutes
of all meetings of the Board; maintain such minutes in the Corporation’s permanent records as
required under the Act; see that all notices are duly given in accordance with the provisions of
these Bylaws or as required by law; be the custodian of the corporate records, and in general
perform all of the duties incident to the office of Secretary and such other duties as from time to
time may be assigned by the Chair or by the Board.
59
Section 5.09. President. The Board shall select and employ a President (who may have
the title of President or President and Chief Executive Officer) who shall be a corporate officer
and responsible for the administration and management of the Corporation’s business and
operations. Subject to the oversight of the Board, the President shall: supervise, coordinate and
manage the Corporation’s day-to-day business and activities; formulate plans and advise on
policies for the accomplishment of the Corporation’s objectives; prepare an annual budget for
approval by the Board; have charge of the Corporation’s funds, discharge its obligations, and
maintain its accounts; carry into effect all directions and resolutions of the Board; and perform
such other duties and have such other powers as may be prescribed by the Board or these Bylaws.
The President shall report to the Board and keep the Board apprised of his or her activities in
carrying out his or her duties hereunder. The President shall serve at the pleasure of the Board of
Directors. Any removal of the President will be without prejudice to his or her rights under a
contract of employment, and the appointment of such person shall not itself create contract rights.
ARTICLE VI
Committees
Section 6.01. Committees of the Board. The Board may, by resolution adopted by a
majority of all the Directors then in office, create one or more committees, each consisting solely
of three or more Directors, to serve at the discretion of the Board (each a “Board Committee”).
Board Committees shall have and exercise the authority of the Board in the management of the
Corporation, to the extent provided in the respective Board resolution. Notwithstanding the
foregoing, a Board Committee may not (i) authorize distributions; (ii) approve or propose to the
Founding Members action required by the Act to be approved by the Founding Members; (iii) fill
vacancies on the Board or any Board Committee; or (iv) adopt, amend, or repeal these Bylaws.
The designation and delegation of authority to a Board Committee shall not operate to relieve the
Board, or any individual Director, of any responsibility imposed upon them by law.
Section 6.02. Advisory Committees. Advisory committees not having and exercising the
authority of the Board in the management of the Corporation may be designated by the Board at
any meeting of the Board. Except as otherwise provided in such resolutions, the Board or anyone
designated by the Board shall appoint the members of such committees. Individuals who are not
Directors may serve as members of any such committee.
Section 6.03. Term. Each member of a committee shall continue as such until his or her
successor is appointed, unless the committee shall be sooner terminated, or unless such member
shall cease to qualify or shall be removed or shall resign as a member thereof.
Section 6.04. Removal; Resignation; Vacancies. Any member of a Board Committee
may be removed from office at any time by the Board, and any member of an advisory committee
may be removed from office at any time by the Board, except as otherwise provided by the Board.
Any committee member may resign at any time by giving written notice to the Chair or to the
Secretary of the Corporation. Such resignation shall take effect at the time specified in such notice,
or, if no time is specified, at the time such resignation is tendered. Vacancies in the membership
of any committee may be filled at any time by appointments made in the same manner as provided
in the case of the original appointments.
60
Section 6.05. Committee Meetings. Meetings of any Board Committee shall conform to
the same standards for notice, quorum, voting, manner and method of acting, and other procedures
applicable to meetings of the Board as are set forth in Article IV of these Bylaws, except as
otherwise provided by these Bylaws, committee charter, or resolution of the Board. Meetings of
any advisory committee shall conform to the standards for notice, quorum, voting, and manner and
method of acting as may be established by the committee chair, with the approval of the committee
members, except as otherwise provided in these Bylaws, committee charter, or resolution of the
Board.
ARTICLE VII
Sundry Provisions
Section 7.01 Contracts. The Board may authorize any Officer or Officers of the
Corporation, or agent or agents of the Corporation, in addition to the Officers so authorized by
these Bylaws, to enter into any contract or execute and deliver any instrument in the name of and
on behalf of the Corporation, and such authority may be general or confined to specific instances.
Section 7.02 Checks, Drafts, Etc. All checks, drafts or orders for the payment of money,
notes or other evidences of indebtedness issued in the name of the Corporation shall be signed by
the Chair, the Treasurer, the Vice Chair, or such Officer or Officers of the Corporation, or agent
or agents of the Corporation, and in such manner as shall from time to time be determined by
resolution of the Board.
Section 7.03 Deposits. All funds of the Corporation shall be deposited from time to time
to the credit of the Corporation in such banks or other depositories as the Board may select.
Section 7.04 Gifts. The Board may accept on behalf of the Corporation any contribution,
gift, bequest or devise for the general purposes of the Corporation or for any special purpose
approved by the Board if all such purposes are within the scope of the purposes of the Corporation
as set forth in the Articles of Incorporation as amended from time to time.
Section 7.05 Books and Records. The Board may engage the services of a recognized
auditing firm which shall review the Corporation's books and statements, and which shall prepare
annually, or more frequently if required, an operating statement, balance sheet and tax returns. The
Corporation shall keep correct and complete books and records of account and shall also keep: (i)
minutes of all meetings of the Board; (ii) records of all actions taken without a meeting by the
Board; and (iii) records of all actions taken by a Board Committee on behalf of the Corporation.
The Corporation also shall keep at its principal office (i) the Corporation’s Articles of
Incorporation, (ii) the Corporation’s Bylaws, (iii) minutes and other required records described
above for the last three (3) years; (iv) a list of the names and business address of the Corporation’s
current Directors and officers; and (v) the most recent biennial report filed by the Corporation with
the District of Columbia.
Section 7.06 Limitation of Liability; Indemnification; and Insurance. To the fullest
extent permitted by the Act and the Internal Revenue Code of 1986, as amended, or the
corresponding provisions of any future internal revenue laws of the United States (i) the personal
liability of each Director, Officer, employee of the Corporation is hereby eliminated, and (ii) the
61
Corporation shall indemnify and advance expenses to any individual who was, is, or is threatened
to be made, a party to a proceeding because he or she is or was a Director, Officer, employee,
and/or agent of the Corporation. The Corporation may purchase liability insurance for the
indemnity specified above, as determined from time to time by the Board
ARTICLE VIII
Fiscal Year and Budget
Section 8.01 Fiscal Year. Except as from time to time otherwise provided by the Board,
the fiscal year of the Corporation shall be the calendar year.
Section 8.02 Budget, Fees, Dues, and Assessments. The Board shall adopt a budget for
each fiscal year, setting forth categories of expenses and totals, as well as expected revenue and
sources. The Board shall set fees, dues, and other assessments (collectively, “Dues”) on an annual
basis, and no Member shall be obligated to pay Dues in a subsequent year if it terminates
membership pursuant to Section 3.02. If the Board increases Dues during a year, a Member may
terminate membership and will not be subject to the increased Dues, but will be subject to Dues
established for that year.
ARTICLE IX
State Program Boards
Section 9.01 Establishment of State Program Boards. The Corporation may establish
governing bodies for one or more state producer responsibility programs in which the Corporation
or its subsidiaries participates as the designated producer responsibility organization, as authorized
by the Board (each, a “State Board”). Each State Board shall function as a designated body of the
Corporation as defined in D.C. Code section 29-406.12. Each State Board shall have responsibility
to approve the program plan and budget for that state and provide strategic oversight and guidance
to the Corporation regarding that state’s program, subject to final approval and oversight by the
Board.
Section 9.02 State Board Meetings. Each State Board shall have a governing charter
approved by the Board. The charter shall operate as internal operating rules for the State Board
and shall address the composition, selection process, and term of members of the State Board, as
well as the procedures for meetings, notice, quorum, and manner of acting of the State Board.
Unless such rules provide otherwise or in the absence of such rules, each State Board shall be
subject to the requirements for meetings, notice, and manner of acting applicable to the Board of
the Corporation.
Section 9.03 Minutes. Minutes of each meeting of a State Board and records of each action
taken without a meeting by a State Board shall be recorded and maintained permanently among
the records of the Corporation, as required by law.
62
ARTICLE X
Amendments
Section 10.01 By the Board. At any meeting these Bylaws may be altered, amended or repealed
in whole or in part upon approval of a majority of the Directors then in office.
Adopted by the Board of Directors on March 1, 2023, as amended by the Board of Directors on
March 15, 2023.
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circularactionalliance.org
Appendix M:
Preliminary Program Implementation Timelines
64
Program Year
Month
Wee k of 4 11 18 25 1 8 15 22 29 6 13 20 27 3 10 17 24 1 8 15 22 29 5 12 19 26 2 9 16 23 30 7 14 21 28 4 11 18 25 2 9 16 23 30 6 13 20 27 3 10 17 24 3 10 17 24 31 7 14 21 28 5 12 19 26 2 9 16 23 30 7 14 21 28 4 11 18 25 1 8 15 22 29 6 13 20 27 3 10 17 24 1 8 15 22 29 5 12 19 26 2 9 16 23 2 9 16 23 6 13 20 27 4 11 18 25 1 8 15 22 29 6 13 20 27 3 10 17 24 31 7 14 21 28 5 12 19 26 2 9 16 23 30 7 14 21 28 4 11 18 25 1 8 15 22 1 8 15 22 29 5 12 19 26 3 10 17 24 31 7 14 21 28 5 12 19 26 2 9 16 23 30 6 13 20 27 4 11 18 25 1 8 15 22 29 6 13 20 27
Program Plan Development & Approval Process/Compliance Detai ls
Program Plan Submission Deadline
ORSAC review
Final deadline for DEQ approv al or rej ection of v1 plan subm ission (120 days after su bmission with 30 days fo r public comment)
Revi sed pl an subm ission (+60 days)
DEQ approve or rej ect re vise d submis sion (+90 days)
2024 Annual Admin Fee Provisional Invoice September 2024
Potential Program Plan Approval
2024 Annual Admin Fee Due (within 30 days of fin al invoice)
Recu rring Annua l Admin i nvoice date (Sept 1 of preced ing program year for p ayment within 30 days)
Recu rring Annua l Admin F ee Due (within 3 0 days of invoice )
Dead line to submit for next prog ram pla n (180 days bef ore end of program - July 4, 2 027)
Confirma tion of 1 0% thres hold (31 Dece mber e ach year)
Goals
Mea surem ent a gains t targe ts/goa ls begins
Local Governme nt Compensation
Detail to be a dded during Oregon Recyc ling System Optimiza tion Proje ct
Local g overnment a nd service provide r consu ltation an d discussion
Update d Program Plan Funding Sch edule an d Estimates
Pre-Program Funding Negotiations
Fundin g Disbursements (As p er program plan sch edule)
Local g overnment a nd service provide r consu ltation an d discussion
Upda ted Program Plan Amendme nts
Pre-Program Pro gram Registrations
Fundin g Disbursements
Local g overnment a nd service provide r consu ltation an d discussion
Upda ted Program Plan Amendme nts
Pre-Program Pro gram Registrations
Fundin g Disbursements Be gin
Local g overnment a nd service provide r consu ltation an d discussion
Upda ted Program Plan Amendme nts
Pre-Program Pro gram Registrations
Fundin g Disbursements Be gin
PRO Depot Network
Preliminary neg otiations with d epots
Consulta tions with CBOs, wome n & minority-owned b usineses & u nderserved p opulations
Upda ted P rogram P lan A mendmen ts
Finalization o f Service Contract s
Collection p oints ope n & operat iona l
Education & Outreach
Quan titative survey, a nalysis and rep orting
Qualitat ive rese arch: concep t testing fo r En glish and Sp anish qua litative resea rch
Qualitat ive rese arch: concep t testing fo r 6 other lan guages
Campaign co ncepting
Naming an d mark develop ment
Media p lann ing, discussion, a pproval and hotshee t of ad sp ecs develop ed
PR plan ning, messagin g and mate rials de velopment
Media n egotiation a nd coordina tion
Campaign la unches first with P R/local g overnments
Ad ca mpaign and o ther outrea ch launche s
Formal campaign launch (July 1 , 2025)
Initial engagement of CBOs
Develop loca l government e ngagemen t plan/proce ss outline
Busine ss association o utreach
Propose d: Review campaig n concept prior to testing
Propose d: Audien ce research an d campaign co ncept prese ntation
Propose d: Review key messa ging, creative d irection , etc. prior to p rodu ction
USCL instructio ns/communications strate gy
Local g overnment review o f USCL instructions/ communica tions strategy
Compile an d incorporate fe edback
Ongo ing co mmunicatio ns: getting accurate info rmation to all residents, businesses a nd
institution s to edu cate on n ew recycling beha viors
Deliver supp ort to effe ctively engage frequen t, infreque nt and n on-participating audiences to
increase ca pture of mate rials
Batch 1 materials due 2/1/25: USCL g uide, cart lab el, style guide , messaging t imeline,
newslette r article, web do main/QR co de (English o nly) available for d ownload bu t not yet on
portal
Batch 2 materials due 4 /1/25: S ocial toolkit, press release , newsletter a rticle, web site with
"chan ge is coming" messa ging, print mat erials (USCL mailer/p oster, postca rd, b ill insert,
depo t/enclosure sig nage). Availab le in all langu ages.
Transcreatio n of Batch 2 materials
Batch 3 materials due 6/1/25: Website strategy, de sign, deve lopmen t and QC to have live,
updated with downloadable materials
Batch 4 materials due 7/1/25: Ad materials (video, radio , banne r, social, native, OOH, p rint, se arch). English a nd Spanish first (17 weeks) followed by remaining la nguages (8 wee ks).
Transcreatio n of Batch 4 materials
Mail house coordinat ion
Portal d esign (must beg in after Bat ch 1 materials are final)
Portal te sting
Portal lau nch (with Eng lish first, o ther langua ges adde d later as a vailable)
Mate rial s: Tra nsitio n to US CL
Detailed plan deve lopmen t in coordina tion with DEQ, MRFs, en d markets and producers
Propose d timing for inclusio n on the USCL: PET the rmoforms
Propose d timing for inclusio n on the US CL: Tran sparent blue and g reen PET b ottles
Propose d timing for inclusio n on the USCL: Spiral woun d containe rs
Mate rial s: SI Ms
Detailed plan deve lopmen t in coordina tion with DEQ, MRFs, en d markets and producers
Begin implementation of plans
Resp onsible End Mark ets (RE Ms) - Ve rificati on
Anticipa ting revisions from DEQ a nd resubmission o f program plan
Finalize an d approve Program Plan REM Con tent V2
Distribute Se lf-Attestation f orm (Collabora tion with CRPFs)
Provide a ccess to service p rovider p ortal for them t o access self a ttestation form
Direct reach o ut to certa in e nd markets ent ities (~40 )
Start n egotiation with b rokers a nd access th eir clients self-atte station forms
Complete a ll self-atte station fo rms by July 1 , 2025 (an d on-going after)
See p ortal details
Pilot syste mwith 1 targete d CRPF for 1 commod ity (comissionn ing, troubleshoo ting)
Adap t system based on pilot resu lts
Develop syste m training cont ent
Start se rvice provid ers training (if nee ded)
Finalize prot ocol for aud it an d random ba le tracking
Write and p ublish RFP
Select ve rification b ody(ies)
Reach o ut to reclaimers to e xplain REM requiremen ts (~100)
Prepare a greement allowing data sh aring and ch ain of cust ody control
Sign a greement with e nd market en tities
List local, sta te and n ational laws an d internation al treaties ap plicable to th e different entities
Select site s to be au dited (base d on criteria de velopped)
Start p re-aud it exchange information
Performaud it
Produce audit re ports
Reacho ut to no n-compliant entitie s for implementation of corrective act ions
Receive e viden t of corrective a ctions and u pdate au dit reports
Decide p ossible intervent ion a nd inform CRPFs/brokers f or non-compliant e ntities
Produce required info rmation PR 340-090 -067 0(3)(f) - Complete by July 1, 2 027
Resp onsible End Mark ets (RE Ms) - Inter vention and mate rial manage ment
Define RE M Clauses for processing co ntract
Externa l valida tion of REM clause s
Prepare MSA for end ma rket e ntities
Externa l valudation o f MSA for end ma rket e ntities
Outrea ch to end ma rket e ntities for materials u nder CAA's con trol (PRO, material CAA ha s taken o wnership of)
Negotia te contract with e nd market en tities
Based on verificatio n results, decid e to take a ction or not , and type of action
Develop action plan and bud get accordin gly
Reporti ng & Communi cations
Quarterly disposition reporting (no lat er than 45 days afte r en d of each calendar qu arter)
Annual Reports due (July 1 e ach year)
CAA DEQ Meetings
Meeting Frequ ency to be Determined
ORSAC Engagement
Meeting Frequ ency to be Determined
Local Governme nts
Meeting Frequ ency to be Determined
PCRFs
Meeting Frequ ency to be Determined
Other Stakeholders
Meeting Frequ ency to be Determined
Producer Engagement
Meeting Frequ ency to be Determined
Webs ite upda tes to re flec t s ear chab le r egi stry of c ompli ant memb ers
(at least once per ca lendar qua rter)
Fees
Inital Program Plan Fee Schedule 2025
Revi sed P rogram P lan Fe e Sc hedule 2025
Producers register and provide data reports to CAA
Final Fee Sche dule for 20 25
CAA prov ides supply a nd mar ket sha re re ports to DE Q
CAA se ts fee s and i nvoice s produc ers for subse quent progr am ye ars
IT & Portal development
Delivery Sprints L eading to Go Live
Stea dy State S upport
Delivery Sprints L eading to Go Live
Stea dy State S upport
Delivery Sprints L eading to Go Live
Stea dy State S upport
Delivery Sprints L eading to Go Live
Stea dy State S upport
Security & Infrastructure
Cybersecurity
Compute rs, Firewalls, Too ls an d IT Suppo rt Desk
Data Quality , Gove rnance , Mas ter Data Managem ent Delivery Sprints L eading to Go Live
Stea dy State S upport
Data Lake, Reporting and Anal ytics Delivery Sp rints Le ading to Go Live
Stea dy State S upport
Dece mber
July
August
September
October
Nove mber
Engage end markets entities
Dece mber
Program Year 1: 2025-2026
April
May
June
July
August
October
Nove mber
Establishing a depot collection system
September
October
Nove mber
Marc h
April
Marc h
Dece mber
September
January
Program Year 2: 2026-2027
September
October
Nove mber
June
May
April
Marc h
Februar y
January
Februar y
Pre-Program (2024-25)
May
June
July
August
Dece mber
January
Februar y
Marc h
April
August
May
June
July
Front Office Stakehol der Support Se rvices Call Cente r
Back Office HR & Pa yroll
Back Office Financ e (inc luding Pr oject Ac counting & Procure ment)
LGs a nd Servi ce Prov iders Sy stem Ex pansions a nd Improvem ents
To be a dapted per material once plan is approv ed
Audien ce re searc h
To be a dapted per material once plan is approv ed
Underta ke pr actica ble a ctions for non-compl iant REM
Prepare marketing and processing contracts
Start annual verification (step 2)
Front Office CRM and Portal s (Producer, Servi ce Prov ider, Munici pality
Revi ew Pr ogram P lan (DEQ comme nts)
Initial screening assessments (step 1)
Stakeholder engagement
Deve lop Mate rial F low Mana gement S ystem
Select Verification Body(ies)
Transportation Funding
Contamina tion Reduc tion Funding
Roll Carts
Portal development
Statewide campaign
Communi cations strateg y
Production of materials
Consul tations w ith ORSAC
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