Policy Tools Driving Post- Consumer Packaging and Printed Paper - - PowerPoint PPT Presentation

Welcome to the Webinar: Policy Tools Driving Post- Consumer Packaging and Printed Paper Recovery

July 23, 2014

2 2

Betsy Dorn

Reclay StewardEdge

Scott Mouw

North Carolina Department of Environment and Natural Resources

Elisabeth Comere

Carton Council & Tetra Pak Inc.

Peder Sandhei

Minnesota Pollution Control Agency

James Short

Delaware Dept. of Natural Resources and Environmental Control

3 3

But first…Who is the Carton Council?

Carton manufacturers united to deliver long term collaborative solutions to divert valuable cartons from disposal

Associate Member

4 4

Improving Recycling in the U.S.

Policy: State and Local Levels Improving Access: End markets, Processing and Collection Industry Collaboration Education to Improve Recovery

Our Comprehensive Approach

5 5

No Silver Bullet – Policy is Only a Piece of the Puzzle

6 6

Why this Webinar?

• Carton Council has achieved 50% access however

more work is needed.

• Exploring policy’s role as tool for building access

AND recovery.

• Purpose of the webinar is to share learnings to

date and hear others’ perspectives.

• Webinar will be followed by release of full report

and half-day forum at Resource Recycling Conference in September in New Orleans.

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Webinar Agenda I. Overview of Carton Council Research

• II. NC Disposal Bans: Giving Recycling a Boost
• III. Implementing Delaware’s Universal Recycling

Program and Lessons Learned

• IV. Volume Based Pricing and the New Commercial

Recycling Mandate in Minnesota

• V. Wrap Up and Q&A

8 8

Overview of Carton Council Policy Research

• Focused on state and local level policy and related programs:
• Recycling laws
• Disposal bans
• Pay-as-you-throw (PAYT)
• Primary and secondary research including:
• Literature review
• Review of past studies
• Internet research
• Interviews

National research covering all post-consumer packaging and printed paper materials conducted by Reclay StewardEdge

9 9

Research Findings

• State-level disposal bans in 4 states
• Three types of recycling policies in 18 states
• PAYT policies in 5 states
• Numerous local governments employing policy

tools – with or without overarching state policy

10 10

S P T D S T P T S T S T P T P P S T S P S T P S T P T S P D D D T T S P S

Policy Type Service Provision/Level Participation/Source Separation Target/Goal Disposal Ban

S P T D

Disposal Bans & Recycling Policies by State

11 11

State-Level Packaging & Paper Disposal Bans

Jurisdiction Glass Steel Aluminum Plastic Paper(a) Massachusetts Containers Containers Containers 1-6 Bottles OCC, RP North Carolina Containers(b) Containers 1-7 Bottles Vermont Containers Containers Containers 1-2 Bottles OCC, RP Wisconsin Containers Containers Containers 1-2 Bottles OCC, ONP, OMG, OP

Notes: (a) OCC=old corrugated containers, ONP=newspaper, OMG=magazines, OP=office paper, RP=all recyclable paper (b) Applies only to certain restaurants and bars with alcohol permits

12 12

Types of Recycling Policies

• 1. Recycling Service Provision:
• Local governments/haulers expected to provide specified

recycling services based on defined criteria

• e.g. population greater than 4,000 or by generator type
• 2. Recycling Participation/Source Separation:
• Requires source separation of recyclables by all or certain

types of generators

• e.g. single-family, multi-family, commercial
• 3. Recycling Target/Goal:
• Local governments/state agencies expected to achieve

specified target or goal

• e.g. 50% recycling rate or diversion rate by X year

13 13

State Level Recycling Policies

Jurisdiction Service Provision/Level Participation/Source Separation Target/ Goal

Material Specific Not Material Specific Material Specific Not Material Specific

California   Connecticut   Delaware    Florida  Maine   Maryland   Minnesota   New Jersey    New York  North Carolina  Oregon   Pennsylvania    Rhode Island    Vermont    Virginia  Washington   West Virginia   Wisconsin  

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Disposal Bans and Recycling Policies: Conclusions

• State policy can drive local policy and infrastructure

development.

• Recycling policies are preferred by states over disposal bans.
• Emphasis for bans has been voluntary compliance with threat
• f enforcement in background.
• Three types of recycling policies equally prevalent and often

used in combination.

• State and local policies involve local implementation and

behavior change.

• States generally expect local governments and/or haulers to

implement and enforce.

15 15

Disposal Bans and Recycling Policies: Best Practices

• Employ program tools to support policies.
• Combine policies and programs for synergistic impact.
• Require use of recycling program best practices.
• Provide funding, particularly for initial compliance.
• Phase in compliance to allow for infrastructure development, public

awareness and transition time.

• Use “supportive” enforcement involving monitoring, feedback and

technical assistance, with penalties as a last resort.

• Clearly define compliance points and mechanisms.
• Require data to benchmark and track performance.
• Identify champions and cultivate stakeholder support.

16 16

Types of PAYT Programs

• Can/Cart: Generators pay fixed price based on size
• r number of containers they select, e.g. 30, 64 or

96 gallons.

• Bag, Tag & Sticker: Generators buy special bags or

stickers for their waste. Price of each bag/ sticker includes cost of collection services.

• Hybrid: Generators pay fixed amount for specified

maximum volume of waste per collection day. Excess waste accrues additional charge.

• Weight-based: Weight of container contents is

determined at curbside. Generators are charged accordingly.

• Other: Generators are offered a PAYT fee structure

as a voluntary option.

17 17

States with PAYT Policies

State PAYT Policies Minnesota

Local governments that charge for solid waste collection must implement a fee structure that increases as the volume or weight of waste collected from each generator's residence or place of business increases.

Washington

Applies mostly to private collectors that operate in unincorporated areas. Does not apply to local governments; however, the law’s existence has led to PAYT throughout the state.

Oregon

No legislative mandate, but PAYT is on list of nine recycling elements that municipalities choose from when designing their recycling programs to comply with state regulations.

Iowa

PAYT at the local level can be required if recycling goals are not met.

Wisconsin

PAYT at the local level can be required if recycling goals are not met.

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State-Level PAYT: Conclusions

• State policies can drive local recycling program performance

and provide non-tax source of funding.

• States historically have refrained from dictating means by

which local governments fund their solid waste services.

• States can promote PAYT, provide technical assistance, offer

incentives, and fund implementation – with/without requiring PAYT.

Example: MA DEP sets best or minimum infrastructure and services standards regarding PAYT and specific pounds per household levels. If municipalities achieve those standards, they are eligible for a specific $/ton diverted incentive

• payment. 40% of MA communities have PAYT.

19 19

State-Level PAYT: Best Practices

• 1. Require PAYT to be paired with recycling

service provision with costs imbedded in waste collection fee.

• 2. State policy language should specify:
• Recyclable materials to be collected
• Minimum frequency of collection
• Container sizes and fee setting expectations with sufficient

spread in size and pricing

• Who is responsible for public education about PAYT and

recycling options

• Reporting requirements

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PAYT Best Practices: Local Level

• Conduct extensive customer and service provider education

and outreach.

• Incorporate cost of recycling in the waste collection fee.
• Develop recycling programs with convenience equal to that of

disposal.

• Ensure pricing increments and container sizes are different

enough to impact behavior change.

• Inspect hauler records.
• Adjust pricing over time to ensure stable financing.
• Provide sufficient staff to oversee PAYT program.

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Conclusions: Future Policy Decision Making

Collect a wide range

• f recyclable

materials (and increasingly

• rganics)

Provide waste generators with convenient access to recycling

• pportunities

Have strong recycling promotion programs

Are supported by policies and funding for infrastructure development and to incentivize participation

High- performing municipal recycling programs

22 22

Conclusions: Future Policy Decision Making

Existing Policy:

EPR, deposit, mandates, bans, PAYT

Recovery Infra- structure & Access Available Funding Mechanisms & Programs Political Climate:

Legislative initiatives, stakeholder positions

Local Circumstances Dictate Best Policy Approach

23 23

Looking Ahead: Future Policy Decision Making

• Trending practice is multi-faceted

programmatic and policy approach with Universal Recycling as the centerpiece – opportunities to recycle everywhere

• Examples: Vermont, Seattle, San Francisco

NC Disposal Bans: Giving Recycling A Boost

Scott Mouw, NC DENR

Policy Tools Driving Post-Consumer Packaging and Printed Paper Recovery: Disposal Bans, Recycling Policies and Pay-As-You-Throw

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State Level Disposal Bans in US

• Widely adopted policy tool for special waste

streams: lead acid batteries, oil, tires, white goods, yard waste, etc.

• Many bans were part of foundational state

recycling laws in the late 80s/early 90s

• Northeast Recycling Council (NERC) 2011 study:

– 47 states have banned at least one material from disposal

• Details:

http://nerc.org/documents/disposal_bans_mandatory_re cycling_united_states.pdf

• Electronics are most recent target for disposal

bans.

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State Disposal Bans on Paper and Packaging

• Three existing: MA, NC, WI
• One pending: VT Effective July 2015
• Only MA consistently enforcing bans
• 150 enforcement actions for waste generators and haulers

since 2009

• Packaging Industry/Brand Owners interested in

Disposal Bans

– AMERIPEN 2013 Policy Study recommends a combination of three legislated approaches within the U.S.: PAYT, Mandatory Recycling, and Disposal Bans – Bans seen as acceptable alternative to EPR

27 27

History of NC Disposal Bans

• Senate Bill 111 in 1989: disposal bans on lead acid

batteries, used oil, tires, yard waste, and white goods.

• Aluminum can ban and antifreeze added by Senate

Bill 59 in 1993.

• Senate Bill 59 also added:

“The accidental or occasional disposal of small amounts of prohibited solid waste by landfill or incineration shall not be construed as a violation of subsections (f) or (f1) of this section.”

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History of NC Disposal Bans, cont.

• In 2005, Representative Joe Hackney sponsored

H1465 and H1518:

▫ H1518 required certain ABC permit holders (bars and restaurants) to recycle beverage containers and included a disposal ban on those containers – effective 1/1/08. ▫ H1465 banned the disposal of wooden pallets, oil filters,

• yster shells, and “rigid plastic containers,” defined to

mean bottles, effective 10/1/2009.

• Disposal ban on computer equipment and

televisions effective July 1, 2011 as part of NC’s electronics law.

• Ban on fluorescent lights and mercury thermostats

in unlined C&D landfills effective July 1, 2011.

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Main NC Ban Statute

No person shall knowingly dispose of the following solid wastes in landfills: (1) Repealed by Session Laws 1991, c. 375, s. 1. (2) Used oil. (3) Yard trash, except in landfills approved for the disposal of yard trash under rules adopted by the Commission. Yard trash that is source separated from solid waste may be accepted at a solid waste disposal area where the area provides and maintains separate yard trash composting facilities. (4) White goods. (5) Antifreeze (ethylene glycol). (6) Aluminum cans. (7) Whole scrap tires, as provided in G.S. 130A-309.58(b). The prohibition on disposal

• f whole scrap tires in landfills applies to all whole pneumatic rubber coverings, but does

not apply to whole solid rubber coverings. (8) Lead-acid batteries, as provided in G.S. 130A-309.70. (9) Beverage containers that are required to be recycled under G.S. 18B-1006.1. (10) Motor vehicle oil filters. (11) Recyclable rigid plastic containers that are required to be labeled as provided in subsection (e) of this section, that have a neck smaller than the body of the container, and that accept a screw top, snap cap, or other closure. The prohibition on disposal of recyclable rigid plastic containers in landfills does not apply to rigid plastic containers that are intended for use in the sale or distribution of motor oil or pesticides. (12) Wooden pallets, except that wooden pallets may be disposed of in a landfill that is permitted to only accept construction and demolition debris. (13) Oyster shells. (14) Discarded computer equipment, as defined in G.S. 130A-309.131. (15) Discarded televisions, as defined in G.S. 130A-309.131.

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Which Of These Things Are “Waste?”

NC Statutes say: None

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Making the Case for Bans

• Disposal bans on wooden pallets, oil filters, and plastic

bottles proposed in 2003 Ten Year State Plan

• Response to robust market demand and available

infrastructure

• Way to close “loophole” on disposed oil, banned in 1990
• Presence of market demand and infrastructure consistently

presented to Legislative committees

• Documentation of general

growth in recycling jobs and the NC recycling economy

7,757 11,762 12,776 14,490 15,187 17,002 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 1994 2000 2003 2008 2010 2013

Employees Year

32 32

The (Recycling) Business Case

• Oil Filters:
• Strong and consistent markets for steel and oil in filters
• Over 30 separate oil recyclers in NC also recycle filters
• 250,000 gallons of oil wasted into NC landfills annually
• Wooden Pallets
• Solid hierarchy of management option: source reduction,

reuse, repair, mulch, compost, fuel, and other end uses.

• 77 different pallet markets in state Markets Directory – NC

State study finds over 1,000 jobs in pallet recycling in NC

• Plastic Bottles
• Southeast U.S. rich in bottle plastic processing and end-

use capacity: 1.439 billion lbs/year

• Carolinas home to major PET and HDPE recyclers

33 33

Plastic Bottle Recycling Capacity vs. Local Supply in the Carolinas (in lbs.)

• 100,000,000

200,000,000 300,000,000 400,000,000 500,000,000 600,000,000 700,000,000 Capacity Amount from Carolinas

34 34

Critical Support of the Disposal Bans

• Technical Assistance

– Training – Education Materials Development – Contact with Generators – Outreach to Media

• Grants

– NC recycling grant funds split between public and private sectors – Specialized grant cycles and bonus points in traditional cycles aimed at banned materials

35 35

Market Development Effects of Bans

• Indirect but inter-related development of recycling

businesses and jobs – synergy of supply & demand.

• Explosion of small start-up collection companies

across North Carolina.

• Expansions at MRFs and processing companies.
• New large processing facilities – e.g., Clear Path

Recycling in Fayetteville:

▫ $80 million investment and ~90 new jobs.

36 36

Beneficial Effects of 2005 NC Bans

500 1000 1500 2000 2500 3000 3500 4000 2008 2009 2010

Oil Filter Collection Customers

5,000 10,000 15,000 20,000 25,000 30,000 2009 2010 2011 (projected)

Change in # of customers for Independent Haulers Increase in business activity for small haulers encouraged by ABC law, disposal bans, and some funding support Tripling of tonnage handled and 250% increase in customers for filter recyclers from the oil filter disposal ban.

37 37

Beneficial Effects of 2005 NC Bans

81% 62% 91% 38% 0% 20% 40% 60% 80% 100% Increased pallet tonnage Increase revenue Increased Customers Hired more workers

Pallet disposal ban increased tonnage and business activity for recyclers Plastic bottle collection by local programs doubled in four years

• 5,000.00

10,000.00 15,000.00 20,000.00 25,000.00 30,000.00 35,000.00 40,000.00 FY 00-01 FY 01-02 FY 02-03 FY 03-04 FY 04-05 FY 05-06 FY 06-07 FY 07-08 FY 08-09 FY 09-10 FY10-11 FY11-12 FY 12-13 PET HDPE Other

38 38

Beneficial Effects of NC Policies

Encouraged by plastic bottle disposal ban, disposal tax grant funds, and technical assistance Decline in waste disposal encouraged by combination of NC policies, protocols, grants, etc

50 100 150 200 250 300 350 FY 1998-99 FY 1999-00 FY 2000-01 FY 2001-02 FY 2002-03 FY 2003-04 FY 2004-05 FY 2005-06 FY 2006-07 FY 2007-08 FY 2008-09 FY 2009-10 FY 2010-11 FY 2011-12 FY 2012-13 Number of Curbside Programs

39 39

Limitations of Bans with no Enforcement

• 20,000

40,000 60,000 80,000 100,000 120,000 140,000 160,000 FY 05-06 FY 06-07 FY 07-08 FY 08-09 FY 09-10 FY 10-11 FY 11-12 FY 12-13

PET/HDPE Recycling PET/HDPE Wasting

40 40

Material Banned Effective Date of Ban Estimated Tonnage of Diversion since Effective Date Whole Tires October 1, 1989 1,939,339 Used Motor Oil October 1, 1990 61,137 Lead Acid Batteries January 1, 1991 23,979 White Goods January 1, 1991 1,025,786 Yard Trash January 1, 1993 11,020,232 Antifreeze July 1,1994 2,010 Aluminum Cans July 1, 1994 110,081 Oyster Shells January 1, 2007 5051 ABC Permit Holder Glass January 1, 2008 165,000 Used Oil Filters October 1, 2009 666 Rigid Plastic Containers (bottles) October 1, 2009 130,201 Wooden Pallets October 1, 2009 90,893 Computer Equipment July 1, 2011 11,844 Televisions July 1, 2011 17,004 Fluorescent lamps and thermostats July 1, 2011 84 TOTAL TONS: 14,603,306

Retrospective on NC Disposal Bans

41 41

Lessons from NC Disposal Bans

• Bans are an effective way to declare material to be

commodities (and to transition to “materials management”).

• Enforcement a tough issue and bans alone are not

a “magic bullet.”

• Successful bans require both presence and

development of infrastructure.

▫ May need lead time for infrastructure to mature. ▫ Success can be encouraged with program and grant support.

Thank You!

Scott Mouw NC Division of Environmental Assistance & Customer Service 919-707-8114 scott.mouw@ncdenr.gov

James Short, Delaware Dept.

• f Natural Resources and

Environmental Control

Implementing Delaware’s Universal Recycling Program and Lessons Learned

Policy Tools Driving Post-Consumer Packaging and Printed Paper Recovery: Disposal Bans, Recycling Policies and Pay-As-You-Throw

44 44

Universal Recycling – History/Background

• Comprehensive drop off yet low diversion rates.
• Resulted in citizen interest in curbside recycling.
• Initial Draft Legislation developed in early 2000’s.
• Pilot subscription and municipal curbside collection

programs started in response.

45 45

Universal Recycling – Unifying Stakeholders

• Important to have legislative support of haulers,

bottle distributors, retailers, municipalities and the general public.

• Important to be both convenient and cost effective.
• Single stream collection offered both and single

stream separation technology was nearby.

46 46

Universal Recycling – Bottle Deposit vs. Bottle Fee

• Delaware “Bottle Bill” was a litter control bill with no

requirement to recycle.

• Large percentage of population did not redeem nickel

deposit.

• Escheat deposits kept by distributor estimated at $3

million/yr.

• Therefore bottle deposit was supported as a good

candidate for the revenue needed to fund capital costs to implement a comprehensive recycling program.

• Four cent bottle fee used to fund capital start up costs

(trucks/carts/processing equipment) and educational costs awarded through the recycling grant and loan program.

• Four cent fee started 12/1/10 and sunsets 12/1/14.

47 47

Universal Recycling Implementation – Key Components

• Haulers required to provide residential recycling

service and bill for both trash and recycling services.

• Recycling participation by resident encouraged but

not required. Residents advised to take advantage

• f recycling services since they pay for it, i.e.

residents cannot get a lower rate and therefore be financially rewarded by not recycling.

• By providing the service to each resident the

economy of scale reduces overall costs.

• In many instances competition lowered prices.

48 48

Universal Recycling Implementation – Key Components

• Reporting and Measurement required.
• Established Recycling Public Advisory Council in Legislation.
• MSW Recycling Goals – 2015: 50%, 2020: 60%.
• Enforcement capability.
• Grant and Loan program supported via bottle fee.

49 49

Implementing Universal Recycling – Status

• Single-family requirement started 9/15/11.
• Multi-family requirement started 1/1/13.
• Commercial requirement started 1/1/14.
• MSW Recycling Rates:
• Residential prior to 2006 estimated around 10% at best.
• 2006 with DSWA/Wilmington voluntary curbside 23.2%.
• 2012 at 40.1%.
• Delaware fortunate to have excellent waste

characterization data courtesy DSWA.

• Resulted in construction of $15,000,000 MRF and

creation of approx. 200 collection/processing jobs.

50 50

Universal Recycling Implementation – Lessons learned

• Funding - Revenue from bottle fee 1/3 less than expected.

Delaware fee collection is from retailers.

• Know your waste/recyclables – residential well understood,

commercial still learning.

• Service and Participation - verifying compliance is a function
• f observation, reporting and a measure of tons diverted.
• Education – A never ending necessity.
• Planning – What gets measured gets managed.

51 51

Universal Recycling Implementation – Going Forward

• Commercial Recycling rate behind residential.
• Focusing on organics and C&D. They represent a

large amount of waste and DE has processing capability for them.

• New waste characterization study in 2015 will help

prioritize which areas of diversion to focus on.

Thank you!

To view additional information about recycling in Delaware, including the universal recycling legislation visit: http://delaware.gov/topics/recycling For questions, contact: Jim Short, James.Short@state.de.us Bill Miller, Bill.Miller@state.de.us

• r call 302-739-9403 ext. 8

Volume Based Pricing and the New Commercial Recycling Mandate in Minnesota

Peder Sandhei, MN Pollution Control Agency

Policy Tools Driving Post-Consumer Packaging and Printed Paper Recovery: Disposal Bans, Recycling Policies and Pay-As-You-Throw

54 54

Volume-Based Pricing

• Only one

community in MN has a true PAYT system

• (City of St. Cloud)
• MN has a volume
• r weight-based

pricing requirement in statute

$30 $20 $10

Approx.

5-7

Approx.

4-5

Approx.

2-3

55 55

Volume-Based Pricing – Minnesota

• §115A.9301 SOLID WASTE COLLECTION;

VOLUME- OR WEIGHT-BASED PRICING.

• A local government unit shall implement charges that

increase as the volume or weight of the waste collected increases

• If a local government unit implements a pricing system

based on volume instead of weight under subdivision 1, it shall determine a base unit size and establish a multiple unit pricing system that ensures that amounts of waste generated in excess of the base unit amount are priced higher than the base unit price

56 56

Volume-Based Pricing in Action

• Statute doesn’t

state how much more expensive the larger size must be

• Result: larger

container is only marginally more expensive than the smaller sizes

• Due to overflow

penalties, most residents select a larger container than they need

$22 $20 $18

Approx.

5-7

Approx.

4-5

Approx.

2-3

57 57

What’s needed to make it effective?

• Pay-as-you-throw is more effective in communities

with contracted service

• In Minnesota, the language would need to specify

the percent increase in cost by volume or weight in

• rder to be effective – difficult to implement

politically

• Challenging in MN due to wide variety of policies at

the local level

• Many communities have subscription service/not

contracting

58 58

Commercial Recycling Mandate Historically, MN has focused on residential recycling

Funded by the solid waste management tax

Commercial buildings (January 1, 2016)

• In metro counties only (section 473.121)
• Anoka, Carver, Dakota, Hennepin, Ramsey, Scott and

Washington

• Contracted for four cubic yards or more per week
• f solid waste collection

Sports Venues (January 1, 2015)

• College and Pro venues only
• Statewide

59 59

Who is impacted?

NAICS 42 to 81

Service-Providing Industries

• Trade
• Transportation
• Utilities
• Information
• Financial Activities
• Professional and Business

Services

• Education and Health

Services

• Leisure and Hospitality
• Other Services (except

Public Administration) These are Exempt NAICS 11 to 33

Goods-Producing Industries

• Natural Resources and

Mining (including agriculture and forestry)

• Construction
• Manufacturing

60 60

Public Entity Recycling Requirements (115A.151)

• Must collect a minimum of 3 materials
• By type: (ex. paper,

glass, metal, organics)

• Single-sort meets requirement
• Must provide containers
• Emphasis on co-locating

all trash with recycling

Collection Requirements

61 61

Collection Requirements

• Is collection required in areas with public

interaction?

• Intent of bill is that the business establish an effective

recycling program

• Where there is public garbage,

provide public recycling

62 62

State Policy Best Practices

• Why recycling? We

already do that!

• Not true – continuous

improvement is critical

• Establish a consistent

funding mechanism

• Find ways to make

recycling and diversion convenient and easy to understand

• Develop good

partnerships with the private sector

Thank You!

Peder Sandhei MN Pollution Control Agency peder.sandhei@state.mn.us

64 64

Conclusion and Next Steps

65 65

Robust MRF Processing

dependable flow of material to create quality bales

Strong End Markets

create demand and appealing price points

Thoughtful Outreach

boosts participation, reduces contamination

Supportive Policy

recognizes the connection to manufacturing

Committed Community

provides ample access &

• pportunity for expansion

Private/Public Partnership

coordination across sectors What does healthy, robust recovery look like?

Source: SERDC 120/The Recycling Partnership

66 66

Looking Ahead

• Carton Council Policy Report on

CartonOpportunities.org

• Policy Forum, Monday morning,

September 15, Resource Recycling Conference, New Orleans

Thank You!

67 67

Elisabeth Comere Carton Council & Tetra Pak elisabeth.comere@tetrapak.com Betsy Dorn Reclay StewardEdge bdorn@reclaystewardedge.com Scott Mouw North Carolina Department of Environment and Natural Resources scott.mouw@ncdenr.gov James Short Delaware Dept. of Natural Resources and Environmental Control james.short@state.de.us Peder Sandhei MN Pollution Control Agency peder.sandhei@state.mn.us

Contact Information