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April 28, 2005 Page 8 Role of the Government in Minimizing Disposal of Materials Collected for Recycling - Provision of standardized defInitions, more research, and clear policy direction as to acceptable levels of process residuals would assist cities and haulers with the best available information about the processing residuals issue. For example, there is still little hard data available that characterizes the color-mixed, broken glass generated from MRFs in Minnesota. We still do not know how much single stream collection and processing systems impact the relative amounts of mixed glass produced compared dual stream systems. Definition of "Recycling" Markets vs. Waste "Disposal" - In lieu of more clear policy direction, each city should establish its own policy for defIning end uses that shall be considered "recycling" vs. "disposal". As the industry moves to more commingled collection systems (e.g., source separated to dual stream; dnal stream to single stream), more color-mixed, broken glass will be produced from the MRFs. Some parties advocate for only higher-value end use applications (e.g., glass bottles) to be defmed as recycling. Others, including integrated waste management companies, will advocate for lower-value end use applications (e.g., aggregate for road base, alternative daily landfill cover, etc.) to be defIned as recycling and not as disposal. This policy definition is critical to evaluating the effectiveness of commingled collection systems. One potential policy position is that color-mixed, broken glass that is further processed (e.g., screened) so that it can be used as an aggregate supplement (e.g., meets MN/DOT class 7 aggregate specifIcations as road base) and therefore can be considered a legitimate commercial commodity could be considered a "recyclable". Mixed broken glass that is not further processed and does not meet minimum specifications for use as an aggregate supplement (e.g., is signifIcantly contaminated with non-glass debris), could be considered a "residual disposed" and therefore a "waste" and not a recyclable commodity. Exceptions to this determination could be requested by the MRF operator if suitable documentation is provided that demonstrates the color-mixed, broken glass is clean enough to be considered a commercial commodity with equal or better value compared to the virgin or other traditional materials used as aggregate for alternative daily cover. Calculating Net Recycling Rates - There is a continuing need among the recycling industry to provide clear, standardized methods to defme and calculate net recycling. Two components of the system should be treated independently: collection, and then processing. Collection effectiveness should measure the performance of the residents in complying with public education messages and the collection crews (if truck-side rejecting of non-targeted materials is employed). The "non-targeted materials rate" (in percent as collected and loaded on the truck) should defme the effectiveness of collection. The "processing residuals rate" (in percent of total inbound material) should define the effectiveness of the MRF in processing the materials. While related, if both rates are measured and reported independently, there can be more objective analysis and management controls implemented to improve quality. 01-00253-10101-01011070001 I 13500 P:\13500 Ramsey Co. 2003\RTA\Roseville\FA\DraftResidualsMemo042805.doc DRAFT