AMERIPEN’s fourth webinar in their five-part series on Preparing for Packaging Producer Responsibility in the U.S.took place on May 22 and focused on “Learning from Needs Assessments”. It covered understanding the packaging recovery system and its needs, including eco-modulation, fee-setting, investments, and more. After a welcome and introduction of the day’s speakers by Kyla Fisher, AMERIPEN’s Program Director, she highlighted the webinar series sponsors, who had a chance to go in-depth on their products and services in part three of the series on April 17, as well as the program, sponsors.
Before she jumped in, she noted that Minnesota became 5th state to pass an EPR bill. However, the final bill did not specify performance targets but rather encouraged Needs Assessments to inform future targets. Also, one of the webinar speakers, Resa Dimino, had released the New York needs assessment. In that report, the MRF operators said they wanted legislators to really fully understand the system before implementing EPR. So, Fisher encouraged attendees to think about the challenge of completing Needs Assessments and the data that comes out as we move forward into EPR.
Needs Assessments
First up was Resa Dimino, Managing Partner at Signal Fire Group, a subsidiary of RRS, and a company that focuses on supporting business and government moving toward a circular economy. They assist in policy development and implementation, assess markets and policies, and develop strategies to align goals and compliance. Her first question was: Why do we need a Needs Assessment? She explained that this is a uniquely American concept because we are trying to define as we go into an EPR system—how can we meet the varying needs of the EPR legislation that sets goals and targets? We don’t necessarily need them but if we are to do them fully within a structure to make clear sense, goals, and targets, what are we planning for? Improvements needed include an existing recycling system, ideal recycling system, EPR for PPP goals and targets needs to work together in coalescence to get to a high-performance system.
She discussed the concept’s origins and said it was due to both the producers who wanted to understand a little more about what was to be expected to make it happen, and the haulers and recyclers wanting to make sure that their concerns about development and planning were going to be considered. Prior to the production of the program plan, a Needs Assessment should be completed to define the investments and activities necessary to achieve the legislative goals, taking into account current levels of investment to ensure fair compensation. A good reference is Guidance for Producer Funded Recycling Collection Legislation by the Recycling Partnership. Needs assessment laws have been fairly consistent across the states who have passed or implemented programs/legislation. Needs assessment roles and responsibilities are all involved at some level and include a Needs Assessment Scope of work, which defines the scope of the assessment, typically issued through an RFP by the PRO or the state; State Agency who may contract for approved contractor for Needs Assessment; Producer Responsibility Organization that may fund or contract for Needs Assessment; an Advisory Group reviews and provides input into the scope of Needs assessment; and a Selected Consulting Team executes the Needs Assessment and prepares the report. Finally, she covered pros and cons of Needs Assessments. Pros were:
- Define baseline of current system
- Identifies what is needed to reach ideal system
- Studies how to reach best key goals
- Creates a database for key decision and targets
- Potential to create a consistent data set to compare states
Cons:
- Data gathering can be time consuming and expensive
- Modeling of costs can be inaccurate, based on assumptions
- Delays implementation, particularly in state that pass Needs Assessments without a program
- Needs Assessments without a policy framework lack context of program/targets/implementation structure
- Needs Assessments without EPR policy related engagement/reporting is challenging
A Deeper Dive
Dan Bacehowski, EPR Lead for HDR, took over the discussion and did a deeper dive into a Needs Assessment that was done in Colorado with the Circular Action Alliance, covering the timeline from 2023 when the Advisory Board was established, and PRO formation in 2024 to the program plan development in process now and coming in 2025; in 2026, the program plan approvals and eco-modulation rulemaking will finish and the program will begin. From 2023 – 2024, the Needs Assessment was developed and presented to JBC. In May 2023, the Circular Action Alliance was selected as the PRO and the RFP was distributed; from August to October, the contract awarded to HDR and information gathering was done, from October to the end of November, Analysis, Modeling, and Fact-Checking was finished and from December to January 2024, they submitted and finalized findings.
Needs Assessment elements included residential collection, service costs, demographics, contamination, non-residential collection, processing capacity, opportunities and costs, minimum recyclables list and additional materials, end markets, new technologies, reuse and refill, education, scenarios, and compost. He said that while available data in Colorado was low, there were some efforts that had been done to give some of the information associated with the recycling systems and programs. He said they had to use their own resources from various companies and consultants. A few had experiences in Oregon and Washington and were helpful as well. With regards to the Needs Assessment Outreach, he commented that they we went out and visited 10 MRFs (and interviewed a few others), eight compost facilities, and 15 haulers. There were also ongoing discussions with stakeholders throughout the process to test inputs as well as extensive desktop research. There were also 90+ tours, interviews with service provider and end markets, 130 completed surveys, 18 Advisory Board meetings held since the contract was awarded, 10 State Board Meetings done since the contract was awarded, and 200+ comments received and responded to by the project team.
Bacehowski pointed out that they started with a strong project team and stakeholder network that included national recycling and compost system understanding, HDR, experienced EPR partners, and local partners. With regards to data gathering, they reviewed existing documentation and database development, then moved to interviews, surveys, and webinars, as well as in-person facility evaluations and demographic analysis, which helped to understand the four different geographic areas. The data assimilation and quality review were the lion share by bringing in state advisory boards and the data consolidated into a database. They also had to understand the system performance relative to covered materials, did an analysis to identify high-level findings and trends, and finalize formulations and cost of system improvements. They visited with as many people as possible who reviewed all of the information for the municipalities and counties and that helped to develop the education, services, and items that led to modeling of the improved system.
Lessons Learned
After Bacehowski’s talk, Sarah Edwards, Director for Eunomia North America, a leading international consultancy to provide clients with data driven circular economy, policy, programs and systems services, took over. She said there were many lessons learned, but the primary ones were: setting the stage for effective collaboration, the tighter the timeline, the less accurate the result, scope the project appropriately, and anticipate the inevitable data limitations (the Needs Assessment is just one part of the data).
When setting the stage, they needed to clearly articulate the roles of the state, the Advisory Board and the PRO. Beyond the roles, there is a need to clearly define how the parties will collaborate to ensure the success of the needs assessment, including:
- Outline whether a group is directing the process, informing it or making recommendations
- Understand the decision tree, who is empowered to do what and when
- Clearly define the channels available to share information and suggestions and the timing of collaboration inputs
- Create guardrails to avoid inherent scope creep or unnecessary tangential deep-dives
- Recognize the strategic importance of the needs assessment to the PRO’s development of the Program Plan
The overarching lesson is to develop a considered approach to co-creation and collaboration.
Tight timelines impacted all elements of the project, significantly data collection, data analysis and ability to see, receive, and incorporate feedback. Due to tight timelines, ensure your project scope is focused and essential. The Needs Assessment provides vital information to inform the drafting of the PRO’s program plan, so the scope should contemplate opportunities to inform it. Bottom line: the importance of the relationship between timelines and scope cannot be understated and has a critical impact on the success of the project.
Data gaps included insufficient data, uniformity, and disclosure. With regards to insufficient data, some industry/local governments may not collect data, or some smaller private operators may not be collecting and tracking data. This means that when collected, the data is not readily comparable (for example contamination at one MRF might not be considered contamination at another). Disclosure is also a challenge because even when data is available, some entities (both public and private) may be unwilling to share it, such as cost and market sales information. The lesson here is to take different approaches to the address the data.
The Needs Assessment as Part of Policy Making starts with Laying the Foundation: Data to Justify the Policy Need. This is the lowest level of data needs and granularity. Framing the Structure: Data to Set Specific Policy Outcomes is the second layer, while Building out the Structure, Fixing the Interior: Data for Implementation, and Maintenance round out the layers of efficacy, with Maintenance being the highest level of granularity and accuracy.
At the end of the discussion, attendees had the chance to ask questions and chat with the presenters on not only the experiences they are going to through but what to expect when they are in the thick of program implementation.
The fifth and final part of this great webinar series will wrap it up with “Session 5: Lessons Learned from Brands and PROs” taking place June 26 at 1pm. This webinar will allow attendees to hear from producers and PROs what they have learned and what actions matter to create best practices from the start. We look forward to it!