/ Governance /
Increasingly, WM is doing much more than managing waste. We are producing energy, restoring habitats and helping local governments and citizens reduce, reuse and recycle materials. As we work with our customers and communities to create a more resilient and sustainable future, we believe we have an important voice to add to the discussion around several key policy debates.
Participation in policy discussions supplements our dialogue at the local level and ensures that we are working with stakeholders from many perspectives. Each year, we give dozens of presentations on topics involving recycling, waste reduction, renewable energy and fuel, and civic engagement. As the dialogue around the topic of sustainable materials management and life cycle thinking developed, we sponsored three terms of multi-stakeholder dialogues on the core issues affecting our industry and those impacted by it.
We have always believed in the value of bringing together diverse viewpoints in a sustained effort to find common ground and mutual understanding of difficult environmental challenges. This has led to an ongoing policy commitment to sustainable materials management, using life cycle thinking to pave the way to reduce environmental impact over time. We have worked with academic institutions such as Florida State University’s Hinkley Center and York University, as well as research institutions such as the Environmental Research and Education Foundation (EREF) to test models around sustainable materials management and life cycle thinking. The results of this research, known as our Spectrum project, included input from third parties, including York University and Cascadia Consulting Group, and was shared with the U.S. EPA, Oregon’s Department of Environmental Quality and others for further input.
Our employees are also enriched by broad interaction with stakeholders and informed dialogue on key issues like materials management, renewable energy, climate change and adaptation, responsible governance, conservation and a host of other topics.
Public Policy Overseas
To ensure compliance with domestic and international law, WM has adopted an Anti-Bribery Policy and established an Anti-Bribery Committee. All employees involved in foreign business projects must receive Foreign Corrupt Practices Act (FCPA) training. In addition, the WM Code of Conduct includes a section on doing business internationally to ensure our compliance with local laws as well as U.S. laws that govern our activities in international markets.
Stances on Key Policy Issues
These issues represent significant challenges for our industry and are areas of special focus for WM. We welcome engagement from stakeholders around these issues and strive to work with representatives from the government, the business sector, community groups and environmental advocates to build consensus for positive change.
WM’s public policy team coordinates its policy positions on topics across the country while also recognizing the local nature of our business. Regional policy and regulatory variations are considered and coordinated with broader corporate policies.
Motivated by concerns about GHG emissions, and in the absence of comprehensive federal policy intervention, numerous states have implemented programs to promote renewable energy. WM supports the development of policies that would allow the country to make significant strides in reducing GHG emissions associated with fossil fuel consumption, including encouraging the continued use of landfill-produced methane gas as a renewable energy product, both in electricity and transportation applications. Providing for greater transparency and long-term certainty for our industry under the federal Renewable Fuel Standard Program.
Alternative Fuel Production
WM supports policies, including existing renewable fuel standards, that encourage and facilitate the production of fuel from renewable sources such as municipal solid waste; tax policy that encourages the development of alternative fueling infrastructure; and the conversion of diesel vehicles to cleaner-burning natural gas and renewable natural gas (RNG) from waste.
Natural Gas and Alternative Fuel Vehicle
WM’s s fleet policy calls for a transition to natural gas vehicles. Further, we are transitioning to RNG fuel in our natural gas trucks to help us achieve our GHG reduction goals. We encourage ongoing federal and state regulatory support for the transition of heavy-duty fleets to natural gas as the preferred fuel for our industry. The natural gas vehicle platform provides an opportunity to use RNG derived from waste materials, further improving air quality. WM also works with original equipment manufacturers on potential fleet alternatives, such as technology for electric vehicles (EVs), for our Class 8 heavy-duty fleet. We are piloting several EVs in 2022 in anticipation of future EV technology options for our heavy-duty truck class.
Extended Producer Responsibility (EPR)
Legislation establishing EPR for traditional recyclables has been implemented in many places around the world, including the EU and Canada. EPR regulations are designed to place either partial or total responsibility on producers to fund the post-use life cycle of the products they create. Along with the funding responsibility, producers may be required to undertake additional responsibilities, such as taking over management of local recycling programs, and managing the collection operations and recycling processing infrastructure. Increased focus on the cost of recycling in the U.S. has increased the threat of EPR at the state and local level. Shifting the cost to producers will disrupt current municipal programs, will create flow control for recyclables and will commoditize recycling.
When combined with the impacts of the global market shifts caused by China’s termination of imports, the most recent financial stress of recycling on local communities has led to a number of states considering EPR regulations, which would shift the financial burden of recycling to the producers of products and goods. Industry trade organizations and individual companies are engaged in discussions to mitigate long-term impacts to recycling programs, and the industry as a whole, as the result of EPR. If wide-ranging EPR regulations were adopted, they could have a fundamental impact on many of the streams we now manage and how we operate our business, including contract terms and pricing. Our customers would be producers instead of municipalities or individual customers, with a focus on lowest price rather than service, and an emphasis on collection rather than end markets.
WM has actively engaged in the public policy dialogue around EPR for over a decade. The company has historically supported EPR legislation for most hard-to-handle materials such as paint, batteries and electronic waste, although not for traditional recyclables such as the paper, cardboard, bottles and cans collected in most recycling programs. WM recently updated and formalized its policy of support for advanced disposal fees (ADF) or eco-fees placed on products/packaging. While WM supports both visible eco-fees and embedded fees (invisible to consumers) on packaging, we prefer visible fees so consumers can clearly see the environmental cost of their purchases.
WM may also support brand-funded mechanisms to support recycling when local control, existing infrastructure and franchises are protected. EPR that recognizes and uses existing infrastructure investments while maintaining local control and contracts/franchises for recycling collection/processing may be worth considering as a funding option for sustainable recycling. WM opposes EPR schemes that relinquish control of recycling programs to producers in exchange for the producers taking on the costs of recycling. Read more about WM’s position on Extended Producer Responsibility.
WM’s mitigation of the risk posed by EPR continues to focus on:
- Partnering with stakeholders to educate policymakers and the public about the long-term, carbon-reducing benefits of recycling, EPR’s shortcomings in driving demand for recycling, the questionable long-term economics, and the environmental impacts of divesting municipal control over recycling contracts.
- Educating customers on how to recycle right.
- Negotiating legislative language directly with bill sponsors.
In 2020, WM created an EPR policy to support funding from packaging fees for recycling, with funds flowing to local government, who will continue to manage their programs. Several states have incorporated EPR WM has suggested. By improving the economics of recycling for our customers, we hope to see more focus on prioritizing recycling those materials with the highest environmental/carbon-reducing benefits.
Sustainable Materials Management
As we have sought to maximize the value of the material we manage, we have reviewed the U.S. waste hierarchy—reduce, reuse, recycle, recover and then dispose—as well as state-level solid waste and recycling priorities. Our review revealed that regulations regarding solid waste, recycling, energy policy and renewable fuels often compete and produce unintended results. Newer technologies designed to divert material from landfills may not fit neatly into the hierarchy. As the EPA and state governments address the environmental impacts of waste disposal, recovery and recycling, we encourage them to consider life cycle approaches that view waste not merely as a problem to be solved, but as a resource. Moreover, life cycle thinking highlights the measurable benefits of material management in its opportunities to reduce GHGs and use of energy.
Mandatory Recycling Programs and Policies
Governments at all levels are seeking ways to divert waste from landfills through increased recycling and recovery. Some jurisdictions have implemented mandatory recycling programs, and we support such programs when they make economic sense, have the support of customers and communities, recognize the expertise and investment of our industry, and reflect planning and preparation sufficient to ensure success.
Managing State and Local Recycling and Organics Policy Developments
Our Government Affairs department coordinates information on recycling, its benefits and challenges, and innovations in state and local regulatory standards, as well as policies in support of our overarching goal to make recycling as environmentally productive as possible. Recycling, organics and waste reduction policies are largely driven by local and state initiatives, so it is important to participate and share experience wherever these policy debates arise.
As China implemented new policies restricting imports of recyclables, WM worked with stakeholders including the Institute of Scrap Recycling Industries (ISRI), the office of the United States Trade Representative, the U.S.-China Institute and other stakeholders to understand the policies and help states, cities and other customers adjust their programs accordingly. China’s policies have had global economic implications but are considered necessary if the country is to achieve its own environmental goals. We have worked with a broad range of industry stakeholders to develop short- and longer-term plans for managing the recyclables that can no longer be shipped to China.
In May 2019, Norway introduced a proposal to ban all exports of plastics as part of the Basel Convention beginning in January 2021. ISRI has represented our industry in the ongoing discussions about this new requirement; however, because the U.S. is not party to the Basel Convention, ISRI is working through other parties that are part of related The Organization for Economic Co-operation and Development discussions. The global plastic export restrictions required by the Basel Convention have further accelerated WM’s commitment to selling plastic to domestic markets. Our position to only sell residential plastic to domestic markets has expanded to a commitment to market all plastic according to the requirement of the Basel Convention and any Article 11 bilateral, multilateral and regional agreements thereunder.
WM prioritizes opportunities with the best potential to deliver high degrees of emissions reduction at low cost, or to deliver emissions reductions combined with a positive return. Our goals and public disclosure of renewable energy production, recycling and fuel efficiency drive our investment strategy. This approach to addressing the challenges of climate change is integrated into the evaluation of all significant activities and potential investments—from collection fleet and logistics to administrative functions, capital investments and facility operations.
For example, WM has engaged collaboratively with the U.S. EPA and state regulators, environmental organizations, and other public and private owners to develop technical information and recommendations on regulation of landfill gas emissions. WM is also working with the EPA and trade associations for public and private landfills on technical issues with current regulation of landfill gas controls to facilitate the beneficial use of this renewable energy resource.
Similarly, we continue to work with government regulators, engine and vehicle makers, fleet owners and environmental groups to provide recommendations on the next phase of fuel efficiency and GHG-reduction standards for heavy-duty trucks. We are hopeful that these new rules will recognize the value of our clean-burning renewable natural gas, while we plan for the future potential of electric and hydrogen-powered trucks.
We are actively working with stakeholders from all perspectives to assess how GHG emissions can be accurately inventoried and disclosed, as well as how information can be used in climate change initiatives that improve environmental quality and are consistent with a healthy economy. We participate with CDP, the Dow Jones Sustainability Index and numerous other non-governmental organizations and customer sustainability evaluation services to report on our sustainability progress.
WM has been very active with all stakeholders and customers on the public dialogue surrounding recycling, its potential as a potent mechanism for GHG reduction and the economic challenges facing the industry. We have also commented on federal, regional and state frameworks for addressing climate change. Extensive comments, all of which are a matter of public record, and recommended strategies have been discussed with the following:
- California Air Resources Board
- Climate Action Reserve
- Climate Registry
- Environmental Council of the States
- Regional Greenhouse Gas Initiative
- U.S. Environmental Protection Agency
- U.S. Department of Transportation
- U.S. House of Representatives, Committee on Energy and Commerce
- U.S. House of Representatives, Committee on Science and Technology
- U.S. House of Representatives, Committee on Ways and Means
- U.S. Senate, Energy and Natural Resources Committee
- U.S. Senate, Finance Committee
- Western Climate Initiative