Policy Position: Presidential Plastic Action Plan

This is my position on the somewhat recent policy proposal from a group of special interests

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In The News

The Center for Biological Diversity has recently asked for President Biden to enact an executive order that would make significant changes to how chemical and plastic producing companies operate. The full proposal can be found here.

This is the very first policy position I’ve written. I’ve attempted to keep it at about 2 pages. When I attended the AAAS Science and Technology Policy Fellowship happy hour the current fellows talked about how 1-2 pages seemed to be the maximum length that anyone would typically read. This is my honest take on the situation. I often feel that my opinion or position on any of these topics is not taken seriously due to “conflicts of interest.” I suppose I would be a chemical industry “insider” to many, but I would stress that I’m a relatively unknown person writing words on the internet. Scientists do not typically run chemical companies (might be more true in pharma). I’ve never felt like an insider anywhere.

If anyone has anything constructive to add please comment, send me an email, or DM me on Twitter (@TPolymerist).

From the Center For Biological Diversity’s Proposal

The Polymerist Policy Position on The Presidential Plastics Action Plan:

The Presidential Plastics Action Plan is a proposal led by the Center for Biological Diversity. The policy seeks an executive order by President Biden to enact a ban of single use plastics in the federal government, halt any new permits for plastic feedstock production, and seeks to increase costs for chemical companies. The proposal also seeks to advance environmental justice, update federal air permitting regulations, change financing rules for federal agencies in relation to chemical and plastics companies, join international efforts, and change the materials that we use to fish. The proposal wants fast change to occur within the plastics industry and it seeks federal action to accomplish this change. While this proposal appears to come from a place of good intentions the drafters of the policy also appear ideologically opposed to chemical companies and disregard any new technology for recycling as a “false solution.” The drafters of the Presidential Plastics Action Plan appear to have some understanding of how the chemical and plastics industry works, but they do not have a deep enough understanding on how to actually change it for the better.

The major flaw of the Presidential Plastics Action Plan, aside from ideology, is the idea that our economy is not completely dependent on the implementation of plastic at scale. The world’s electronics, construction, agriculture, energy, automotive, and aerospace industries are all completely reliant on deploying plastic and high performance polymers at scale. Restricting new capacity and enacting legislation that increases costs for existing manufacturing capacity will cause a cascade of price increases across the sector that will lead to higher consumer good prices and potentially closure of manufacturing facilities that operate on margins of 15-20% or less. Restricting new capacity means that new technology that is currently being developed will not be able to be launched in the United States. For instance under this plan a start-up that is going public, Origin Materials, would not be able to build out capacity for their bio-based route to polyethylene terephthalate or produce polyethylene furanoate. I would argue having a company do well by doing good is what we want to see in the sector.

The problem that the Presidential Plastics Action Plan seeks to solve is one of plastic waste. If the primary concern is plastic waste pollution and environmental emissions from producing plastics then their policy while well intentioned is misguided. If we wish to stop putting plastics into landfills and our waterways we need economical strategies for recycling in the event that reuse has reached its logical limit. Currently, for a local municipality to recycle their plastic waste it often costs more to recycle than to landfill and is not an efficient use of tax payer money. If we want to truly solve the plastic waste problem we need to first figure out how to separate and isolate spent plastic so that it can be appropriately shipped to either a traditional recycling facility or a new advanced recycling facility. The National Science Foundation has been funding research into these problems for years, but if anything the amount of funding is too small compared to the urgency and complexity of the problem.

The Presidential Plastics Action Plan is at best a reactionary policy proposal that disregards science and engineering to satisfy its supporters. If the stakeholders of the Presidential Plastics Action Plan were truly interested in making a difference they would engage stakeholders that could effect change from inside of the chemical and plastics industry. No one in the chemical industry wants to pollute—we are desperate for economical solutions to problems in a field that is still less than 100 years old.

My Counter Proposal:

The plastic waste problem can be solved by putting a higher a value on post-consumer plastic. We need to think of spent plastics as a new raw material that can be transformed into something else that is equally if not more valuable than what it was before. The government can do this through three main policy levers that could garner bipartisan support: taxation, subsidies, and regulatory approvals. I propose that variations on these initiatives be conducted at local municipality levels in parallel so that a federal policy framework could be drafted. An example of how this might work would be the Massachusetts healthcare policy that The Affordable Care Act used as a framework.

We should be able to develop a progressive tax plan that penalizes older and less efficient production facilities that produce more emissions than newer technologies. Construction of more efficient chemical plants will reduce the total emissions released to atmosphere and would ideally become completely closed loop systems. Taxation could also be used to increase costs for future emissions, landfilling plastics, and landfilling compostable waste. Many municipalities do not have easily accessible recycling options for their residents and there is even less composting capacity available than recycling.  

Subsidies could also be offered to newer technologies that provide environmental benefits, but have initial higher costs due to not having a robust supply chain or economies of scale. Companies seeking to scale enzymatic catalysts, biobased raw materials, new recycling technologies, and biomanufacturing should get a few years of subsidies to be more cost competitive with incumbent technologies that have seen 75+ years of efficiency projects from chemical engineers. We cannot expect higher cost sustainable technologies to become economical if we do not provide a level playing field. The government has done something similar with electric vehicles already—we just need an equivalent for chemistry and plastics.

The third way that government can ease our transition off of fossil fuels and oil would be to fast track new chemicals and intermediates through the EPA if they are displacing something that is known to be dangerous. For instance if chemists were to develop chemicals that could displace the top 10 substances of very high concern that the EPA is currently investigating and we know that the new chemicals would be safer then they should get special treatment. Just because a chemical is registered with the EPA does not mean that it will sell and become economically viable and the longer it takes to get a project from the lab to a successful commercial sale can take anywhere between 2-5 years where regulatory approval is not an issue. Current time from submission of a premanufacturing notice to approval can take up to a year or longer for a decision to be made. Often, customers of chemicals do not even want to trial new materials until it has been approved from a regulatory agency. This can lead to a death spiral for new products.

In conclusion public policy for the chemical industry should be done through inclusion of all stakeholders with a logical thought process as to all of the effects that a public policy change can cause. The Presidential Plastic Action Plan is similar to that of the Republican effort to repeal the Affordable Care Act during the Trump Administration without having policy drafted to take its place. Public policy that is not fully formed or is designed to kowtow to special interest groups causes more harm than good. This is why passing legislation is more meaningful and will have more lasting impact than an executive order.

Talk to you Friday,

Tony

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The views here are my own and do not represent those of my employer nor should they be considered investment advice.

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