FPA Submits Comments to the Oregon Department of Environmental Quality (DEQ) Regarding the Producer Responsibility Organization (PRO) Proposed Plan Amendment 2 to the Oregon Producer Responsibility Program Plan

The Flexible Packaging Association (FPA) respectfully submits these comments to the Oregon Department of Environmental Quality (DEQ) regarding the Producer Responsibility Organization (PRO) proposed Plan Amendment 2 to the Oregon Producer Responsibility Program Plan. FPA understands that the intent of Appendix A is to provide a quick reference crosswalk between the program plan proposal and what is required in the regulations. We understand that Appendix A does not reflect the plan per se, however we would be remiss if we did not note that any documentation submitted to the state for public comment is a legal document subject to interpretation.