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Board refines plastic-reduction waiver form and seeks quantitative hardship examples
Summary
Board members recommended making the waiver form for the town's plastic-reduction rule a fillable electronic attachment that requires a marginal-cost calculation and an example to quantify "undue financial hardship"; staff will prepare sample reports and a fillable form for permit attachments.
The board reviewed a draft waiver form intended to document undue financial hardship for food-service operators seeking exemptions to the town's plastic-reduction rules and asked staff to make it more quantifiable and legible.
Members recommended adding an example calculation of incremental cost (the additional cost of the alternative container divided by the product price) so applicants provide consistent, comparable information. "If you take the additional cost of the container divided by the cost of the goods in the container as sold ... that incremental amount would be meaningful," one member said when proposing an example.
Members suggested the form be converted to a fillable electronic attachment to reside with the food permit (so legibility and recordkeeping improve) and that staff add fields for business name, incremental-cost computation and a short narrative about supply-chain or timing constraints. Staff said they can create a fillable form and that the submission will remain attached to the permit file for review.
The board also discussed operational burdens and emphasized the need to balance the regulatory goal with practical compliance costs for small businesses. Staff will prepare sample calculations drawn from recent permit reports and return a fillable form for board review.
