EPA Letter from GRN

Fri, 22 Jan 1999 16:14:27 -0500

TO GreenYes chat group
FROM Grassroots Recycling Network Steering Committee
RE Letter to EPA

Below is the letter sent to EPA by the Grassroots Recycling Network on
behalf of the 50 co-signing individuals and organizations listed at the end.
The letter urges EPA to adopt a more aggressive goal than the 35 percent
recycling goal it is now considering. I am sending the press release we
issued for this event in a separate email message.

We urge you to send your own comments to EPA as soon as possible. PLEASE copy
GRN: email bill.sheehan@sierraclub.org or mail a copy to 268 Janice Drive,
Athens, GA 30606.

Thanks in advance!
Bill Sheehan

September 19, 1996

The Honorable Carol Browner
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460

Dear Administrator Browner:

We are writing to support a review of the national goal for recycling,
which EPA Assistant Administrator Elliott Laws announced is under
consideration. Mr. Laws stated in June that EPA is considering a new
national goal of 35 percent recycling by the year 2005.

We applaud EPA for setting a national goal, but we urge EPA to set a
waste elimination rather than a recycling goal, and to set a far more
ambitious goal for the year 2005. Specifically, we call for 50 percent or
greater per capita reduction of waste going to landfills and incinerators by
2005, and for the eventual elimination of waste altogether.

The undersigned individuals and organizations are all engaged in efforts
to eliminate waste. All of us have experience that demonstrates numerous
environmental, economic and community benefits flowing from public
and private efforts to conserve resources rather than waste them in
landfills or incinerators.

(1) Set a waste elimination goal that relies on waste prevention, reuse,
recycling and composting - While we strongly endorse setting a national
goal, we urge EPA to change its focus to eliminating waste -- all types of
waste -- rather than just recycling. Establishing and achieving waste
elimination goals requires increased waste prevention, reuse and
composting, as well as traditional recycling. Pursuing aggressive waste
elimination goals will increase reuse, recycling and composting because
these practices compete directly with wasting for the same supply of

Waste elimination is also necessary for long-term environmental
protection. Today's landfilling regulations transfer the economic, public
health and environmental burdens associated with groundwater pollution
to future generations. They also postpone pressure on society to develop
viable long-term discard management alternatives.

We request that EPA work to revise Subtitle D of the Resource
Conservation and Recovery Act (RCRA) to require that landfills protect
groundwater for as long as wastes remain a threat. RCRA needs to be
updated to require the full costs for perpetual maintenance of 'dry tomb'
landfills are paid by those who create waste.

(2) Set an ambitious waste reduction goal - A much more ambitious
national goal is warranted as we enter the 21st century, based on empirical
data from programs developing across the nation. Several states report
recycling more than 35 percent of their discards, including Florida,
Minnesota, New Jersey and Washington. More importantly, dozens of
large and small communities across the nation have already succeeded in
diverting more than 35 percent of their discards from waste facilities.
California has exceeded 25 percent waste diversion and is aiming for 50
percent diversion by 2000. In the private sector, some companies have
already reported reducing their waste by as much as 80 to 90 percent in
ways that are cost effective.

One of the most important pieces of evidence that our nation can do more
to eliminate waste is the phenomenal public support for recycling. More
than 100 million Americans demonstrate their commitment daily by
recycling. More Americans recycle than vote.

The growth of recycling has defied all predictions. When EPA was
created in 1970 very few communities provided convenient opportunities
for the public to recycle. In 1970 only a handful of curbside recycling
programs existed, and in 1996 more than 7,000 are operating. The majority
of those programs were created since 1990. By 1980 we reached a 10
percent recycling rate and many in the waste disposal industry claimed
that was the limit. A few years later some critics claimed that 25 percent
recycling was the limit. Today Americans are beyond this artificial, self-
serving 'limit.'

(3) Waste prevention, reuse, composting and recycling offer tremendous
economic, social and environmental benefits - Processing recyclables
creates about ten times more jobs than landfilling or incinerating the same
materials. Manufacturing products from recovered materials creates
many additional jobs - as many as 60 times more jobs, depending on the

The huge job creation benefits of reuse and recycling have both social as
well as economic significance. At a time when our social fabric seems to
be unraveling, increasing use of our human capital in businesses that
conserve our natural capital is sound public policy.

Environmentally, the greatest benefits from reduction, reuse and recycling
come at the front end of the manufacturing process. These material
conservation strategies save wilderness, reduce the pressures to despoil
diverse wildlife habitat and old growth forests, and reduce the energy use
and massive air and water pollution impacts of extracting, refining and
transporting raw materials. Environmental benefits are also gained from
reducing reliance on burning and burying waste.

(4) How to increase recycling and reduce wasting - Recycling will
increase and wasting will decrease by eliminating policies and subsidies
favoring garbage collection, landfilling and incineration. Local
government contracts limiting competition by granting exclusive
franchises for commercial recyclables must be ended and clear public
policies supporting fees for recycling and composting services must be

Recycling, reuse and composting will also increase by eliminating
taxpayer subsidies for extracting natural resources (such as metals,
petroleum and timber). Each year, for instance, hundreds of millions of
taxpayer dollars go to pay for logging roads on public lands, and often
trees are sold below market value. Outdated laws allow companies to
plunder public lands for precious metals for only a token fee -- such as the
Canadian company that recently was given title to billions of dollars
worth of gold on our public land while returning virtually nothing to the
U.S. Treasury.

Until welfare for wasting resources is eliminated, we believe that
governmental action is necessary to 'level the playing field' so that
recycling, composting and reuse are not put at a competitive

In conclusion, ample evidence from polls and empirical data from many
communities demonstrates that the American public is predisposed to
recycle if government and industry meet them half way. By establishing a
goal of 50 percent waste reduction by the year 2005, EPA will send a signal
that America is committed to creating jobs where they are most needed,
and intends to become a world leader in harnessing the economic, social
and environmental benefits of resource conservation.

Please enter these comments into your formal record concerning the
proposed national recycling goal and keep us informed of additional
opportunities and deadlines for public review and comment. You can
contact the Grassroots Recycling Network through Neil Seldman or
Brenda Platt, Institute for Local Self Reliance, 202-232-4108; Bill Sheehan,
Sierra Club National Waste Committee, 770-995-9606; or Gary Liss,
California Resource Recovery Association, 916-652-4450.


Bill Sheehan, Ph.D.
268 Janice Drive
Athens, Georgia 30606

On behalf of the Grassroots Recycling Network and the following

cc: Vice President Al Gore
Assistant EPA Administrator Elliott Laws

Co-signing individuals and organizational affiliation:

Kate Krebs Arcata Community Recycling, Arcata CA
Rhys Roth Atmosphere Alliance, Olympia WA
Peter Dreckmeier Bay Area Action, CA
John Hunting Beldon Fund, Washington DC *
David Hurd Bronx 2000, NY
Rick Anthony California Resource Recovery Association, CA
Rick Best Californians Against Waste, Sacramento CA
Alan Silverstein Center for Ecological Technology, Pittsfield MA
Ann McGovern Compost Forever, Inc.
Ann Gerace Conservation Consultants, Inc.
Ted Ward Del Norte Solid Waste Management Authority, CA
Juan Ruiz, P.E. E & C Consulting Engineers, Inc., Lawrenceville GA
Gretchen Brewer Earth Circle Recycling and Conservation, CA
Emily Miggins Earth Island Institute, Rethink Paper Project, CA
Eric Lombardi EcoCycle, Boulder CO
Mary Applehof Flowerfield Enterprises, Kalamazoo MI
David Stitzhal Grassroots Recycling Network, Sacramento CA
Alicia Culver Government Purchasing Project, Washington DC
Harvey Wasserman Greenpeace U.S.A., Senior Advisor, Columbus OH
Andy Mahler Heartwood, Bloomington IN
R. Ford Schurmann, Jr. Infinity Recycling, Chestertown MD
Brenda Platt Institute for Local Self-Reliance, Washington DC
Dave Kirkpatrick Kirkworks, Durham NC
A. Bradley Knox County Solid Waste Department
Dennis Livingston Community Resources, Baltimore MD
Amy Perry MASSPIRG, Boston MA
Bob Ginsburg Midwest Labor Research Center, Chicago IL
Inge Theisen National Asian Pacific Center
Jim McNelly NaturTech Composting Systems, MN
Resa Dimino Nonprofit Recycling Council (Natnl Recycling Coalition)
Judi Enck NYPIRG, NY
Maurice Sampson Pied Piper Institute, Philadelphia PA
Jim Knox Planning and Conservation League, Sacramento CA
Tim Keating Rainforest Relief
Peter Anderson RecycleWorlds Consulting, Madison WI
Tania Levy Recycling Analyst, City of Berkeley, CA
Cathy Evans Recycling consultant, CA
Jim Crater Recycling Services, Inc., Pottstown PA
Jeffrey Smedberg Santa Cruz County Public Works, CA
Beverly Marshall SEMREX, Winona MN
Jacy Davis Solana Recyclers, Encinitas CA
Lynn Landes Solid Waste Chair, Pennsylvania sierra Club
Jeffrey Morris Sound Resources Group, Seattle WA
Mary Tkach St. Paul Neighborhood Energy Consortium, MN
Shelli Graff The Pickup Artisits, Losangeles CA
Pete Pasterz The Recyclers, East Lansing MI
Dan Knapp Urban Ore, Inc., Berkeley CA
Elizabeth Schrag Washington Citizens for Resource Conservation, WA
Sonya Newenhouse WasteCap, Madison WI
John Young Worldwatch Institute, Washington DC *

* Affiliation for identification purposes only