Final EPA Letter!
Fri, 22 Jan 1999 16:19:13 -0500

TO GRN Steering Cmtee
FROM Bill Sheehan 9/5/96

RE EPA Letter Action

Attached is THE FINAL version of the EPA letter (includes a little tinkering
with paragraphs 4-6).

Please fax or email your letters this week and make follow-up calls so that
you can get confirmations to ME by midweek: Cutoff time will be 5 PM
EST Wednesday (9/11). Be sure to get organization to appear on the
letter, as well as address, phone, fax, email for our follow-up. Ditto for
any additional names they get. If you encourage additional letters to EPA,
be sure to ask them to copy to you (I will collect).

The asterisks (**) are meant to signify bold subheadings, should you print
this off. I put three names as contact at end since this will be as much an
organizing tool as a letter to EPA.

Good work gang!

-Bill S.


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

Dear Ms. 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% 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. Specifically, we call for 50% or greater per capita
reduction of waste by the year 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.

** 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 by mixing and burying used
resources. Elimination of landfills -- and incinerators -- should be our
national goal.

** 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
statewide recycling goals above 35%, including Florida, Minnesota, New
Jersey and Washington. Dozens of large and small communities across the
nation have already succeeded in diverting more than 35% of their 'waste'
from landfills. California has exceeded 25% waste reduction and is aiming
for 50% reduction by 2000. In the private sector, some companies have
already reported reducing their 'garbage' by as much as 80 to 90% 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 easy and convenient
opportunities for the public to recycle. In 1970 there were only two
curbside recycling programs and in 1996 there are over 7,000. The
majority of those programs were created since 1990.

By 1980 we reached a 10% recycling rate and many in the waste disposal
industry claimed that was the limit. A few years later some critics claimed
that 25% recycling was the limit. Today Americans are beyond this
artificial, self-serving 'limit.'

** Waste prevention, reuse and recycling offers tremendous economic,
social and environmental benefits - Just processing recyclables creates
about ten times more jobs than landfilling or incinerating the same
materials. Manufacturing from these materials can create 60 times the
number of jobs compared with landfilling or incinerating discards.

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.

** 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 to waste haulers must be ended and clear public policies
supporting fees for recycling and composting services must be allowed.

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% 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, 770-995-9606; or Gary Liss, California Resource Recovery
Association, 916-652-4450.