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[GreenYes] Fwd: CIWMB Zero Waste Proposal Under Attack
Apologies for Cross-Postings

>>Date: Mon, 05 Nov 2001 16:37:06 -0800
>>From: Mark Murray <murray@cawrecycles.org>
>>Subject: CIWMB Zero Waste Proposal Under Attack
>>
>>Your letters and testimony in support of a California 'Zero Waste' goal 
>>needed by Wednesday, November 7, at 9 am.
>>
>>>As the attached cover letter and comments indicate, a coalition of 
>>>manufacturing interests led by the American Plastics Council is 
>>>attacking provisions of the California Integrated Waste Management 
>>>Board's proposed 'Strategy Plan'. Foremost among their demands is the 
>>>exclusion of any language refering to the goal of 'zero waste'.
>>
>>The Board will be hearing comments on their Strategic Plan at the Board 
>>Agenda Briefing on Wednesday, November 7, starting at 9:30 in the 2nd 
>>Floor, Coastal Hearing Room of the CalEPA Building, 1001 I Street, Sacramento.
>>
>>If you believe that California should be at least 'aiming' for the goal 
>>of 'Zero' waste, then this is your opportunity to have your voice heard.
>>
>>If you can not attend Wednesday's hearing in person, I urge you to Fax or 
>>Email a brief letter in support of the inclusion of Zero Waste in the 
>>strategic plan to members of the CIWMB prior to the hearing.
>>
>>Keep in mind, the CIWMB has already included 'Zero Waste' in their 
>>proposed plan. The plastics industry and others are proposing that it be 
>>removed.
>>
>>Also attached is CIWMB Contact info.
>>
>>>-----Original Message-----
>>>From: Leary, Mark
>>>Sent: Monday, November 05, 2001 9:12 AM
>>>To: (BRD) Board Staff; Barnes, Deborah
>>>Subject: FW: CIWMB Strategic Plan - Comments
>>>
>>>The following note is provided to keep you current on the efforts of the 
>>>" the Thursday Group" to affect our proposed Strategic Plan. Thanks
>>>
>>>-----Original Message-----
>>>From: Tim_Shestek@plastics.org 
>>>[<<mailto:Tim_Shestek@plastics.org>mailto:Tim_Shestek@plastics.org>mailto 
>>>:Tim_Shestek@plastics.org]
>>>Sent: Friday, November 02, 2001 3:53 PM
>>>To: Leary, Mark; Packard, Rubia
>>>Subject: CIWMB Strategic Plan - Comments
>>>
>>>Mr. Leary, Ms. Packard:
>>>
>>>On behalf of the Thursday Group, I am forwarding a cover letter that
>>>outlines our comments, as well as a "mock-up" version of our suggested 
>>>language changes and additions.  We appreciate the opportunity to submit 
>>>these comments and look forward to continuing our dialogue.
>>>
>>>Tim Shestek
>>>Manager, State & Local Public Affairs
>>>American Plastics Council
>>>1121 L St., Suite 910
>>>Sacramento, CA 95814
>>>916-448-2581 (phone)
>>>916-442-2449 (fax)
>>>916-838-0713 (cellular)
THURSDAY GROUP LETTER

>November 2, 2001
>
>Mr. Mark Leary
>Executive Director
>California Integrated Waste Management Board
>1001 I Street
>Sacramento, California 95812
>
>Dear Mr. Leary:
>
>The Thursday Group would like to express its appreciation to you and your 
>staff, Mr. Michael Paparian, and Mr. Jose Medina for meeting with us to 
>discuss the California Integrated Waste Management Board's (CIWMB) 2001 
>Strategic Plan.  As you requested, this letter serves to provide the Board 
>with more information about our concerns and comments.  We have also taken 
>the liberty of including our latest "mock-up" version that reflects our 
>constructive dialogue on October 31, 2001.
>
>Our concerns and comments can be outlined in the following 
>categories:  (1) the process by which the business community is afforded 
>the opportunity to participate in the implementation of this plan; (2) 
>concern over the term "zero-waste"; (3) the need for further development 
>of the terms "sustainability" and "product stewardship"; (4) technical and 
>clarifying language changes in the area of environmental justice, 
>environmentally preferable purchasing and conversion technology; and (5) 
>concern over the Board's role in regulating household chemical products.
>
>PROCESS
>
>In an attempt to ensure the business community is afforded every 
>opportunity to participate in the implementation of the strategic plan, 
>its objectives and strategies, we propose the addition of language on page 
>1 specifying that all affected stakeholder groups will be included in the 
>formation of strategic teams and that the Board will make every feasible 
>effort to ensure that decisions and actions associated with the 
>implementation of the plan be subject to public review and 
>comment.  Additional references to help ensure business community 
>participation are also contained in our mock-up version.  We would also 
>suggest that periodic workshops or briefing sessions be held to review the 
>implementation of the strategic plan and solicit further public 
>comment.  We recommend that the Board include a description of that 
>process and clearly outline in the strategic plan opportunities for 
>continued public input.
>
>ZERO-WASTE
>
>The term "zero-waste" is defined in the original strategic plan to mean, 
>"where the public, industry, and government strive to reduce, reuse, or 
>recycle all municipal solid waste materials back into nature or the 
>marketplace in a manner that protects human health and the environment and 
>honors the principles of California's Integrated Waste Management Act." 
>(page 4, priority #7). The notion of recycling 100 percent of the state's 
>solid waste stream is not feasible, due in large part to recycling 
>economics and consumer behavior.  Today, state and local governments are 
>close to achieving the mandated 50 percent waste diversion goal, mainly 
>because it makes environmental and economic sense to capture the 
>substantive portions of our waste stream.  A zero-waste policy ignores the 
>law of diminishing returns by forcing the state and manufacturers to enact 
>programs to capture even the smallest components of the waste stream. The 
>blind pursuit of a zero "solid" waste environment would impose substantial 
>costs on manufacturers, taxpayers and consumers, require inordinate energy 
>expenditures and would result in increased air and water pollution.  These 
>trade-offs do not make economic or environmental sense.  Our comments 
>propose that this term be replaced with the term "sustainability."
>
>SUSTAINABILITY
>
>On page 26, we propose to define the term sustainability as a goal that 
>all stakeholders should strive for and one that strikes a fair balance 
>between environmental protection and continued economic growth.
>
>PRODUCT STEWARDSHIP
>
>We propose on page 26 and 27 that the strategic plan include a product 
>stewardship policy statement and list of guiding principles. Reducing the 
>environmental impact of a product is a laudable goal and one that makes 
>good business sense.  At the same time, we feel that a working definition 
>is necessary to convey the Board's intention that all actors involved in 
>the useful life of a product play a role in product stewardship.  The 
>Board's product stewardship policy statement should also reflect the need 
>for flexibility, independent judgment and discretion in the application of 
>this concept.
>
>ENVIRONMENTAL JUSTICE LANGUAGE CHANGES
>
>The suggestion to strike the first bullet (Page 2, and Pages 7, 8: 
>"Commitment to Environmental Justice") is strictly editorial based on 
>proposed changes to the last bullet.  The Thursday Group does not object 
>to this statement.
>
>Our proposed language in the last bullet is taken from California's 
>statutory definition of "Environmental Justice", established by SB 115 
>(Solis) in 1999.  The Legislature reaffirmed this language last year in SB 
>89 (Escutia) and again this year in SB 828 (Alarcon), AB 1390 (Firebaugh) 
>and AB 1553 (Keeley).
>
>The current language undermines the statutory mandate to ensure the fair 
>treatment of all people by drawing the conclusion that all low income and 
>minority populations are disproportionately impacted by pollution, absent 
>any analysis to support that conclusion.  SB 89 requires the Cal-EPA 
>agencies to review existing programs, policies and guidelines to identify 
>shortcomings that could impede the achievement of environmental justice 
>and take action to correct any problems.  This language prejudges the 
>outcome of that process.
>
>ENVIRONMENTALLY PREFERABLE PURCHASING
>
>On page 27, we suggest that cautionary language be added that reflects the 
>difficulty in designating a product or process as "environmentally 
>preferable." The State should avoid specific endorsements of any product 
>or service.
>
>CONVERSION TECHNOLOGY
>
>On page 3, we have added language to strengthen the role new alternative 
>waste management practices can play in reaching waste diversion goals.  We 
>have also added language that would direct the state to support local 
>government efforts to use alternative means of diverting waste, including 
>but not limited to the creation of electricity and fuel.
>
>HOUSEHOLD CHEMICALS
>
>We are suggesting that the reference on page 14 pertaining to state grants 
>to local governments regarding the dangers of household chemicals and 
>alternatives that may be available be deleted.  Household chemicals must 
>adhere to applicable federal and state regulatory requirements and 
>products must be thoroughly evaluated for health, safety, and 
>environmental effects before they reach the marketplace.  Prior attempts 
>to provide grants to local governments have resulted in material promoting 
>alternatives to household chemicals that actually resulted in increased 
>risks to children.  In well-meaning but misguided efforts, environmental 
>groups and some local governments have urged consumers to formulate their 
>own substitute products using various commercially available chemicals and 
>materials, with possibly some very dangerous consequences.  These home 
>mixtures do not have labels, and there is no data on their efficacy, 
>health, safety and environmental impact.
>
>We propose that the Board work with the household chemical industry to 
>examine if the state can bolster existing industry education efforts.
>
>Our comments are an attempt to strengthen the Board's strategic plan in a 
>manner that helps further protect the state's resources, but also 
>encourage policies that foster continued economic growth. These goals 
>should not be mutually exclusive.  We look forward to working with the 
>Board on the continued development and ultimate implementation of the 2001 
>strategic plan.
>
>Sincerely,
>
>THE THURSDAY GROUP
>**************************************************
>CIWMB Board Members
>Contact Information
>
>Linda Moulton-Patterson
>Phone:  916-341-6024
>Fax:  916-319-7280
>Email:  lmoulton@ciwmb.ca.gov
>
>Dan Eaton
>Phone:  916-341-6010
>Fax:  916-319-7100
>Email:  deaton@ciwmb.ca.gov
>
>Steven R. Jones
>Phone:  916-341-6016
>Fax:  916-319-7445
>Email:  sjones@ciwmb.ca.gov
>
>Jose Medina
>Phone:  916-341-6051
>Fax:  916-319-7216
>Email:  jmedina@ciwmb.ca.gov
>
>Michael Paparian
>Phone:  916-341-6035
>Fax:  916-319-7359
>Email:  paparian@ciwmb.ca.gov
>
>David A. Roberti
>Phone:  916-341-6039
>Fax:  916-319-7599
>Email:  droberti@ciwmb.ca.gov

Gary Liss
916-652-7850
Fax: 916-652-0485

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