[GreenYes] Send Comments Today to EPA on Beyond RCRA policy

[Gary Liss <gary@garyliss.com>]

Apologies for Cross-Postings

Pasted below is a cover letter to a 15 page statement GRRN just sent in to 
EPA regarding their Beyond RCRA policy paper.

Please send a note TODAY to EPA to say you agree with the key points in 
GRRN's cover letter, to show more support for this document by today's 
deadline.  Please Send:
To: <RCRA-Docket@epa.gov>
Cc: <leith.angie@epa.gov>, <jennifer.agostinelli@ross-assoc.com>, "Bill 
Sheehan" <zerowaste@grrn.org>, gary@garyliss.com (Gary Liss)

If you want a copy of the full document, please email me back and I'll send 
it right back to you.  It will be posted on the GRRN website in the near 
future as well.

Thanks!

Gary Liss
*********************************************
From: "Bill Sheehan" <zerowaste@grrn.org>
To: <RCRA-Docket@epa.gov>
Cc: <leith.angie@epa.gov>, <jennifer.agostinelli@ross-assoc.com>
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Beyond RCRA White Paper
c/o RCRA Information Center
U. S. Environmental Protection Agency (5305G)
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Dear EPA Staff:

The GrassRoots Recycling Network (GRRN) appreciates the opportunity to 
comment on your Draft White Paper: "Beyond RCRA: Prospects for Waste and 
Materials Management in the Year 2020."

GRRN is a North American network of recycling and community-based activists 
who advocate policies and practices to achieve zero waste, to end corporate 
welfare for waste, and to create sustainable jobs from discards. We aim to 
reverse unsustainable practices and policies by building effective 
coalitions and partnerships for Zero Waste policies based on government and 
corporate accountability for waste.

We applaud the EPA's drafting of this visionary document and believe that 
it has much to commend it.  However, based on our years of experience in 
this field, we believe the EPA should adopt Zero Waste as the unifying 
theme for this vision statement.  EPA needs to adopt Zero Waste as its 
overarching message to focus the resources and attention needed on all 
aspects of the challenges and opportunities of managing wastes and 
materials described in this vision statement.

GRRN also believes that the rules it promulgated in 1991 as 40 CFR Part 258 
to establish national minimum standards for municipal landfills do not 
comply with the law.  Major changes are required in performance standards, 
accountabilities and designating what materials are permissible in Subtitle 
D landfills.  In particular, GRRN supports eliminating land disposal of 
organic matter in the ground, which would divert more than 60% of the 
material presently discarded.  When added to current recovery efforts, this 
would bring overall diversion to 75% of the municipal waste stream.

We also believe that producers of products and packaging must play a much 
larger role in taking responsibility for the wastes that they create.  For 
every ton of municipal discards wasted, about 71 tons of manufacturing, 
mining, oil and gas exploration, agricultural, coal combustion, and other 
discards are produced Local governments have done more than their fair 
share over the past decade to increase the national rate of 
recycling.  Dramatic future progress can only be achieved through the 
adoption of new rules for businesses that ensure that waste decisions are 
factored into the design, manufacturing, promotions, and shipping of 
products to consumers, all decisions that are beyond the control of local 
governments.

Additional comments are attached.  These comments first describe the GRRN's 
position on current "dry tomb" and proposed accelerated decomposition 
landfills, and, second, outline GRRN's vision for zero waste in the new 
millennium. The second section responds to the key questions that you have 
identified as part of this process.

SECTION 1:  Grassroots Recycling Network Comments On Municipal Waste 
Landfill Policies

SECTION 2:  Grassroots Recycling Network Comments On Draft White Paper 
"Beyond RCRA:  Prospects For Waste And Materials Management In The Year 2020"

Thank you for your consideration of our input.  If you have any questions 
on Section 1, please contact Peter Anderson at 608-231-1100 or 
anderson@recycleworlds.org.  If you have any questions on Section 2, please 
contact Gary Liss at 916-652-7850 or gary@garyliss.com.  If you have any 
questions about GRRN, please contact me at 706-613-7121 or zerowaste@grrn.org

Sincerely yours,

Bill Sheehan, Ph.D.
Executive Director
GrassRoots Recycling Network
706-613-7121
Fax: 706-613-7123
zerowaste@grrn.org
www.grrn.org
Gary Liss
916-652-7850
Fax: 916-652-0485

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