[GreenYes] Landmark EPR Report in CA Needs Support NOW

["Gary Liss" <gary@no.address>]

Apologies for Cross-Postings

Please send in a letter like the sample letter
attached to the CIWMB expressing your organization's support for this
Report.  Please cc: me.  Thanks!

Gary

From: "Tedd Ward" <tedd@no.address>
To: <CRRAPolicy@no.address>,
         <crra_alerts-owner@no.address>,
         <ncra@no.address>,
         "'Scott Smithline, Esq., CAW'" <scottsmithline@no.address>,
         <nicklapis@no.address>,
        "'Ann Schneider'" <schneiderann@no.address>,
         "'Gary Liss'" <gary@no.address>
Subject: Landmark EPR Report Needs Support NOW
Date: Mon, 2 Jul 2007 11:00:48 -0700
Organization: Del Norte Solid Waste Management Authority

Greetings:
 
The CIWMB has posted a landmark report on a Framework for Evaluating End-of-Life Product Management Systems in California, which may be found at:
http://www.ciwmb.ca.gov/agendas/mtgdocs/2007/07/00022134.pdf
 
Not surprisingly, many industry reps are submitting thick comment letters deriding the very concepts of Extended Producer Responsibility (EPR) and Product Stewardship described within this document.  The CIWMB has adopted strategic directive #5 supporting EPR:
 
SD-5: Producer Responsibility
It is a core value of the CIWMB that producers assume the responsibility for the safe stewardship of their materials in order to promote environmental sustainability.
 
Specifically, the CIWMB will: 
1.       Utilize existing Board authority to foster "cradle-to-cradle" producer responsibility.
2.       Seek statutory authority to foster "cradle-to-cradle" producer responsibility.
3.       Analyze the feasibility of various approaches to increasing producer responsibility, including during the product design and packaging phases, and make recommendations to the CIWMB Board by December 2007, and annually thereafter.
4.       Build capacity and knowledge in CIWMB on Extended Producer Responsibility (EPR) issues and solutions.
5.       Develop and maintain relationships with stakeholders that result in producer-financed and producer-managed systems for product discards.
 
SO, now is the time for your support letters for EPR programs.  CIWMB needs your support for their courage in standing up to the lobbyists and creating an EPR framework for programs benefitting the planet and a more efficient material economy.
 
Please customize the letter below and send to CIWMB ASAP.  Forward this e-mail to any and all parties who support EPR programs.  The more letters, the better. 
 
Thanks.
 
Tedd Ward, M.S.  - Program Manager
Del Norte Solid Waste Management Authority
1700 State Street
Crescent City, CA 95531
 
(707) 465-1100
 
"My life is garbage, but I'm in recovery."
 
 
 
 
Addressed To:
 
Ms. Margo Brown, Chair
California Integrated Waste Management Board
1001 I Street, P.O. Box 4025
Sacramento, CA 95812
 
Via Fax:  916-319-7349
 
 
RE:  Contractor's Report to the Board:  Framework for Evaluating End-of-Life Product Management Systems in California
 
Madam Chair:
 
I am writing on behalf of X to provide comments on the Contractor's Report to the Board titled:  Framework for Evaluating End-of-Life Product Management Systems in California
 
First, I want to thank the CIWMB for adopting Strategic Directive #5 on Producer Responsibility.  Our jurisdiction simply cannot afford to manage the proper recycling of U-wastes and Paint and we believe large quantities of those materials continue to be disposed in California landfills in spite of the disposal ban.
 
Regarding the Report, we believe the framework developed to evaluate End of Life product management systems is a useful tool to allow for discussion and evaluation of EOL management systems.  Having EOL systems broken into the eight elements made understanding and comparing different product management systems easier and should provide a common "language" for discussion of EOL systems as California considers these issues.
 
R egarding the contractor recommend ed elements, we agree with the contractor that the place to start any discussion with producers and others is with the recommended options of m andatory systems where the producers incorporate the fee into the price of the product, design and manage their own collection and recycling systems, and government oversees the funds and the collection to ensure transparency and accountability.   Using the case study findings, the recommended framework should be where the CIWMB starts any discussions and vary from it only after carefully considering that framework first. 
 
NOTE in separate paragraph any specific jurisdictional policies that support EPR or the state in taking action to support EPR.  Also note any data on costs to manage demonstrating the jurisdiction's inability to manage them with taxes or local tipping fees.
 
Sign-off:
 
 
 

Gary Liss       
916-652-7850    
Fax: 916-652-0485
www.garyliss.com