[GreenYes] Re: [ZWIA] RE: [CRRA]Zero Waste, EPR and Total Recycling

[Dan Knapp <dr.ore@no.address>]

Hi Tedd:

I'm certainly not asserting that performance like we see in parts of  
the Pacific West is common, not when the state Colorado, to cite just  
one example, is recycling at only 12%!  This number comes from  Lisa  
Skumatz at the NCRA recycling update three weeks ago.  And not when  
Vancouver, BC lost the battle over incineration years ago, and is now  
trying to fend off the incinerator vendors who want to sell them a  
second one.  Anyone who reads Waste News can get the annual recycling  
summary, which is quite dismal for most states.

Elsewhere I have also argued that recycling numbers have been  
corrupted by phoniness, the best but not only example being how ADC  
is given recycling credit in the State of California.

But some things really do work well, and you and Kevin Hendrick  
happen to have one of the finest examples of a source-separation  
materials recovery facility anywhere.  It's those successes, and the  
59% reduction in wasting (not disposal, please!) over 17 years as  
embodied in Berkeley's regional transfer station's actual weight- 
based numbers, that we should be using as our "north star."

PPI's reductionism is a problem, you seem to agree.  I applaud your  
effort to come up with a less damaging argument for EPR.

Dan Knapp'
Urban Ore, Inc.


On Apr 18, 2008, at 11:16 AM, Tedd Ward wrote:

> Dan and All:
>
>
>
>             As background, attached is an excerpt from the Del  
> Norte Zero Waste Plan (to which Urban Ore was a contributing  
> author), discussing the question ‘What is Zero Waste?’  Further  
> background information may be found at:
>
>
>
> http://www.grrn.org/zerowaste/zerowaste_faq.html
>
>
>
>             If you refer to the table in my attachment, you will  
> see that we have acknowledged that different groups will  
> necessarily have their own perspectives and approaches and benefits  
> from pursuing Zero Waste.   That is really OK, even necessary,  
> because we each have our roles to play.
>
>
>
> I want to briefly address some of the policy issues you raised in  
> your last post:
>
>
>
> EPR + Composting does not equal Zero Waste.
>
>
> I agree, this understanding of Zero Waste is far too simplistic.   
> As you know, when introducing new concepts, one has to start simple  
> and build on what the audience already understands.   But among  
> professionals, I believe this is at best only a partial understanding.
>
>
>
> “…existing recycling efforts and disposal bans aren’t reducing  
> total waste generation.”
> "In US, product waste far outstrips all other types".
>
>
> I think you raise some important issues regarding the continued use  
> of Franklin Institute / EPA generation numbers, their origins and  
> embedded assumptions.   While I really applaud the achievements of  
> communities where disposal has decreased, my perception is that is  
> sadly less common than you appear to be asserting.   Again, not  
> that the efforts of Urban Ore an other recovery-based businesses  
> have not made HUGE achievements which have inspired us all, but  
> that we need to continue to be open to reality checks.
>
>
>
> A related issue here is the choice of using a message of ‘failure’  
> related to product waste and EPR.  As mentioned, the primary  
> motivation for pursuing EPR at this time are the hazardous consumer  
> products which are being increasingly regulated, with local gov’t  
> presumed to step up to set up programs and educate our customers  
> for each newly identified hazardous waste.  Private businesses can  
> choose which items are adequately profitable to recover or recycle,  
> but local governments have not been given that choice.  Still it is  
> a choice we would like to assert as well.
>
> In order to get our constituents to see this situation as we  
> perceive it, we feel it is necessary to explain how local  
> governments by themselves can only afford to fail or have programs  
> which recover (or even properly handle) a small percentages of  
> these items.  The great danger here is that we fool ourselves into  
> believing that recovering less than 15% of hazardous (or really  
> any) materials is all that can be done, or that is adequate, or  
> that the environment is not suffering additional insult every day  
> under such a system.
>
> I for one feel that in order to effectively advocate for EPR  
> systems which at least have potential for 100% capture of hazardous  
> materials, we simply must tell everyone how badly the current  
> system is failing such an objective.    While the same message is  
> somewhat less applicable to the total quantity of materials being  
> disposed, it is still useful to provide historical context  
> regarding the increase in the proportion of manufactured products  
> within the materials being disposed, and the increasing trend for  
> those products to contain hazardous components.
>
> Within such a context, spending too much time celebrating the  
> successes of recycling and recovery based businesses like yours I  
> believe would distract from the advocacy of EPR as a way forward on  
> these toxic-product issues.   We do not want members of the  
> audience to believe that since recycling has been such a success,  
> recyclers will also be willing to take all our toxics and solve  
> that problem as well.  At least not without some advance recovery  
> fee.   Recyclers and local governments may ultimately be part of  
> the total solution, but the real missing players in the recovery  
> system are the product designers and brand owners.   That is the  
> message.   Without EPR we fail, further insulting our only planet.
>
>
>
> "We suggest that manufactured product discards be managed by  
> producers or their agents.  (italics mine).  Local governments  
> should focus limited resources on managing things that are grown --  
> (bolding mine) like yard trimmings and food scraps."
>
>
> The California Product Stewardship Council is working to support,  
> flesh out, and support legislation to implement the CIWMB’s adopted  
> EPR framework.  This is a dynamic situation.  The above quote was  
> an effort to communicate an evolution of the role of local  
> government in managing discards.   At present, there is little to  
> no involvement at all from product designers and brand owners in  
> the recovery of their products.  This is what we hope to change.   
> The quoted excerpt focuses attention on those burdens we would like  
> to shift back to their designers (while retaining reuse and  
> recovery of usable items and parts salvage).   It feels a long way  
> off, and we’ll see what it actually looks like when we get there.    
> In the meantime, if anyone can find any local government who has  
> achieved this state of affairs, please let me know.
>
>
>
>
>
> Again, I believe we each have a piece of the puzzle, different ways  
> to move towards Zero Waste which complement eachother, and  
> different desired benefits for moving in that direction.   Our  
> diversity of perspectives, approaches, and skills are and should be  
> viewed as assets. I welcome discussions aimed at improving our  
> collective vision for EPR in California, and I appreciate those who  
> share other perspectives and experiences.
>
>
>
>
>
> Finally, personally I would not be in this profession at all if it  
> were not for the phenomenal success of recovery and recycling  
> businesses and non-profits which dreamed big and showed us what was  
> possible.   Like you and yours, Dan.
>
>
>
>
>
> 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."
>
>
>
> From: crra_members@no.address  
> [mailto:crra_members@no.address] On Behalf Of Dan Knapp
> Sent: Thursday, April 17, 2008 4:01 PM
> To: tedd@no.address
> Cc: Gary Liss; CRRA Listserve; GreenYes subscribers;  
> zwia@no.address; sustainablebusiness@no.address;  
> ZWBusiness@no.address; p2tech@no.address; p2@no.address;  
> ZeroWasteCommunities@no.address; rebeccajanewood@no.address;  
> Chris Harris; Mary Lou Van Deventer; Mark Gorrell; Neil Seldman;  
> Maxine Narburgh; Gerry Gillespie; Carolyn Brooks; David Tam; arthur  
> boone; Paul Connett; Tania Levy; Rick Anthony; Anne Rabe; Bill  
> Sheehan; Jeffrey Morris; John Moore; Peter Holtzclaw
> Subject: Re: [ZWIA] RE: [CRRA]Zero Waste, EPR and Total Recycling
>
>
>
> Hello Tedd, and all who receive this response:
>
>
>
> I agree with you, Tedd, and thank you for a very thoughtful and  
> generous response.  Also, I now support and have always supported  
> EPR as well as ULS and source reduction in all its forms.  And Mal,  
> I'd love for all of us Zero Wasters to "just get along."  But my  
> complaint about the attack on recycling embedded in PPI's  
> argumentation is substantive and serious as I hope to show.
>
>
>
> I have spent many hours debating these issues both in public and in  
> private with representatives of PPI.  A couple of years ago, in a  
> NCRA public debate featuring Bill Sheehan and I,  Bill put up an  
> astonishing powerpoint slide that neatly summarized the problem.   
> Here's what it said:  EPR + composting = Zero Waste.  PPI and its  
> affiliates are still using this gross reductionism today.
>
>
>
> To anyone who works at a transfer station or landfill that is open  
> to the public, this formula does not match reality.  What happened  
> to all the stuff from the built environment, from 200 to 400 years'  
> worth in most communities?  It can never be affected by EPR, yet it  
> is the lion's share of stuff that's already produced and coming to  
> our transfer stations and landfills every day.  It's invisible in  
> PPI's reckoning, yet they say we can ignore it and still somehow  
> get to zero waste.
>
>
>
> Like you, Bill has told me in private that I should mute my  
> critique because after all, we are interested in the same goal.   
> Fine, I reply, just stop maligning me and all the other independent  
> recyclers on your way to proving your point.
>
>
>
> I actually thought I had made some progress with PPI until the NCRA  
> Update conference on April Fools Day, where I picked up a new  
> brochure from the California Product Stewardship Council.   The  
> last phrase on the foldout says "Developed with support from The  
> Product Policy Institute", and includes PPI's north star logo.   
> Whatever the beliefs of the CPSC, the brochure they are handing out  
> to the public is a rehash of pure and distilled PPI talking points,  
> which have remained remarkably consistent for the last several years.
>
>
>
> Here's a quote from the flyer:  "The simple fact is that existing  
> recycling efforts and disposal bans aren't reducing total waste  
> generation.  Despite our best efforts, we're losing the  
> battle."  (Elsewhere in other papers, Mr. Sheehan calls recycling a  
> "failure."  And how many EPR-istas have you heard mouthing the  
> slogans "Oh, recycling, that's so twentieth century" or "so end-of- 
> pipe."  For me, it's been a lot, way too many.  In game theory this  
> behavior is a zero-sum game, meaning one side can't win without the  
> other losing.
>
>
>
> I believe that PPI's conceptual error begins with its uncritical  
> acceptance of the Franklin Institute's catechismic principle that  
> everything becomes waste the moment it is discarded, regardless of  
> what happens to it next.  So all our attempts to reform the way we  
> think about discards -- calling them resources, for example, or  
> saying we dispose of them by conserving them -- is irrelevant.   
> "Waste generation" figures come not from transfer stations, not  
> from observing what is actually being dumped and either wasted or  
> conserved, but from Franklin Institute desktop studies of  
> production, read: "generation."  Everything else in the discard  
> supply is irrelevant, invisible, inconsequential, by definition if  
> not in fact.  This is sophistry.
>
>
>
> In Berkeley, according to Peter Holtzclaw, our most recent Refuse  
> Superintendant, we sent 225,000 tons to landfill in 1990.  At our  
> last Zero Waste Commission meeting Peter said that in a mere  
> seventeen years from 1990 that wasting tonnage had dropped to  
> 95,000 tons, close to a 60% reduction.  Doesn't this conflict with  
> PPI's ideology?  True, there are probably more discards now than in  
> 1990, but that has nothing to do with what is being wasted.  The  
> brute fact is that wasting numbers are down, way down, at  
> Berkeley's regional transfer station.  Alameda County has many  
> other jurisdictions that are achieving these kinds of numbers.  So  
> we're not losing the battle, we're winning!  We should be analyzing  
> the why of this, not repeating false and misleading slogans that  
> make us out to be failures, enablers, "an afterthought," whatever.
>
>
>
> When I told Rick Anthony of these wasting numbers in Berkeley he  
> said the same is true in the San Diego area.  I'm sure Oakland and  
> San Franscisco, among others, can show similar Zero Waste  
> progress.  Other parts of California aren't doing so well.  But  
> none of that variation means anything to PPI, which trumpets our  
> collective failure across the board.    (Mary Lou Van Deventer  
> points out that with the PPI's formulation, we could be reusing and  
> recycling everything discarded and still be losing the "waste  
> generation battle."  Does this make sense?)
>
>
>
> Other lowlites from the brochure:
>
>
>
> •  a pie chart showing "waste production is increasing" with 3/4 of  
> it colored mustard (products), and 1/4 colored green (food/yard).
>
>
>
> •  a bar chart showing "In US, product waste far outstrips all  
> other types".  The mustard bar is 174.9 million tons; the green bar  
> is 58 million tons.
>
>
>
> •  a bargraph headlined "Waste Production (in California) is  
> increasing..." in which recycling numbers and wasting numbers are  
> combined to form a procession of bars marching ever higher, leading  
> to the illogical but waste-friendly conclusion that wasting equals  
> recycling because both are just different forms of "waste  
> production."  Eh?
>
>
>
> •  a paragraph that says "We suggest that manufactured product  
> discards be managed by producers or their agents.  (italics mine).   
> Local governments should focus limited resources on managing things  
> that are grown -- (bolding mine) like yard trimmings and food scraps."
>
>
>
> The phrase "...or their agents" might mean recyclers, but who  
> knows?.  There's not a word in the whole flyer (printed expensively  
> with soy inks using wind power on 100% recycled oversized card  
> stock ) about resource recovery parks or the continuing need to  
> support them, too.  That would be the "existing recycling efforts  
> and disposal bans", which have failed, wouldn't it?  So why  
> shouldn't local governments conclude from this that they can safely  
> stop supporting their local discard management transfer facilities  
> and associated materials recovery businesses and convert them and  
> the land they are on to "higher" uses, like retail outlets for all  
> the imported goods we as American Patriots are supposed to be  
> consuming?
>
>
>
> Starting in 2007 in Berkeley we narrowly fought off an attempt to  
> rezone our entire transfer station complex for auto dealer use,  
> part of the City's plan to increase sales tax revenue to pay for  
> their employees' high salaries and huge retirement liabilities.  It  
> doesn't matter to the Planning Department that the 60% waste  
> reduction number comes from the efforts and hard, effective work of  
> six or eight enterprises based at or near the transfer station  
> complex .  It doesn't matter that it's hundreds of men and women  
> working in "green collar" jobs who are responsible for a big share  
> of this cut.
>
>
>
> Urban Ore's property was scheduled for similar upzoning; we and  
> other neighboring businesses fought like crazy and stopped it at  
> the Planning Commission level.  But new threats pop up all the  
> time, and the industrial land we need for expansion is being  
> nibbled to death as we speak.  PPI does not seem to think it has  
> any responsibility for this deplorable state of affairs, in its own  
> way as threatening to real Zero Waste as the more overtly hostile  
> actions of the Australian ACT government.  I believe I have shown  
> that their argument directly supports moves and threats like this.
>
>
>
> I did not pick this fight with PPI.  My purpose is to defend  
> homegrown reuse, recycling, and composting, and to celebrate its  
> successes.  I first began to notice the attack on recycling from  
> the EPR quarter about eight or ten years ago, but was too busy and  
> preoccupied with our business move to counter it then.  Now I'm  
> playing catchup, but I really, really would like the EPR-istas to  
> develop a more truthful and more realistic approach to zero waste  
> -- and EPR.   Tedd, maybe you or some others could help them.  I've  
> tried, to little effect so far as I can tell.
>
>
>
> Dan Knapp, Ph.D.
>
> Urban Ore, Inc.
>
>
>
> PS:  PPI is against banning, too, apparently.  But I don't want to  
> go back to styrofoam cups in Berkeley or elsewhere, do you?  And by  
> the way, who is paying for PPI to do this lobbying, anyway?
>
>
>
> On Apr 16, 2008, at 3:35 PM, Tedd Ward wrote:
>
>
>
>
> Dan:
>
>
>
> Always a pleasure to read your analysis of the international  
> movements and where they appear to be headed.  Surely the news from  
> Canberra is disappointing and I appreciate your perspectives on  
> those developments.
>
>
>
> I must, however, strongly disagree with the statement ‘Zero Waste  
> has also been commandeered as a brand by the Product Policy  
> Institute, among others, and they and others have tried to make  
> zero waste into a synonym for Extended Producer Responsibility…’
>
>
>
> I fully acknowledge that much of what is now referred to as ‘Zero  
> Waste’ (at least within the wonky jargoneers) developed out of your  
> years of good work on ‘Total Recycling,’ with the former term  
> coming into widespread use largely due to the efforts of entities  
> like GRRN, CRRA, ZWIA, and EcoCycle, followed by the CIWMB.   I  
> think if you refer to any of these sources, you will see that EPR  
> is just one aspect of the Zero Waste approach.
>
> If any confusion arises between EPR and ZW, I think it is because  
> ZW differs significantly from what has be termed ‘Integrated Waste  
> Management’ (IWM) by targeting ways the current resource-product- 
> discard system must change if the market system is to really reward  
> resource and energy efficiency.  I do not claim that your work on  
> ‘Total Recycling’ ignored these systemic issues, but I think some  
> people who are just learning about Zero Waste think something like   
> ZW = IWM + EPR.  This is not correct, just like ZW is not AB939 at  
> 100% diversion.  Both are incomplete understandings of the big  
> picture advocated under the term ‘Zero Waste’.
>
>             That said, I think there is no reason to slam PPI for  
> advocating EPR, or for their advocating EPR as part of a system  
> moving towards  Zero Waste.  That is what they do.  EPR is  
> complicated enough, and I for one would not criticize an advocate  
> of EPR (we need many more), for not going into adequate detail of  
> other non-EPR aspects of ZW or Total Recycling.   Similarly, I  
> would not blame Urban Ore for not covering the many ways the system  
> producing waste is subsidized (or the need for EPR) during a tour  
> of your impressive facilities and programs.   Nobody is completely  
> right or comprehensive all of the time, and there is no reason to  
> expect it.
>
> True, EPR actions in California for HHW products have some momentum  
> right now because local gov’ts are being asked to set up separate  
> financially unsustainable systems to handle hazardous products, and  
> agencies like ours simply cannot afford to capture more than 15% of  
> these streams.    So right now EPR has some urgency from the local  
> gov’t perspective for hazardous materials from the moment a product  
> or material is designated as hazardous or needing to be managed  
> separately from the organics stream.  Given that EPR is such a big  
> change from our current system, will likely have strong industry  
> opposition, and that it will take coordinated advocacy from local  
> gov’ts, I am not surprised that EPR has eclipsed all other ZW  
> actions for the moment for many.   In fact, I encourage all local  
> gov’t types reading this post to get involved with the important  
> work of the California Product Stewardship Council.  Check out:
>
>
>
> http://www.caproductstewardship.org/
>
>
>
> Similarly, policy wonks for EPR and ZW should continue to be  
> respectful (and acknowledge the continuing contributions) of all of  
> us in recovery ‘at the back end.’    We each have a piece of the  
> puzzle, and each piece is important.
>
>
>
> Yours in recovery,
>
>
>
> 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."
>
>
>
> From: crra_members@no.address  
> [mailto:crra_members@no.address] On Behalf Of Dan Knapp
> Sent: Wednesday, April 16, 2008 12:30 PM
> To: Gary Liss
> Cc: CRRA Listserve; GreenYes subscribers; zwia@no.address;  
> sustainablebusiness@no.address; ZWBusiness@no.address;  
> p2tech@no.address; p2@no.address;  
> ZeroWasteCommunities@no.address; rebeccajanewood@no.address;  
> Chris Harris; Mary Lou Van Deventer; Mark Gorrell; Neil Seldman;  
> Maxine Narburgh; Gerry Gillespie; Carolyn Brooks; David Tam; arthur  
> boone; Paul Connett; Tania Levy; Rick Anthony; Anne Rabe; Bill Sheehan
> Subject: [CRRA] Re: [GreenYes] Join us for LA Zero Waste Plan  
> Conference 5/3/08
>
>
>
> To All:
>
>
>
> As many of you know, the proximate source of inspiration that  
> launched the worldwide movement for zero waste in 1996 was the  
> Australian Capital Territory (ACT) government in Canberra,  
> Australia. Earlier efforts in the same direction had primarily  
> focused on total recycling, of which I was and still am a champion.
>
>
>
> Now those of you who are celebrating further successes in what I  
> recently called "zero waste goalism" would do well to understand  
> and acknowledge that zero waste goals mean less than nothing when  
> there is no will to make real zero waste happen. The proof is, once  
> again, Canberra Australia, which in mid-2007 opened its new $11  
> million landfill cell after using up the entire hillside landfill  
> site (supposed to be its last) that it called the Mugga Lane  
> landfill. Further proof: ACT NoWaste's attacks on Revolve, the  
> nonprofit landfill scavenger business that really invented the  
> Australian concept of zero waste; ACT's refusal to build the Zero  
> Waste Resource Recovery Park on land set aside in 1996 or 1997 for  
> the purpose with money made from their profits on wasting; ACT's  
> attempts to restrict competition for the discard supply so that  
> more waste, not less, goes into landfill; and ACT's tardy removal  
> of "no waste by 2010" from ACT NoWaste's publicity materials,  
> trucks, and logos. Until they removed the date in 2006 and 2007,  
> the zero waste goal functioned in Canberra as a cloak to hide their  
> waste-friendly actions. Now they've finally owned up to their  
> betrayal of the public's trust.
>
>
>
> So beware! I presented a ten-minute powerpoint on Canberra relying  
> on my site visit to Canberra in April of 2007 as well as on photos  
> and correspondence from Gerry Gillespie and Carolyn Brooks at the  
> annual Recycling Update conference in Oakland, CA sponsored by the  
> Northern California Recycling Association. It was immediately  
> labeled a "cautionary tale" by Tom Padia of StopWaste.org and  
> others in the audience of 170 recycling professionals.
>
>
>
> Zero Waste has also been commandeered as a brand by the Product  
> Policy Institute, among others, and they and others have tried to  
> make zero waste into a synonym for Extended Producer  
> Responsibility. This is no less false and misleading than  
> Canberra's brand of sophistry, in my opinion, because it dismisses  
> honest hardworking recyclers dealing everyday with the gazillions  
> of tons of discarded materials flowing from the built environment  
> to landfill and transfer stations that have already been  
> manufactured and therefore can never be affected by EPR.
>
>
>
> I see EPR as an important part of source reduction (the "reduce"  
> part of "reduce, reuse, recycle" imperative), but only a part. When  
> you look closely at what EPR-istas concentrate on, it is mostly low- 
> tonnage but important stuff like household toxics, pharmaceuticals,  
> and the like. All well and good, and more power to them, but let's  
> not forget other potent source reduction tools like ULS (Use Less  
> Stuff), the focus of Annie Leonard's popular new video.
>
>
>
> And let's support total recycling in source-separation-based 12  
> category resource recovery parks and celebrate them when, against  
> long odds, they somehow or other get built and occupied by real  
> recyclers producing quality feedstocks.
>
>
>
> The other two legs of the 3R tripod should not be subject to  
> insults like "so twentieth century" and "so end-of-pipe", but they  
> are thanks to EPR zealots.
>
>
>
> Dan Knapp, CEO
>
> Urban Ore, Inc., a reuse and recycling business in Berkeley,  
> California since 1980
>
>
>
>
>
> On Apr 11, 2008, at 11:25 AM, Gary Liss wrote:
>
>
>
>
>
> Apologies for Cross-postings & please forward to colleagues who may  
> be interested
> The 3rd Citywide Conference for the Los Angeles Zero Waste Plan is  
> Here!
>
> Please join us for the 3rd Citywide Conference for the Zero waste  
> Plan. This will be the final conference for Phase 1 of the project  
> and will be a celebration of all of the hard work and input  
> provided by you, the stakeholders, for the Zero Waste Plan thus  
> far! The conference will be on May 3, 2008 at the Cathedral of Our  
> Lady of Angels conference center from 8:30 am to 1:00 pm. The  
> Cathedral is located at 555 W. Temple Street in downtown Los  
> Angeles.. All conference attendees will receive complimentary parking.
>
> Don't forget! We will also be having a Zero Waste Film Festival  
> from 7:30-8:30 am along with a complimentary continental breakfast.  
> A complimentary lunch will be served later in the day.
>
> This is the chance for you to sign off on the Guiding Principles  
> for the plan, join your fellow stakeholders in celebration for the  
> first year being completed and for you to share your SWIRP story  
> with others.
>
> Want more information? Please contact Rebecca Wood at  
> rebeccajanewood@no.address . Tell your family, friends, coworkers  
> and neighbors about this special event and RSVP with Vikki Zale via  
> email at vikkizale@no.address or via phone at (310) 822-2010.
>
>
>
>
> Gary Liss
> 916-652-7850
> Fax: 916-652-0485
> www.garyliss.com
> >
>
>
>
>
>
>
>
>
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> Yahoo! Groups
>
> w/ John McEnroe
>
> Join the All-Bran
>
> Day 10 Club.
>
> .
>
>
> __,_._,___
>
> <What Is Zero Waste.doc>