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[GreenYes] [CRRA] product collection systems: let a hundred flowers bloom

CRRA and CPSC Leaders:

I agree with the concerns and opportunities raised by Dan Knapp and Neil Seldman.  EPR advocates need to make room (at least during the transition from our current system) for multiple approaches to solving our resource management problem.  Setting up municipal programs does NOT let producers off the hook, as we know that municipal programs for toxics generally only collect 1-10% of the materials that are out there.  EPR programs will still be needed to get the majority (hopefully) of the materials and products.  We can also use the real data from municipal programs to make the case why EPR is needed.  Not everyone needs to implement municipal programs to make that case, so those that are so inclined such not be vilified.  They should be asked to share their data (like San Luis Obispo has done to date in CPSC presentations) to help us all make the case for state and federal EPR programs that are needed.  That's how we'll work together to get to the Zero Waste future we all want.


Cc: annettepuskarich <annette.puskarich@no.address>,
To: Dan Knapp <dr.ore@no.address>
From: Neil Seldman <nseldman@no.address>
Date: Wed, 29 Aug 2007 18:48:19 -0400
Subject: Re: [CRRA] Re: product collection systems:  let a hundred flowers bloom

Dan, By insisting that brand manufacturers take back all their products and packages, local businesses will be denied their feedstock for production. This is a national view that destroys local economies---jobs, skills, small businesses and expanded tax base.
Computer refurbishing will be the first to go, if it is not strong enough by the time any mandatory take back measures are passed. This trend is already developing. How can we transcend the current national corporation controll over our economy if we set up laws that give them back precious raw materials. These companies will recycle but they will not refurbish, except for small show case programs. Large scale refurbishing at the local level cuts into OEM sales of new equipment.

I call this EPR run amok.

Neil Seldman

On Aug 29, 2007, at 3:58 PM, Dan Knapp wrote:

To Annette Puskarich: 

Your either-or/one-best-option approach to EPR is deeply troubling to me. 

As you have outlined it, governments have just two choices for collecting "products:"  "programs" and "manufacturer's responsibility."  You say that programs are the wrong approach and you no longer advocate for them.  Your advisor the Product Policy Institute famously calls such programs "welfare for wasting."  From this rhetoric I gather that you want government to stop supporting "programs" entirely, and "shift" to an approach that forces manufacturers to do the collection for all "products."

But any organization that collects substantial amounts of discarded material will need to have a "program" for the same products that PPI wants to flow exclusively to manufacturers, and not just to manufacturers but to a much smaller subset called "brand owners."  No collection system is 100% efficient, and a huge supply of stuff manufactured before EPR is already out there aging.  The result is that anyplace discard management happens is a good place to collect these materials, bringing us right back to "programs."  Even Urban Ore has such programs as working subsets of our overall materials handling protocol.  Any transfer station needs these facilities, procedures, and protocols, or the "products" will not be captured but will be wasted by landfilling or incineration.  Why should we who do this work have to feel guilty about it? 

 All the zero waste transfer stations Urban Ore designs now have designated spaces for these materials.  We call this part of the transfer station the "regulated materials area."   

Whenever I play out the PPI scenario for these materials in my head, what I see is a bunch of EPR commissars strongarming brand owners into setting up completely new collection systems for selected products while ignoring all the stuff that's already been manufactured because they have "shifted" from an inferior to a supposedly superior collection system.  At its wildest extreme, one PPI rep reduced it to a formula:  EPR + composting = zero waste.

If you were out in your front yard gardening and someone tossed an empty container onto your yard, wouldn't you pick it up?  Or would you, heeding a higher principle, leave it there as a rebuke to the manufacturer that made the damn thing?

I'd pick it up in a heartbeat.  I think you would, too.

So why does this have to be cast as an either/or situation?  What if there three or four alternative systems are needed instead of just two?  Why can't it be a both/and situation?  Why does one technology have to be put down, disrespected, and demonized in order for another to succeed?

Please understand that I support manufacturer's responsibility initiatives, and see them as essential parts of a very complex discard management system, a true ecology of commerce based on fully mining the discard supply rather than the wilderness.

On a lighter note, here's some good news for you:  a new zero-waste transfer facility is now up and running in Crescent City, California.  It was designed as a collaborative effort between the Del Norte Solid Waste Authority, Gary Liss Associates, Urban Ore Development Associates, and Winzler and Kelly, Engineers.  DNSWA owns the land and the Phase I site improvements, which includes an extensive regulated materials area.  Winzler and Kelly did the construction management.  At full buildout it will be a full 12 category zero waste transfer facility based primarily on source separation and variable disposal rates rather than mechanical mixing and separation.  Right now 9 acres are developed, with 5 to go.  On the five acre Phase 2 site will be a large reuse facility, and a postconsumer recycling facility.  The DNZWTS has been open two years and is working very well, according to Kevin Hendrick, Director.  I hope you'll go see it sometime, and enjoy the long beautiful drive getting there and back.

Dan Knapp
Urban Ore, Inc.
A Berkeley reuse and recycling business since 1980
On Aug 28, 2007, at 7:48 AM, annettepuskarich wrote:

While I work for a city that has an existing program, I would not
advocate for one today. If jurisdictions are really interested in
putting a stop to unfunded mandates, I believe our energies should be
put toward extended producer responsibility and product stewardship.

I suggest cities get involved with the California Product Stewardship
Council and put pressure upstream (on manufacturers). If jursidctions
continue to fund programs we are sending the mixed message that if
producers don't step up, government will take care of it. We are
undermining extended producer responsibility efforts. It is time to
resist new programs for items currently banned from landfills.

Manufacturers figured out how to get their products into the hands of
consumers and they can certainly figure out how to get products back
at the end of their life. Lets send a clear message that we want them
to do it. Upstream will be worth the effort.

1) California Product Stewardship Council

1) DTSC Take-It Back Program (get a local nongovernmental entity to

Annette Puskarich

e--- In crra_members@, judigregry@no.address wrote:
> From: Wes Thompson
> Sent: Thursday, August 23, 2007 1:43 PM
> To: crra_members@no.address
> Subject: curbside colletion of household batteries
> Good afternoon
> I am wondering if there are cities collecting household batteries
> with commingled recycling. There is a proposal to allow residents
to place
> their batteries in a ziplock bag and include that in curbside
collection and I
> am wondering about the feasibility of that. Upsides? Downsides of
> programs? Thoughts and comments will be greatly appreciated.
> ************************************** Get a sneak peek of the all-
new AOL at
> http://discover.

Neil Seldman
Institute for Local Self-Reliance
927 15th Street, 4th Floor
Washington, DC 20005
202 898 1610 X 210


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Fax: 916-652-0485

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