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

Just a minor correction to this interesting thread - EPA's consultant for its waste comp studies is Franklin Associates (, founded in 1974 by Bill & Marjorie Franklin, and based in Kansas.  The Franklin Institute ( is in Philadelphia & was founded by Ben Franklin in the late 1700s.  The latter has evolved into a great science museum and is worth a visit if you're in Philly.

And, a 2007 study showed that Colorado's recycling rate is actually around 20%, but as we all know, it all depends on what you count and don't count. I'm working here in CO and we need to recycle a LOT more. But it can be hard with many large institutions enjoying $12/T tip fees and high transport costs to recycle markets.  Fortunately, some of the big generators are doing just what you recommend Dan, and taking a close look at their waste streams via waste comp studies, to lay the groundwork for better diversion. 

Gracestone, Inc.
Boulder, CO
303.494.4934 vox/cell
303.494.4880 fax

Dan Knapp wrote:
Hello Jon:

At our regional transfer station I'm guessing that the proportion of "discarded packaging and whole products" is more like 30%.  As you probably know, "MSW" is an extremely slippery concept, thanks to a continuing pattern of conceptual errors made by the EPA and its hardwired advisor The Franklin Institute back more than three decades ago.  But Berkeley is a municipality that operates a regional discard management facility that draws from many other cities all around it, and our "MSW" does not resemble the profile you cite.  

PPI's numbers do, though.  Maybe you could enlighten us all on the discrepancy?  

Meanwhile, I continue to believe that there is no substitute to going to the landfills and transfer stations and actually looking at what's happening.  Whenever I've had an opportunity to do so, (including extensive tours of New Zealand and Australian facilities) the profile looks like Berkeley's.

Dan Knapp
Urban Ore, Inc.
On Apr 17, 2008, at 6:26 PM, J. Michael Huls wrote:

I believe that the zero waste program that several industries are implementing based on the 5Rs is very germane and appropriate for this discussion.  Refuse, return, reduce, reuse, and recycle.  These actions combine to reduce dependence on scientific dumping (landfill and incineration) as well as stopping the flow of matter that gets discarded and requires recycling. 
But I do want to mention that I really appreciate Dan and Mary for their leadership in the industry, and making their views known.  I have never made my admiration for them a secret. However, we all have roles to play, and I equally respect others, "even" PPI, for their concerted effort to stop the flow of matter that ends up needing to be recycled.  As we may know, 70% of our MSW today is likely composed of  "discarded packaging and whole products."

J. Michael Huls, REA

Huls Environmental Management, LLC 
P.O. Box 4519
Covina, CA 91723-4519 
(626) 332-7514 ext 26 ofc 
(213) 840-9279 (cell)                                                     (626) 332-7504 fax

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From: crra_members@no.address [mailto:crra_members@no.address] On Behalf Of Dan Knapp
Sent: Thursday, April 17, 2008 3:01 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:


Always a pleasure to read your analysis of the international movements and where they appear to be headed.  Surely the news fromCanberra 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:

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: [] On Behalf Of Dan Knapp
Sent: Wednesday, April 16, 2008 12:30 PM
To: Gary Liss
Cc: CRRA Listserve; GreenYes subscribers; zwia@no.addresscom;;;; p2@no.address;ZeroWasteCommunities@no.addresscom;; 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 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, Californiasince 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, 2008at 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 toshare your SWIRP story with others.

Want more information? Please contact Rebecca Wood at . Tell your family, friends, coworkers and neighbors about this special event and RSVPwith Vikki Zale via email at or via phone at (310) 822-2010.

Gary Liss
Fax: 916-652-0485
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