Existing Comprehensive Procurement Guideline Designations and Recovered Materials Advisory Notice Recommendations

Docket ID No. EPA-HQ-OLEM-2019-0589 The Center for Biological Diversity submits the following comments to the Existing Comprehensive Procurement Guideline Designations and Recovered Materials Advisory Notice Recommendations. The Center for Biological Diversity is a national, nonprofit conservation organization with more than 1.7 million members and online activists dedicated to the protection of endangered species and wild places. We believe the health and well-being of humans is intrinsically linked to the health and well-being of nature. Government procurement can have an enormous impact on water, soil, climate, biodiversity, and the health of ecosystems. The EPAs Comprehensive Procurement Guidelines have been valuable in converting recyclables into new products and stimulating markets by using governmental purchasing power. This work should continue and be strengthened, especially in light of our struggling economy caused by stock market volatility, closing of local businesses and high unemployment. By investing in the collection, processing, manufacturing and buying of recycled content products all processed and produced domestically we can support a new green economy. Buying recycled content products versus those made with virgin materials has numerous environmental benefits. It reduces the need for additional landfill disposal or incineration capacity and reduces air and water pollution during both disposal and production. Because recycled content products require fewer materials, prioritizing their use conserves land, reduces impacts on forests and other ecosystems, saves water and energy and decreases greenhouse gas emissions that contribute to global climate change. Topic 1: Designated Items Lists Must Be Expanded to Include Textiles, Additional Plastics and Waste Collection in Parks According to the EPA, in 2017, 11.2 million tons of textile waste ended up in landfills. Recycled content clothing and other textiles keeps waste out of landfills and reduces the use of land, water, energy and pesticides and other chemicals used to produce new fabrics. I recommend assessing and adding textiles including but not limited to uniforms, tablecloths, and flags to the lists of designated items. According to a 2018 National Geographic report, of the 8.3 billion metric tons of plastic that has been produced, 6.3 billion metric tons has become plastic waste. Of that, only 9% has been recycled. The vast majority79%is accumulating in landfills or sloughing off in the natural environment as litter. This enormous amount of waste pollutes the environment, accumulates in oceans and in the tissue of fish and other wild animals, and creates deadly choking and entanglement hazards for wildlife. The EPA should add the minimum recycled content requirement recommended by the Break Free from Plastic Pollution Prevention Act for plastic beverage containers -- 25% post-consumer recycled content from US sources by 2025 moving up to 80% by 2040 which would need to be verified by an independent party designated by the Administrator. In addition, the EPA should expand the plastic products included in the lists to include other food grade plastic like to-go containers, shrink wrap and plastic bags. Finally, I recommend adding recycled content trash and recycling bins to the Park and Recreation section as they are only listed in the office category. Topic 2: Recommendations for the Designated Items Must Include Life Cycle Analyses and Increased Accountability According to the EPA website minimum post-consumer content levels were not designated previously. It is important that baseline threshold metrics be established and publicly available, along with incremental improvement goals to stimulate continued success and track progress. The recycled content levels must be regularly reviewed with updated data and codified with clear ranges and targets to increase accountability in all procurement programs. Additionally, I recommend the EPA bu…