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Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics

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Natural Resources Defense Council (NRDC) filed 1 comment on this docket between Feb 6, 2024 and Feb 6, 2024. 63 other organizations filed here. The comment window closed 906d ago.

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Feb 6, 2024· Comment submitted by Natural Resources Defense Council (NRDC)· EPA-HQ-OLEM-2022-0415-0134

Re: Docket ID No. EPA–HQ–OLEM–2022–0415 – NRDC Comments on Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics Dear Director Hoskinson and staff, NRDC (Natural Resources Defense Council) respectfully submits these comments in response to EPA's request, Docket ID No. EPA-HQ-OLEM-2022-0415 Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics. We appreciate the opportunity to provide recommendations on ways that Environmental Protection Agency (EPA), U.S. Department of Agriculture (USDA), Food and Drug Administration (FDA), and other agencies can prevent food waste, redistribute surplus food, and recycle food scraps. NRDC works to safeguard the Earth – its people, its plants, its animals, and the natural systems on which life depends – including addressing the environmental harms of managing waste. We particularly focus on wasted food – an often-ignored resource. Since 2015, NRDC has worked with more than twenty municipalities to implement cross-cutting food waste reduction strategies and in states like New York and California on their organic waste policies. Through our work, we have seen the economic and political challenges to improving and expanding food scrap recycling and waste prevention. Drawing from these experiences, we provide the following comments. We congratulate EPA, USDA, and FDA on your work to support and invest in food waste reduction activities across numerous offices and programs. It is exciting to see this list of actions that are being proposed or already undertaken and we offer these comments to help strengthen the effort. Overarching Feedback: • Reporting progress: It is great to see a focus on measurement across the strategy, but it is unclear how often reporting will happen. We would like to see frequent public reports on progress and suggest that government entities and agencies should be required to measure and annually report on their progress on actions outlined in the strategy. • Lead by example: Federal agencies and facilities have an incredible opportunity to take the lead on implementing food waste reduction measures and send a clear signal. For example, federal facilities should measure, prevent, and recycle organic waste, donate surplus food, and purchase finished compost products. We suggest you include specific commitments to lead by example within federal agencies to the National Strategy. • Create a whole-of-government strategy: Many federal agencies engage in food service, and some in particular manage significant amounts of food and could make a big impact on food waste reduction, like the Department of Education and Department of Defense. Efforts should be made to include these agencies in the Federal Interagency Collaboration to Reduce Food Loss and Waste and to incorporate their commitments into the National Strategy. • Prioritize actions: With limited funding and staff time within the federal government, we suggest this strategy should outline what specific metrics will be used to assess and help prioritize the many commitments laid out in this plan to make sure that we are focusing on the most effective actions to achieve our national goal and ensure that funding is allocated proportionally. • Establish incentives under existing grants for applicants to develop and implement food waste plans: Agencies should require grant applicants to develop food waste reduction plans to receive grant funding or should offer bonus points to grant applicants that include food waste reduction plans. Please see the attachment for a more detailed description of these points as well as additional recommendations for each objective. Overall, we appreciate the work that went into creating this strategy and are glad to see the agencies taking necessary steps to achieve our national goal. We hope you will take these recommendations into consideration as you work to produ…

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Abstract

The Environmental Protection Agency (EPA), U.S. Department of Agriculture (USDA) and Food and Drug Administration (FDA) have developed the Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics (“draft Strategy”) to help prevent the loss and waste of food, where possible, and increase recycling of food and other organic materials. The draft Strategy identifies concrete steps, and complementary EPA, USDA, and FDA actions, that will help accelerate the prevention of food loss and waste, where possible, and recycling of the remainder with other organic waste, across the entire supply chain. The actions detailed in this draft Strategy will help the U.S. meet its National Food Loss and Waste Reduction Goal to halve food loss and waste; contribute to reaching the National Recycling Goal to achieve a 50 percent recycling rate by 2030; and contribute to global achievement of the United Nations Sustainable Development Goal Target 12.3. Preventing food loss and waste and recycling food and other organic waste will also reduce landfill methane emissions, in support of the U.S. Methane Emissions Reduction Action Plan, which identified food waste prevention and organic waste diversion as the top two methane emissions reduction strategies for municipal solid waste.

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