Bay Area Water Policy Proposes Product Bans as “Credit” Toward Trash Load Compliance Goals
The San Francisco Bay Regional Water Quality Control Board is currently accepting public comments on a report by the Bay Area Storm water Management Agencies Association (BASMAA) concerning Baseline Trash Loads and Trash Load Reduction Tracking Methods.
These documents are intended to be a blueprint for how local jurisdictions will meet a required 40% reduction of “trash” that is found in creeks, roadsides and local waterways by 2014. Incredibly, BASMAA has suggested that “credits” for banning specific food service products be used to help meet the reduction goals. If adopted, this proposal could have sweeping long-term ramifications for a host of manufacturing, retail businesses, local restaurants and food trucks.
In addition to credits for banning these products, the report further proposes even greater credits be issued to jurisdictions that ban and/or adopt a mandatory fee for ALL single-use food and beverage products; OR adopt policies that require vendors to provide a discount for “Bring your Own” service ware (knives, forks, spoons) or charge a fee on those products.
Bans on arbitrarily specified products so localities can “claim” trash reduction credits -- without implementing demonstrated measurable trash reduction programs -- sets a dangerous precedent for any consumer product manufacturer, restaurant operator, or retailer doing business in California. Product bans can result in higher operating costs for businesses, which can mean higher costs for consumers and lost of jobs – all without any demonstrated impact on reducing overall trash in local creeks and waterways.
Edwin Lombard Management, LLC (ELM), is in the process of developing detailed comments and will be circulating a draft in the coming days. These comments are due March 20, 2012. ELM encourages you to file comments on behalf of your organization, opposing the “credits” proposed for product bans, so localities can “claim” trash reduction credits -- without implementing demonstrated measurable trash reduction programs. Please send all comments to firstname.lastname@example.org with the words “Trash Plans” in the subject line.
If you have any questions, please contact Edwin Lombard at 916-524-8070 or via email at email@example.com .
Edwin A. Lombard III