Bay Area Stormwater Managment Agencies Association – Baseline Trash Load Comments due March 20, 2012

The San Francisco Bay Regional Water Quality Control Board is currently accepting public comments on a report by the Bay Area Stormwater Management Agencies Association (BASMAA) concerning Baseline Trash Loads (Generation Rates) and Trash Load Reduction Tracking Methods

In short, these documents are intended to be a blueprint for how local jurisdictions will meet a required 40% reduction by 2014 of trash that is deposited as litter in creeks, roadsides and local waterways.   BASMAA has suggested that “credits” for banning specific products be used to help meet the reduction goals.  If adopted, this proposal could have long-term ramifications for a host of manufacturing and retail businesses.

In addition to credits for banning single use plastic bags and polystyrene foam foodservice 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 or charge a fee on those products.   

Bans on arbitrarily specified products without implementing  measurements for trash reduction for these specific products 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 – all without any demonstrated impact on reducing overall trash in local creeks and waterways.

The American Chemistry Council (ACC), on behalf of its food service packaging members, 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.

ACC encourages you to file comments opposing the “credits” proposed for product bans, or to file comments on behalf of your organization supporting ACC’s comments.  Please send all comments to dbowyer@waterboards.ca.gov with the words “Trash Plans” in the subject line.

BASMAA Draft Sample Coalition Letter March 2012