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Wednesday, March 19, 2008


March 19, 2008

Members of the Monterey Regional Waste Management Board
Monterey Regional Waste Management District
14201 Del Monte Boulevard
P.O. Box 1670
Marina, California 93933-1670


Dear Honorable Board Members:

With the understanding that an ordinance aimed at banning the use of expanded polystyrene foam (EPS) take-out food containers for food vendors throughout Monterey County is under consideration by MRWMD Board Members, our broad coalition of environmental and community organizations is pleased to provide the following comments.

We would first like to thank the MRWMD for considering a potential ordinance on this pressing environmental issue. Plastics represent sixty to eighty percent of all marine debris, ninety percent of floating marine debris and have been well-documented as a huge and ever-growing problem in the environment. While it is recognized that EPS is economical and convenient for food service industries, the inherent non-biodegradable nature and chemical composition of this product raises serious concerns. Polystyrene foam, a form of air blown plastic, is particularly pernicious because:

- Though the containers are designed to be useful for a few minutes in the transporting of food and drink, they persist for hundreds and possibly thousands of years- an unconscionable material dissonance when biodegradable and compostable alternatives are readily available. The short-term economic benefits do not compare to the long-term economic and environmental costs.

- Polystyrene foam is a non-renewable petroleum by-product, composed of the chemicals styrene and benzene. Benzene is classified as a human carcinogen. Styrene is a neurotoxin and also considered a “suspected carcinogen” by the US EPA; heat and food acids induce migration of styrene monomers from the vessel into the food and drink.

- Small, ubiquitous and persistent, EPS debris closely resembles the food of many species- the growing compendium of data and photographs are just beginning to tell the unfortunate story: countless marine animals, birds and fish ingest the pieces and suffer from starvation and poisoning.

- No meaningful recycling of EPS currently occurs in Monterey County; no facility accepts food-stained EPS for reuse or recycling

- Polystyrene foam is very lightweight and easily breaks up into smaller pieces, and thus presents a major litter problem for our county parks, streets and beaches

- According to the California Integrated Waste Management Board, “In the categories of energy consumption, greenhouse gas effect, and total environmental effect, EPS’s environmental impacts were second highest, behind aluminum.” Aluminum, at least, is easily and commonly recycled.

The most recent Surfrider Foundation Monterey Chapter/Carmel Middle School classes’ beach cleanups, January 30-31st at Del Monte Beach in Monterey found the following items:

Bags: 34
Balloons, ribbons: 6
Beverage Containers: 28
Caps, Lids: 99
Cigarette Butts: 233
Clothing, shoes: 37
Disposable food containers and utensils: 31
Fishing nets, lines, rope: 36
Styrofoam (majority)/plastic pieces, broken up: 1012

By volume, clearly the broken up pieces of EPS present the largest litter nuisance. It is the very fact that EPS breaks apart so easily that makes it so difficult to contain and control.

We encourage the effort necessary to implement a practical ordinance that will help stop the threat to our oceans and marine animals and the unnecessary litter of our beaches and neighborhoods due to tossed and blown polystyrene containers, manufactured and used specifically as single-use, throw-away items, primarily in the food-service industry.

Moreover, we are supportive of the regional approach since such restrictive ordinances are most fair, practical and effective if enacted and enforced throughout all jurisdictions in the county area. As litter has no natural boundaries it is desirable and prudent for all jurisdictions in a given region to follow the same plan regarding such product-specific waste management practices.

As you are aware, there is an ever-growing public interest in mandatory restrictions to control and regulate the widespread use of polystyrene and other types of throw-away plastic products so highly-visible in our society. Such local efforts abound throughout California, with ordinances passed in over 100 cities and counties, from Sonoma County to Orange County, and locally, in the cities of Santa Cruz and Capitola and, soon, Santa Cruz County. The fact is that a very large segment of the coastal and regional population is strongly in favor of such bans and expects local jurisdictions to take positive action in accordance with the expressed public will.

Many of our undersigned organizations have been heavily involved in community advocacy regarding this issue, and so continue to hear from untold numbers of the public as well as from our direct membership regarding their desire for and support of such bans of polystyrene containers and also plastic throw-away bags. We have provided educational materials regarding the effects of polystyrene in the environment to thousands of area residents at community public meetings, workshops, tabling at various sites, and at our frequent beach cleanups. We have also reached out to the businesses which are most affected by the ordinance, food vendors, with information on alternatives.

Our educational efforts have also included communication on this issue with numerous local elected and appointed bodies, city and county staff, and elected officials, both in writing and in person. Thus, we perceive a clear trend evident around Monterey Bay which coincides with the obvious trend throughout many California jurisdictions. We believe the public wants to take action on this matter, and we therefore confidently assert that such a county-wide effort will be both appreciated by county residents and actively supported.

Our strong environmental coalition wishes you success in this project, and we compliment your decision to explore proactive measures to protect our fragile marine environment, conserve limited resources, and reduce unnecessary amounts of highly-durable polystyrene plastic foam in our local waste stream. As this process moves forward, our organizations will be happy to assist you with comments or letters of support as appropriate. Please feel free to contact us if we may be of assistance. At this juncture, we urge you to approve the template ordinance at your meeting on March 21, 2008 so that it can be forwarded on to local governments for their timely consideration.

Thank you,

The Surfrider Foundation, Monterey Chapter, Tony Tersol
The Surfrider Foundation, Santa Cruz Chapter, Dustin MacDonald
Oceana, Santi Roberts
Defenders of Wildlife, Jim Curland
Save Our Shores, Laura Kasa
Sierra Club, Ventana Chapter, Rita Dalessio
Monterey Coastkeeper, Steve Shimek
Save the Waves Coalition, Dean LaTourrette
Aquatic Protection Agency, Eric Russell
Surfer’s Environmental Alliance, Andrew Mencinsky
Ocean Revolution, Dr. Wallace J Nichols
The Otter Project, Steve Shimek
Citizens for a Sustainable Monterey County, Denyse Frischmuth
Monterey Green Action, Megan Tolbert
Sustainable Carmel Valley, Mibs McCarthy
Sustainable Pacific Grove, Joy Colangelo
Big Sur Powerdown, Linda Parker
MERGe- Marina Moss Environmental Response Group, Dane Holland

Cc: Litter Abatement Task Force

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