l The April 10 [Page 14] Perspective, ``APC walks political tightrope,'' concludes that the American Plastics Council shouldn't get too involved in helping calculate recycling rates in states with plastics recycling mandates. From my experience in Oregon, I find this conclusion off base. I chaired a state task force to determine how to calculate the rigid plastic container recycling rate. I also served on a technical advisory panel that advised the consultant hired to undertake the rate study. In both cases I found the advice and research undertaken by APC staff and member companies to be invaluable in Oregon's effort to calculate a defensible and accurate recycling rate.
Jerry Powell
Resource Recycling
Portland, Ore.
Reader explaing Clif., Ore. Laws
It has come to my attention that some manufacturers of recycled plastic packaging films are skewing the California and Oregon plastics recycling regulations story for their own commercial benefit. At a time when the plastics industry should be working together to combat irresponsible regulations, the misinformation being disseminated is divisive.
On behalf of responsible film manufacturers, I would like to clarify the complicated existing regulations for your readers, as I see it.
California regulations state that all reclosable packages having a volume in excess of 8 ounces must either have a 25 percent post-consumer recycled content or a reduction of total package weight by 10 percent relative to a base-year package weight. There are three options to meet these regulations: create a nonreclosable seal; reduce the total package weight by 10 percent as compared to the base-year package weight; or use 25 percent post-consumer-content film in the package. (Post-consumer content includes buy-back from thermoformers and is readily available.)
Oregon regulations state that packages must contain 25 percent recycled content; however, this law applies only if 25 percent of all plastics packaging in aggregate is not recycled in Oregon. Oregon recycling efforts have gone well, and it is fully expected that plastics recycling in Oregon will exceed the regulation threshold, and thereby render compliance unnecessary in 1995.
In the interest of fairness to all, I believe it is important to be entirely truthful with your readers. It is my hope this information will clarify the situation.
Harry J.G. van Beek
Klockner Pentaplast of America
Gordonsville, Va.
APC rebuts article on Calif. recycling
Plastics News has unnecessarily attempted to create a nonexistent controversy.
The American Plastics Council volunteered to work with the California Integrated Waste Management Board as the latter conducted a plastics recycling rate study for California. The article [``APC retracts offer to help California,'' April 3, Page 1] failed to point out that APC was under no obligation, nor any expectation, to assist in such an expensive and resource-consuming activity. Rather, APC agreed with the CIWMB that it was in everyone's best interest - and that the most accurate rate determination would occur - if a thorough and methodologically correct survey were conducted and if APC's extensive background in recycling activities were incorporated. While a CIWMB-proposed change in the method of managing the study led APC to conclude that its financial underwriting of the exercise was no longer justifiable, APC has volunteered to continue to work with the CIWMB and supply them with information as APC pursues an independent study. CIWMB has stated that it welcomes such assistance and input.
Plastics News' headline infers negative actions on the part of APC, overlooking the somewhat unique offer of a private entity to fully fund a legislatively mandated action of a state agency.
The article began with an unattributed assertion that the ``plastics industry seems likely to fall way short of California's target for recycling plastics packaging.'' This appears to be an unfounded and unsubstantiated statement within a ``news'' story. Is this the opinion of Plastics News? If so, on what information is this based? Until a methodology is selected and some research undertaken, it is difficult to understand how a credible estimate could be created relating to the ``likely'' plastics recycling rate.
Red Cavaney
American Plastics Council
Washington
Editors note: The assertion about California's recycling rate was attributed to William G. Huston, the official charged with implementing the state's plastics recycling law.
R.W. Beck assures objectivity of work
Plastics News recently made what we would consider an off-the-cuff comment that questions the objectivity and professionalism of R.W. Beck's work, particularly with regards to developing state and national recycling rates.
Your article dated April 3 [Page 1] in some ways infers that our firm would produce results favorable to the American Plastics Council if selected to perform a rigid plastic container recycling rate study for California. Based on our discussions with Californians Against Waste, which the article claims made the remark, it is clear to us that no such comment was either explicitly stated or implied. In fact, during our discussions with CAW, they encouraged Beck to bid on the project due to our nationally recognized expertise in determining state and national recycling rates for all packaging materials.
Was it not R.W. Beck that worked with the Association of Postconsumer Plastics Recyclers and APC to facilitate a review of the national recycling rate figures? And, wasn't it Plastics News that recently gave our national recycling rate effort an ``A'' on your recycling report card -particularly for making the national rate study more of a cooperative effort?
Regardless of the group financing the work, R.W. Beck has and will continue to produce objective and credible work using the most accurate methodology available. R.W. Beck may eventually be selected to perform the California work - not due to our relationship with the APC or APR - but because we are the most qualified firm bidding on the project.
Jonathan J. Burgiel
R.W. Beck & Associates
Orlando, Fla.
Calif. recycling story gave false impression
I am writing in regard to your front page article from April 3 about the plastics recycling rate in California. I believe you did a disservice to the process taking place in California to determine a plastic recycling rate and the American Plastics Council.
You claim that the plastics industry is unlikely to meet the mandated rate, but you later include a quote from APC's Roger Bernstein that ``It's premature for anyone who hasn't embarked on any rate analysis to ascertain what that rate is.'' You should have listened to his advice. No one knows today how that rate determination will come out. However, having read Plastics News, I'm sure many people will come away with the false impression that the rate is a done deal. Let's wait and see what the actual process produces.
Additionally, the negative impression I got from reading your article about APC's work on this issue is very different from this reality I have experienced first-hand. APC has been doing a yeoman's job in working with California processors and the state regulators to help determine a plastics recycling rate. They have gone beyond the call of duty to assist the state of California in getting a legitimate and usable rate methodology estab-lished.
While the funding will now have to come from the state's taxpayers, APC has proven its willingness to continue to work with all concerned so that California processors and the entire plastics industry are judged by accurate and reliable data.
Regrettably, the California Integrated Waste Management Board has not worked as judiciously. Rather, they have not been responsive to the plastics industry nor the voters of the state. Here was a chance to have an accurate calculation, while at the same time saving the taxpayers' money, through incorporating the private sector's participation and expertise. Un-fortunately, their rejection of this excellent opportunity is not reflected in your article.
Frank C. DeVore
Tri-Plas Inc.
Ontario, Calif.
