The WasteWatcher: The Staff Blog of Citizens Against Government Waste

CAGW to NPS: Show Me the Data

The WasteWatcher is the staff blog of Citizens Against Government Waste (CAGW) and the Council for Citizens Against Government Waste (CCAGW). For questions, contact blog@cagw.org.

Today, the House Appropriations Subcommittee on the Interior, Environment, and Related Agencies marked-up (read and amended) its fiscal year 2017 appropriations bill.

Section 121 of the bill reads: “None of the funds made available by this Act may be used by the Director of the National Park Service to implement, administer, or enforce Policy Memorandum 11–03 or to approve a request by a park superintendent to eliminate the sale in national parks of water in disposable, recyclable plastic bottles.”  Here’s why Citizens Against Government Waste (CAGW) supports the committee’s effort.

On December 14, 2011, the National Park Service (NPS) issued Policy Memorandum 11-03, which allowed the national parks to institute a ban on the sale of water contained in disposable plastic bottles.  In order to implement the ban, a park’s superintendent had to request approval from the NPS’s regional director.  The superintendent was required to analyze and address in writing 14 factors related to implementation of the ban, such as the amount of waste eliminated, the pros and cons of the ban to overall park operations, the availability and operational costs of water filling stations, safety considerations for visitors who may not carry enough water, and a “system for annual evaluation of the program, including public response, visitor satisfaction, buying behavior, public safety, and plastic collection rates.”

The rationale for the ban was environmental; it was posited as an opportunity to reduce the parks’ waste streams.  However, while the memorandum banned the sale of water in disposable plastic bottles, it did not ban other drinks, such as soda and fruit juices.

A July 2015 study conducted by University of Vermont Professor of Nutrition Rachel Johnson demonstrated there were reasons to be concerned about the ban.  After the sale of bottled water was banned at her university, there was a 33 percent increase in the consumption of other drinks such as soda and fruit juices.  Furthermore, there was an overall six percent increase in bottles being shipped to the university and entering the waste stream, even though 68 water fountains were retrofitted to accept reusable water bottles and the university launched an educational campaign encouraging the use of reusable bottles.

CAGW expressed its concerns about the ban in a December 1, 2015 and a March 11, 2016 op-ed in The Hill, as well as in its November 2015 WasteWatcher, “A Baffling Ban on Selling Bottled Water.”  On March 2, 2016, CAGW submitted a Freedom of Information Act (FOIA) request to Department of the Interior Secretary Sally Jewell seeking details on how the ban on the sale of disposable plastic water bottles had affected the reduction of disposable plastic waste in each of the participating national parks.  CAGW also asked for sales data on beverages sold just prior to the ban’s implementation and after the ban was put in place, as well as records related to recycling.

As of today, CAGW has received no annual analysis from any of the participating parks that would prove one way or the other whether the ban on bottled water is reducing plastic waste, even though the NPS’s memorandum required such an analysis.

Curiously, one document that CAGW did receive as a result of the FOIA request, was a copy of a May 5, 2016 NPS response letter to another organization’s FOIA request, number NPS-2014-00051, that asked for “records relating to the effects of any bottled water ban in any unit of the National Park System, including all records rating to any annual evaluations undertaken pursuant to Policy Memorandum 11-03.”  The NPS’s response letter to that FOIA request stated: “A Search of the Sustainable Practices Report database has found that those parks that have discontinued plastic water bottle sales do not separately report their recycling quantities based on type (plastic, glass, aluminum, paper, etc.)  As a result they do not have data available to conduct a post-ban analysis.”

Furthermore, after a December 8, 2015 hearing held by the Senate Committee on Energy and Natural Resources, a question for the record was submitted to NPS Director Jonathan Jarvis by Senator Joe Manchin III (D-W.Va.), asking: “Is the NPS tracking whether the bottled water sales ban is reducing waste significantly?” (See page 18 of PDF link.)

The NPS’s answer was released on February 26, 2016: “The National Park Service is exploring ways to quantify the waste stream reduction impacts that have resulted from the 2011 disposable water bottle reduction and recycling policy and plans to evaluate the cost and resources required to track this waste reduction.  A major challenge in capturing the data is that, typically, disposable plastic water bottles placed in recycling bins at the parks are comingled with other recyclable containers such as bottles and cans, making it labor intensive and difficult to measure reductions in visitor-generated plastic containers.  Additionally, there is currently no mechanism for monitoring the number of plastic water bottles placed into trash receptacles and not recycled.”

That statement clearly demonstrates the NPS had given very little thought to measuring the outcome of the bottled water ban; there were no metrics in place to quantify whether the ban would reduce waste.  It seems increasingly obvious this policy was probably less about the environment and more about political correctness stemming from an objection to selling bottled water at a profit.

The Subcommittee is correct in stopping this arbitrary ban on selling bottled water and CAGW looks forward to it being signed into law.

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