March 24, 2000

Wendy Mann
Concession Program Manager
National Park Service
1849 C Street, N.W.
Washington, DC 20240

RE: The Society of the Plastics Industry, Inc. (SPI) Comments:
February 23, 2000 Federal Register Notice - 65 Fed. Reg. 9060 - Solicitation of Public Comments on Exhibits to Proposed National Park Service (NPS) Standard Language Concession Contracts and Amended Proposed Environmental Protection Provisions

Dear Ms. Mann:

SPI 1 appreciates the opportunity to submit comments on the NPS Proposed Standard Language Concession Contracts and Amended Proposed Environmental Protection Provisions. SPI understands the relevance of NPS' efforts to prescribe the use of "products [that] have the least impact on the environment." 2 SPI believes, however, that the proposal does not take into consideration many of polystyrene and plastic products' attributes that indicate their environmental preferability.

SPI believes that the NPS should adhere to EPA's Final Guidance on Environmentally Preferable Products ("Guidance"). 3 Central to this Guidance are a set of guiding principles designed to help agencies, such as the Department of the Interior, identify and purchase environmentally preferable products and services. In particular SPI would call to the NPS' attention three of these guiding principles: the life cycle perspective/multiple attributes principle, the comparison of environmental impacts principle, and the environment + price + performance = EPP principle.

The life cycle/multiple attributes principle states that "a product or service's environmental preferability is a function of multiple attributes from a life cycle perspective." 4 A product or service may have environmental impacts long before and after the Federal government purchases and uses it. The manufacture, use, distribution, and disposal of products can interact with the environment in a variety of ways. According to the Guidance, Federal agencies should strive to purchase products or services with as few negative environmental impacts in as many life cycle stages as possible. In other words, Federal agencies should determine the "environmental preferability" of a product or service by comparing the severity of environmental damage it may cause throughout its life cycle with that caused by competing products-from the point of raw materials acquisition, product manufacturing, packaging, and transportation to its use and ultimate disposal. By doing so, the Federal government can minimize the overall environmental impacts of the products and services it purchases. In addition, by actively seeking and considering life cycle information to inform buying decisions, Executive agency personnel can send a clear signal that government business will go to those who consider the effect of their product's life cycle on the environment.

SPI supports the American Plastics Council's and Pactiv Corporation's comments regarding the consideration of the life cycle attributes of polystyrene products. Reiterating these comments, polystyrene products:

• Contribute less air emissions, waterborne wastes, and consume less energy --during manufacture-- than coated, bleached paperboard products
• Are not made with CFCs
• Are filling up only a small percentage of landfills and can be recycled

The comparison of environmental impacts principle states that determining environmental preferability might involve comparing environmental impacts. According to the Guidance, "in comparing environmental impacts, Federal agencies should consider: the reversibility and geographic scale of the environmental impacts, the degree of difference among competing products or services, and the overriding importance of protecting human health." 5 In determining environmental preferability, Executive agency personnel might need to compare the various environmental impacts among competing products or services.

Again, SPI supports the American Plastics Council comments regarding the environmental impact of polystyrene products through reduction of wastes and source reduction.

The Environment + Price + Performance = EPP principle means that procurement decisions should not be made on the basis of environmental considerations alone. Price and product performance should also be key factors in purchasing decisions. In this context, polystyrene products compare favorably to competing materials.

SPI appreciates the opportunity to submit these comments as part of the development of exhibits to the proposed standard language concession contract and amended proposed environmental protection provisions. SPI remains available to discuss these comments and to respond to any questions you may have on these issues. Please do not hesitate to call if you require any additional documentation or if we can be of assistance in any way.

Respectfully submitted,

Lewis R. Freeman, Jr.
Vice President, Government Affairs

FOOTNOTES

1. SPI is the trade association representing the fourth-largest manufacturing industry in the United States. SPI's 1,700 members represent the entire plastics industry supply chain, including processors, machinery and equipment manufacturers and raw material suppliers. The U.S. plastics industry employs 1.3 million workers and provides $274 billion in annual shipments. Founded in 1937, SPI is the voice of the plastics industry.

2. 64 Fed. Reg 9073 (Feb. 23, 2000)

3. 65 Fed. Reg. 45810 (Aug. 30 1999)

4. 64 Fed. Reg. 45819 (Aug. 30, 1999)

5. 64 Fed. Reg. 45821 (Aug. 30, 1999)

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