American Forest & Paper Association

Statement Submitted for the

Department of Environmental Protection

Florida’s 75 Percent Recycling Goal

December 2, 2008

The American Forest & Paper Association (AF&PA) appreciates the opportunity to comment on Florida’s new 75 percent recycling goal and strategies for reaching it.

AF&PA is the national trade association of the forest, pulp, paper, paperboard, and wood products industry. We represent 175 companies and related associations focused on producing essential products for people from renewable and recyclable resources that sustain the environment. The forest products industry generates $200 billion a year in sales and employs more than one million people earning $54 billion in annual payroll. The industry is among the top 10 manufacturing sector employers in 48 states. In Florida our industry employs more than 32,000 people, owns and operates nearly 11 million acres of forestland, and manages more than 200 manufacturing facilities.

Thanks to industry leadership and tireless efforts of millions of Americans who recycle paper at home, work, and school every day, national paper recovery has reached record levels. In 2007, 56 percent of the paper consumed in the U.S. was recovered for recycling. Building on that success, the paper industry has set an aggressive 60 percent recovery goal for 2012. Getting there will not be easy, as each percentage point represents nearly one million additional tons of recovered paper - enough to fill more than 14,000 railroad cars.

According to the Department of Environmental Protection’s (DEP) Division of Waste Management, Florida paper recovery statistics are far lower than the national average. In 2006, only 1.8 percent of office paper and 7.2 percent of newspapers were recovered in Florida compared to the national average of 71.8 percent and 72.7 percent, respectively.

Availability of paper and paperboard recycling programs at the community level does not seem to be the issue. A national survey conducted by AF&PA in 2007 revealed that 82 percent of Florida residents have access to either drop-off or curbside paper recycling programs. Florida’s new recycling goal offers an opportunity to educate residents regarding the availability of recycling programs, the materials that can be recovered, and the importance of their participation.

While overall state recovery statistics are low, examples of outstanding paper recycling programs already exist within the state. In 2008, AF&PA, through it’s Recycling Awards program, recognized two outstanding programs in Florida that promote the recovery of high quality paper for recycling.. Brevard County, FL, received the AF&PA Community Recycling Award as a result of a variety of creative programs including location partnerships, contests, and presentations reaching more than 10,000 residents annually and collecting 33,341 tons of paper for recycling in 2006. The AF&PA School-Wide Recycling Award went to Pasco County, FL, where the District School Board of Pasco County works in creative ways with students, teachers, and administrators at the county's 76 schools to promote and measure recycling success. In 2007, Pasco County schools collected 1,267 tons of paper products for recycling, helping the county save more than $135,000 in solid waste disposal costs.

Programs like those already in place in Brevard County and Pasco County are great examples of how public and private partnerships that employ creative outreach efforts can encourage and increase recycling. They are featured on AF&PA’s website, along with background information, interactive features, and statistics that may be of use in creating new recycling programs and opportunities.

AF&PA's goal is to ensure a continuing, expanding domestic recovered fiber supply to help meet global demand. Paper recycling reuses a renewable resource that sequesters carbon and helps reduce greenhouse gas emissions. Greenhouse gas reductions result from avoided methane emissions and reduce energy required for a number of paper products. In addition, recovering paper extends the fiber supply.

The challenge is to encourage increased participation without compromising the marketplace or unintentionally harming community collection programs. The paper industry strongly supports allowing market forces to dictate the ownership and use of recovered fiber.

We believe that government mandates are likely to hurt community collection programs and create considerable compliance and administrative costs both for the private sector and government. AF&PA opposes government-imposed fees on products and packaging, as well as recycled content mandates, as means to promote recycling and waste reduction. Such fees unnecessarily increase costs for consumers and are regressive in nature. Mandated recycled content requirements create unintended consequences in the free flow of recoverable commodities. Further, they do nothing to increase recovery.

AF&PA, along with the entire paper manufacturing and recycling community, would like to continue this dialogue with Florida’s DEP. We applaud your interest in increasing recycling and thank you for your time and consideration.

Brynn K. Iversen
Manager, Government Affairs
American Forest & Paper Association
1111 19th Street, NW, Ste 800
Washington, DC 20036
Phone: (202) 463-2433
Fax: (202) 463-2055