This Is Plastics: GSA ANPR based on flawed petition from environmental groups, poses threat to reducing emissions


GSA ANPR based on flawed petition from environmental groups, poses threat to reducing emissions

Petition for the federal government to move away from single-use plastics ignores data and should not support an ANPR by General Services Administration.


In February 2022, dozens of environmental groups led by the Center for Biological Diversity filed a legal petition requesting that the Biden Administration leverage the power of procurement held by the General Services Administration (GSA) to restrict the purchase of single-use plastics by federal agencies. According to the petition, restricting federal use of plastics would “[align] with the Biden Administration’s pledge to address both climate change and environmental justice.” In response, GSA issued an advanced notice for proposed rulemaking (ANPR) to evaluate the use of single-use plastics and examine the potential of phasing out single-use plastics from federal purchase and procurement.

However, the Center for Biological Diversity’s original petition is grounded in unfounded claims and uses studies that are neither peer-reviewed nor reflective of the breadth of evidence demonstrating plastic’s sustainability and critical uses across the economy. That the Center for Biological Diversity and other activist groups argue that a reduction in the use of plastics would service efforts to address climate change when plastics actually reduces emissions is only further indication of bad faith. The federal government cannot ignore clear facts and proven science demonstrating that single-use plastics can help reduce greenhouse gas emissions and, with proper investment in recycling infrastructure, can be appropriately managed when discarded.

Emissions – Reduce the Carbon Footprint

At the core of Center for Biological Diversity’s argument against single-use plastics is the assertion that plastics cause environmental harm. While the plastics industry agrees that plastic waste belongs in the economy, not the environment, the Center for Biological Diversity’s petition fails to acknowledge that waste in the United States is already being managed responsibly with very little leak into the environment. One study found that only about 2% of all plastic waste is mismanaged in the United States. While there is always room for improvement, this is hardly a significant percentage. Furthermore, the Center for Biological Diversity’s petition also ignores the actual environmental benefits of plastics when compared to alternative materials. Reputable studies and Life Cycle Assessments (LCA) repeatedly demonstrate the sustainable properties of plastics and prove how the material outperforms would-be substitutions like wood, glass, paper and aluminum from production to transportation to end-use.

Especially for use in logistics, packaging and everyday single-use products, plastics are clearly superior. In food packaging, a recent study found that, throughout its lifecycle, plastic packaging has a lower environmental footprint than paperboard packaging. A different study evaluating similar properties found that plastic packaging has a lower environmental impact than substitute packaging, including metals, glass and paper-based options, for all impacts (global warming potential, emissions produced, etc.) evaluated in the United States and Canada. In general, heavier goods require more energy and result in higher emissions. Glass, for instance, can require 40% more energy for transportation than plastics. A study from the Imperial College of London found that if all plastic bottles were replaced with glass, the resulting CO2 emissions would be equivalent to 22 coal-fired power plants. Even cotton requires 80 times as much fuel, generating 80 times the emissions, to transport than plastic.

As critics of the plastics industry look to push brands, consumers and government bodies towards alternative materials, they would do well to recognize the environmental advantages plastics provide before they inadvertently upend the very climate and sustainability goals that plastics are, clearly, key to achieving.  

Environment – Protect Waterways and Wildlife

Not only do plastics reduce emissions at every step of their life cycle, but they also have endless post-consumer opportunities for infinite lives through mechanical and advanced recycling processes as new products and consumer goods. The plastics industry has invested billions of dollars to improve and fortify recycling systems, including a recent announcement by ExxonMobil of the company’s intention to build one of the largest advanced recycling facilities in North America, which will have the capacity to recycle 500,000 metric tons of post-consumer material each year.

Industry initiatives like Operation Clean Sweep, the Microplastics Advanced Research and Innovation Initiative (MARII) and Zero Net Waste are also actively working to address waste in the environment and waterways and implement innovative new solutions and designs that make plastic products more circular. Consumer brands have also launched green packaging lines made with recycled plastic and leading beverage companies like Coca Cola are moving toward bottles made with 100% recycled content or more easily recycled plastic.

By seeking to restrict, if not outright eliminate, the use and purchase of single-use plastics by the federal government, the Center for Biological Diversity’s petition ignores the circularity of plastics and the potential of the material for endless reuse. Continued investment in education and recycling will support a more robust circular economy that will keep all materials out of the environment and create new opportunities for further innovation. Collaboration between government, the plastics industry and consumers can help these efforts and ensure that infrastructure is fortified and able to process more post-consumer plastic for new products.

Economics – Protect Consumers and the Federal Pocketbook

The Center for Biological Diversity’s claim that the federal government can “harness the power of the federal pocketbook” to reduce plastic waste would only short-circuit the buying power that the federal government has. A move away from plastic and toward more environmentally degrative materials would significantly increase costs for the government, diverting valuable funding away from important social programs and infrastructure spending.

Plastic is by far the most affordable material when it comes to single-use products as well as reusable products or products for more advanced applications. Producing alternative materials like glass, aluminum and cotton is more expensive than producing plastic, not to mention more environmentally degrative. Aluminum mined from bauxite can poison water sources while cotton farming is extremely water intensive. In terms of transportation, switching to heavier packaging materials like aluminum or glass for beverages would increase transportation costs by up to five times per item.

Furthermore, any action to restrict or regulate the use of plastics would significantly impact the U.S. economy. Having a short comment period in particular could hamper efforts to provide a full economic accounting of just how much a move away from single-use plastics could cost taxpayers. For example, one study by the government of Pennsylvania found that banning expanded polystyrene foam foodservice products alone would cost local government, non-profits and other institutions about $40 million per year. Furthermore, the plastics industry currently supports over 1.55 million jobs, both directly and indirectly, and recently planned advanced recycling projects could create up to 40,000 more jobs, supporting local economies and communities. Plastics also contribute over $450 billion in shipments, with an annual expected growth rate of over 13% for the next five years. Keeping this value and supporting the millions of hard-working Americans in this industry is key to our future.

The science is clear, the Center for Biological Diversity petition’s claims are unfounded and allowing this to be the basis for an ANPR from the GSA would be an irresponsible mistake. Plastics are the best option for reducing emissions, protecting the environment and lowering costs for the government and consumers.  

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