President Clinton's 1998 Executive Order 13101 directed the creation of a Biobased Products List (BPL) to stimulate the market for agricultural products by directing government purchasers to specify these products. RCA commented on the proposed guidelines to advocate for agricultural materials over their wood-based counterparts.

September 8, 1999

J.R. Holcombe, Jr.
Office of Procurement and Property Management
U.S. Department of Agriculture
Mail Stop 9303
1400 Independence Avenue, SW
Washington, DC 20250

Re: USDA Biobased Products List

Dear Mr. Holcombe, Jr.:

The Resource Conservation Alliance is a nonprofit organization dedicated to protecting natural forests and other ecologically important systems through market- and commodity-based conservation strategies. These strategies include reduced consumption and increased recycling, redesign and resource diversification. I am writing to provide comment on the August 13, 1999, Federal Register Notice—Procedures for Submission of Biobased Products for Listing by USDA.

While having the potential to greatly expand the markets for biobased products, the proposed procedures are troublesome in their continued promotion of "forestry materials." One of the primary goals of E.O. 13101 is to use government purchasing power to increase the market share of recoverable materials in an effort to conserve the environment. The inclusion of "forestry materials" in the biobased products list maintains the federal government's reliance on environmentally destructive industries, such as logging, which is dependent upon virgin resources.

As stated in the notice, "The Federal market place is already well aware of mature biobased products, such as ... dimensional lumber." While the proposed procedures claim that the "USDA has decided not to list commonly known mature products," the procedures contradict themselves by promoting "forestry materials." In the United States, forest-based products currently enjoy a tremendous share of the market compared to many alternative agriculture- based products. Their inclusion in this list is not only unnecessary, it is entirely detrimental to the development of the numerous agriculture-based products that deserve an expanded market share.

Perhaps more disconcerting, as it stands now, biobased products are so broadly defined that they can contain virgin, clearcut, non-renewable materials from ancient forests. This directly contradicts E.O. 13101's mandate "to increase and expand markets for recovered materials through greater Federal Government preference and demand for such products."

By including "forestry materials" in the biobased products list, the USDA will be creating an unreconcilable policy conflict. According to E.O. 13101, "It is the national policy to prefer pollution prevention, whenever feasible." Pollution prevention is defined as the implementation of "practices that reduce or eliminate the creation of pollutants through... protection of natural resources by conservation." Furthermore, guideline 4 of the Environmental Protection Agency's Environmentally Preferable Purchasing Guideline developed in adherence to E.O. 13101 mandates that federal agencies examine the magnitude of impact of their purchases with respect to "the reversibility and geographic scale of the environmental impacts."

The consumption of "forestry materials" contributes to the massive scale of environmental degradation caused by the timber trade. Only 12 percent of the world's original forests remain as relatively healthy, intact ecosystems. In the United States, outside of Alaska, only five percent of our original forests are still in their natural condition. Furthermore, as a developed nation, the United States consumes a disproportionately high number of the world's trees. Since the volume of wood that can be logged sustainably worldwide cannot even begin to meet our current demand for wood, reducing consumption becomes a prerequisite to the "protection of natural resources through conservation."

Therefore, the Resource Conservation Alliance strongly recommends that "forestry materials" be removed from the biobased products list in an effort to prioritize the market development of agricultural products. Agricultural residues are an excellent alternative to virgin wood fiber for many reasons. There are approximately 350 million tons of agricultural residues produced annually in North America. Aside from their abundance and renewability, using agricultural residues will benefit farmers, industry and human health and the environment. If the biobased products list were to prioritize agricultural products, it could help to ameliorate the well-known economic plight of America's family farmers. In order for the list to truly be a "successful implementation of E.O. 13101" with "significant outcomes for U.S. agriculture and the environment," as claimed in the notice, the biobased products list would first need to eliminate "forestry materials."

Please contact me with any questions or concerns you may have. Thank you for your consideration.

Sincerely,

Leda Huta
Director