Environmental Resources Planning, LLC
City of Dallas Memo © Environmental Resources Planning, LLC
September 6, 2013Dallas City Hall1500 Marilla StreetDallas, TX 75201Members of the City Council,
Environmental Resources Planning, LLC (“ER Planning”) is the only U.S. firm focusing entirely
on litter surveys and related research. Among our fields of expertise is the analysis of litter datato determine sources and pathways of litter.I read your
Update on Dealing with Carryout Bags
memorandum, dated August 21, 2013, and
would like to call your attention to misused data from Keep America Beautiful’s 2009 National
Litter Study (KAB Study) which I led the design of and managed.Specifically I want to address the following research errors in your memo cited as our work:
Page 13 of your memo states that 5% of plastic bags are “littered” and inaccurately
attributes that statement to the KAB Study. Our study made no such claim and did notconduct any analysis of that type.
While the data points regarding plastic bags on Retail Areas and Storm Drains cite thecorrect numbers, your memorandum does not taken into account that this included plasticbags of all types including leaf bags, dry cleaner bags and illegally dumped bags of trashand garbage. To suggest that this data referred only to plastic retail bags would beinaccurate.
The graphic on page 14 implies visually that, based on the KAB Study, three plastic bagswould be about six feet tall. Our study made no statement to support such a claim and didnot conduct any analysis of that type.
Regarding litter on Retail Areas, the higher than usual number of plastic bags on Retail Areas was due to litter and illegally dumped bags of trash found on one particular site - anabandoned New Jersey Retail Area. The site had a fence that caught more than 800 piecesof litter and illegally dumped bags of trash. If that outlier was removed, the data for litteredplastic bags of all types on Retail Areas would have reflected the following results:
0.8% of litter on Retail Areas.
0.5 bags/1,000 square feet instead of 3 bags/1,000 square feet on Retail Areas
21st most common littered item on Retail Areas.This change would have reduced the number of plastic bags on the page 14 graphic to ½bag rather than three.
Regarding plastic bags found near Storm Drains, plastic bags of all types, including illegallydumped bags of garbage and trash, were only the 17th most common littered item nearStorm Drains.