Environmental Resources Planning, LLC

September 6, 2013 Dallas City Hall 1500 Marilla Street Dallas, TX 75201 Members 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 data to 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 Beautifuls 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 not conduct any analysis of that type. While the data points regarding plastic bags on Retail Areas and Storm Drains cite the correct numbers, your memorandum does not taken into account that this included plastic bags of all types including leaf bags, dry cleaner bags and illegally dumped bags of trash and garbage. To suggest that this data referred only to plastic retail bags would be inaccurate. The graphic on page 14 implies visually that, based on the KAB Study, three plastic bags would be about six feet tall. Our study made no statement to support such a claim and did not 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 - an abandoned New Jersey Retail Area. The site had a fence that caught more than 800 pieces of litter and illegally dumped bags of trash. If that outlier was removed, the data for littered plastic 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 bag rather than three. Regarding plastic bags found near Storm Drains, plastic bags of all types, including illegally dumped bags of garbage and trash, were only the 17th most common littered item near Storm Drains.

City of Dallas Memo

Environmental Resources Planning, LLC

Environmental Resources Planning, LLC

Page 44 states that plastic bags are higher by count, but no statistically-based litter survey has ever found that plastic bags are a significant portion of the litter stream and no statistically-based survey of items caught in trees has ever been published to my knowledge.

As the principal at ER Planning my work on the impact of litter to our communities has been featured in the New York Times and National Geographic Magazine as well as on NPR and Good Morning America. I have taught Environmental Science and Ethics in Management at the university level and was invited, as a subject matter expert on environmental issues and community dynamics, to participate in a study commissioned by the President. ER Planning organized and sponsored the 2011 National Litter Forum, which focused on the role of litter abatement on restoring our nation's communities. I was lead author of the 2007 report, Litter Literature Review, conducted for Keep America Beautiful. Our senior staff led seven statewide litter surveys (including the 2013 Texas Litter Survey), four citywide litter surveys and a number of beach litter surveys. We have also provided pro bono assistance to groups such as Potomac Watershed Initiative and Ocean Conservancy, including their National Marine Debris Monitoring Program. As the principal of the organization whose work is cited by the City of Dallas it is my professional opinion that: The use of misleading data such as this will likely lead to discussions of narrowly focused material bans, which if put into place, will not resolve the littering issues they are meant to address in the City of Dallas. Instead, they will create a false sense of security that litter-related problems have been appropriately resolved. In fact, because they will have not been, litter-related problems will continue to grow when left inadequately addressed as The KAB Study cited by the city showed that all plastic bags, of which plastic retail bags are only a subset, are just 0.6% of litter nationally, and the 2013 Texas Visual Litter Survey showed that plastic retail bags are 1.95% of litter in Texas statewide. Litter abatement can only be achieved by addressing known source activities along with a commitment to continuous education and consistent enforcement of anti-litter statutes bearing a clear message: Litter is not acceptable in our community and the cost to litterers will be substantial. I hope this information has been helpful. Feel free to contact me if I can be of help with your efforts. Regards, Steve Steven R. Stein, Principal Environmental Resources Planning, LLC Office: (240) 631-6532

City of Dallas Memo

Environmental Resources Planning, LLC