December 10, 2001

To:  RCRA-Docket@epa.gov (Subject: Beyond RCRA White Paper)

I am submitting comments on "Beyond RCRA: Prospects for Waste and Materials Management in the Year 2020" on behalf of the Waukesha County Environmental Action League (WEAL), Waukesha County, Wisconsin.

WEAL was established in 1978 with a mission "to represent the Waukesha County community for the protection of Waukesha County's natural resources through dedicated grass-roots participation and action.

Over the years WEAL has been a strong proponent for Recycling and Waste Reduction and we believe the document "Beyond RCRA" can serve as a foundation for sustainable waste management practices in the future. Although the document addresses a number of important issues, we feel the
concept of ZERO Waste should be the focal point and not viewed as a nonrealistic goal.

A goal should be an objective to strive for. Goals must be set to the highest standards and need not be 100% achievable.  However, a goal should
reflect an ongoing effort to realize an intended objective. Therefore, it is doubtful the vision set forth in "Beyond RCRA" will ever be achieved without
ZERO Waste as an end point to strive for.

In Waukesha County we have a number of landfills that have reached National Priorities List (NPL) status. We also have two large, private landfills that continue to increase volume and expand at unprecedented levels.  In the future these landfills may also reach NPL status.  Resources are being
wasted every day in Waukesha County and across the nation, a comprehensive plan is needed to end our dependence on disposal and landfills.

Consumers purchase products, pay to dispose of these wasteful products, and then pay for pollution cleanup in the future.  A clear vision of ZERO Waste can put an end to this continuous cycle of waste and contamination.

We cannot assume that "industry will be more efficient and less wasteful." We need a plan for industry to follow. Manufacturers should have
comprehensive guidelines in place so that by the year 2020 we will no longer have products that must be discarded and packaging that is so wasteful. A viable goal of ZERO Waste will lead the nation in that direction.

Thank you for the opportunity to submit comments on this very important plan for the future. WEAL asks that you consider the long range implications of waste generation and that you include ZERO Waste as a major component of the plan.

Sincerely,

Charlene Lemoine
Waste Issues Representative
Waukesha County Environmental Action League (www.weal.org)
clemoine@wi.rr.com
phone:  262-574-7568