Fiscal Year 2000 - 2001 Action Plan

for Greening the Department of the Interior

Through Waste Prevention, Recycling and Federal Acquisition

April 2000

To promote achievement of the vision and goals established in the Strategic Plan for Greening the Department of the Interior Through Waste Prevention, Recycling, and Federal Acquisition, the Department of the Interior commits to implement this Action Plan during fiscal years 2000 and 2001. This Action Plan provides a brief description of each action, and the attached summary table will identify the bureau or office with lead responsibility for the action and the anticipated time frame for completion of the action.

WASTE PREVENTION AND RECYCLING STRATEGIES

Develop bureau and facility Waste Prevention and Recycling Programs.

(per Section 705 in EO 13101)

Each bureau shall initiate, if they have not already done so, a program to promote waste prevention and recycling activities at all of their facilities. Facilities should meet or exceed all applicable state and local guidelines (summarized in Appendix B to the Strategic Plan).

Bureau waste prevention and recycling programs should ensure that all DOI personnel know their responsibilities for recycling: white paper; mixed paper/newspaper; cardboard; aluminum; plastic(#1PET and #2HDPE); glass; shipping pallets; scrap metal; toner cartridges; and, consistent with applicable hazardous waste regulations, fluorescent lamps and ballasts; batteries, used oil; antifreeze; and tires. There is a also need to update the Departmental Manual chapter on property to address on the proper recycling of electronic equipment (which contain hazardous materials).

These programs should include DOI contractors, GOCOs (government-owned, contractor-operated) contractors, and concessioners, requiring these entities to reduce waste and recycle, and to contribute to attaining DOI goals.

Some bureaus have written guidance regarding how to reduce solid waste. The National Park Service (NPS), Division of Facilities Management, authored the NPS Solid Waste Handbook and the NPS Inter-Mountain Region has written the Tool Kit for Solid Waste Management. Both offices have agreed to make their guidance documents available for use by other bureaus. The Greening the Interior Work Group will review these documents and determine if any revisions or updates are appropriate for current use. Particular focus will be given to ensure that the guidance document provides useful and up-to-date information to help facilities get composting programs started. Other bureaus are encouraged to adapt these guidance documents for their bureaus’ use.

Designate bureau and facility Waste Prevention and Recycling Coordinators.

(per Section 705 in EO13101)

Every bureau facility with more than five permanent, full-time-equivalent (FTE) employees shall designate a Waste Prevention and Recycling Coordinator. Nonetheless, facilities with five or fewer full-time personnel still need to implement the provisions of E.O. 13101 and achieve Departmental goals to the extent practicable, with the exception of recordkeeping and formal reporting. The Recycling Coordinator position may be a collateral duty or, as appropriate, assigned to personnel who will be dedicated to this activity. Bureaus should consider having designated contacts in the regional offices to assist and coordinate waste prevention and recycling program activities. Bureaus will develop and maintain contact lists of these coordinators to assist with information dissemination and to aid in cooperative efforts among facilities (see Strategy 3 below).

Initiate cooperative efforts to recycle among bureau facilities and with other State and local entities within geographical clusters.

Waste minimization and recycling efforts may be less feasible for DOI offices located in remote areas. However, these offices should endeavor to participate in existing local recycling programs or to establish cooperative efforts with other nearby DOI facilities, or USDA Forest Service facilities. Bureaus also should pursue cooperative ventures with State and local entities to promote recycling and waste reduction.

Allocate to waste prevention and green procurement projects the revenues generated by recycling managed by the General Services Administration in accordance with Part 515, Chapter 3 of the Departmental Manual (515 DM3)

Part 515, Chapter 3 in Departmental Manual (515 DM 3) directs the allocation of revenues earned from sales of recycled materials in accordance with Public Law 106-58, section 607, or its successors. When GSA manages the recycling program at a DOI facility, revenues that are generated are added to a DOI account which accumulates all revenues generated throughout the Department. The Departmental Manual indicates that these funds will be allocated by DOI’s Agency environmental Executive (AEE). The funds must be allocated to further Department efforts in areas such as recycling, pollution prevention, or environmental improvement. The Office of environmental Policy and Compliance will convene and chair a panel of bureau/office representatives to call for proposals and recommend allocations to the AEE.

GREEN PROCUREMENT AND PROPERTY MANAGEMENT STRATEGIES:

Develop policy and guidance on the consideration of environmental factors in acquisition planning.

(per Section 401 in EO 13101)

Section 401 in the Executive Order requires that environmental factors be considered in acquisition planning. To accomplish this, the Office of Acquisition and Property Management, will work with the Acquisition Management Partnership Group to amend the Department of the Interior Acquisition Regulation (DIAR), Section 1407, to require consideration of environmental factors for acquisitions over $100,000. Since program managers are primarily responsible for the development of specifications, program managers and Contracting Officers are jointly responsible for the acquisition planning process. Bureaus may voluntarily choose to use the "green" acquisition planning process for contracts less than $100,000.

In accordance with the expanded acquisition planning policy, requisitioners preparing specifications will need to address the following questions:

How have requirements for virgin materials been eliminated in this contract?

How will this contract promote the reuse of products?

How does this project include use of biobased products?

How does this contract incorporate use of recovered materials, including Comprehensive Procurement Guideline (CPG) items?

How does this contract specify use of environmentally preferable products?

Are life-cycle costs accounted for in project design? How?

How does this project promote the use of products that are recyclable?

How will waste minimization be incorporated into the specifications?

How will this contract specify use of less toxic products?

Web-based acquisition-planning tools are being developed within the Department. This effort will be expanded to address the Department’s revised DIAR. The on-line, automated tool will facilitate the planning process for requisitioners and will allow for easy capture of data for program management purposes. Requisitioners also will find helpful web-links to model contract language developed by EPA and the Office of the Federal environmental Executive.

There also is a need for general guidance on to how to analyze requirements and revise acquisition documents to make them more environmentally preferable. A guidance document will be developed to help requesters address environmental considerations in acquisition planning and specifications."

This Strategy does not address credit card purchases, which is instead addressed in Strategy 6 and 9 below.

Update the Department Affirmative Procurement Program policy, and develop and support bureau Affirmative Procurement Programs and activities.

(per Section 402 in EO 13101)

The Department will update its current Affirmative Procurement Program Plan as required under Section 402 in the Executive Order and Section 6002 of RCRA. The Department’s previously-issued policies include:

Department of the Interior Acquisition Policy Release (DIAPR) 92-12, "Interim Acquisition Policy Release Establishing a Department-wide Affirmative Procurement Program," dated

March 25, 1992

"General Guidance on Pollution Prevention and Right-to-Know, Recycling, and Green Acquisition," September 1995
DIAPR 97-2 , "Guide to environmental Contracting"

Preference Program

Preference will be given in the procurement of products and services of similar price and performance to those having more environmentally-preferable qualities. Products and services with environmental benefits may be purchased at higher cost over less-environmentally sound products and services, particularly if use of the product will result in cost-savings elsewhere in the products’ life cycle. The bureaus will determine with prudence and on a case-by-case basis the extent to which it is appropriate to pay such a premium. Given the objective of RCRA 6002 and E.O. 13101, which is to foster markets for green products through government purchasing, it is not inconsistent to pay more initially for these products in anticipation that market forces will eventually lower prices.

The Department will develop policy to state explicit preferences for specific products when they are found to be competitively priced, available, and of good quality. The Government has adopted this practice in mandating that all paper contain at least 30% postconsumer material. Likewise, many executive agencies, including DOD, are standardizing the use of re-refined oil. In the revised APP, the Departmental policy shall identify when and how such preference policies will be established.

Promotion Program:

The APP will outline promotional activities to be undertaken to build awareness of recycled content products (RCP), environmentally preferable products (EPP), and biobased content products (BCP) within the DOI purchasing community, to provide guidance on appropriate use of products in DOI, and to overcome barriers to a specific product’s use that may exist within DOI. During FY2000 and FY 2001, the following promotional activities will be pursued, focusing particularly on products highlighted in the Department’s goals (re-refined oil, retread tires, reclaimed engine coolant, copy paper, paper towels, bathroom tissue, plastic trash bags, carpet and bio-based lubricating oil):

Teleconferences to discuss specific products

A Vehicle Managers Workshop with GSA to promote use of green products in leased vehicles

Guidance on appropriate use of retread tires

Web-links to lists of product vendors for CPG and other products

Recognition of facilities that initiate green procurement programs

Verifying Estimates of Recycled Content and environmental Attribute Claims:

The APP will revise procedures to implement FAR 52.223-9, "Certification of Percentage of Recovered Material Content for EPA Designated Items Used in Performance of the Contract," as well as expand these verification efforts to address other product claims related to environmental attributes. Brief guidance for Contracting Officers and Technical Representatives will be developed and include suggestions on how to use third-party environmental standards and certifications for verification of product attributes.

Annual Review and Monitoring: DOI will track green procurement and property- management goals as identified in the Strategic Plan. Refer to Action 12 below.

Develop model contract language for services and goods routinely used throughout the Department which incorporates and specifies waste prevention and green procurement.

Model contract language for "greening" particular contract commodities routinely used throughout DOI will be developed to help requisitioners adopt initiatives more readily. A "Green Contract Team" with appropriate expertise will be created for each contract type. A good example of such an effort was the"green" contract developed by DOI to procure custodial services for the Main and South Interior Buildings.

(per Section 501 in EO 13101)

To help identify contracts for potential incorporation of "environmentally preferable" specifications, the Greening the Interior Work Group will refer to the annual publication, "Forecast of Interior Acquisitions," published by the Office of Small and Disadvantaged Business Utilization.

Develop and disseminate green procurement training materials.

(per Section 801 in EO 13101)

Instructional material about green procurement and the Department’s goals will be developed and disseminated for incorporation in bureau training and guidance given to government charge card users.

Green procurement curriculum material also will be developed to be included in the Department’s Acquisition Intern Program. These training materials will be made available for other audiences and classes, and for inclusion in bureau training of Contracting Officers, and Contracting Officer’s Representatives.

Partner with procurement sources to ensure that products and services sold to DOI comply with RCRA and EO 13101, and support DOI goals.

The Department will build partnerships with traditional federal supply sources to ensure products meet E.O. 131010 mandates and support DOI goals. We want to encourage these sources to review their products and services to ensure:

that they comply with the recycled content requirements in the CPG;
that they have environmentally-preferable attributes; where appropriate; and
that they support the green procurement goals of the Department.

Under a Memorandum of Agreement (MOA) among DOI and the Committee for Purchasing from the Blind and Severely Disabled (the Committee), the National Industries for the Blind (NIB) and Severely Handicapped (NISH), products and services supplied by mandatory sources specified in the Javits-Wagner-O’Day Act (JWOD) will be evaluated for the above purposes. DOI will promote actively those products that meet these environmental mandates. NIB and NISH will make efforts to improve the environmental performance of products where there are opportunities to make them more preferable. By working with the Committee and affiliated agencies, DOI will seek to purchase products consistent with the Javits-Wagner-O’Day Act and that also satisfy environmental purchasing mandates. The Department, through the GSA commercial source program, will promote "Buy Green with "JWOD."

A MOA between DOI and GSA will define mutually-supported initiatives to "Buy Green, Build Green, Save Green, and Drive Green." Through this MOA, the Department will work with GSA to pursue the Department’s goals with respect to leased facilities, leased vehicles, and products consumed while also supporting GSA’s Planet GSA program.

A MOA will be initiated with the Federal Prison Industries for similar purposes, in part, focusing on their services for computer equipment deconstruction and recycling.

Working with Interior’s Office of Small and Disadvantaged Business Utilization (OSDBU), Interior will seek to raise green-product awareness within the small, disadvantaged, women-owned, veteran-owned and historically-underutilized business (HUB) zone communities by participating in national conferences hosted by the Small Business Administration (SBA). Participation will include hosting a booth and workshops. Additional opportunities to further this initiative will be sought in consultation with the environmental Protection Agency and SBA.

11. Execute pilot projects to evaluate products for efficacy, environmental benefits, and cost of use.

(per Section 503 (b) in EO 13101)

In accordance with Section 503 in the Executive Order, the Department will test the principles of purchasing EPPs through pilot projects. The projects will focus on product performance, availability, cost, and environmental benefit.

With the leadership of the National Business Center, environmentally preferable products and services will be pilot tested in the Main Interior Building (MIB) and South Interior Building (SIB). Three pilot projects underway include:

environmentally Preferable Paper: The National Business Center’s (NBC) Creative Communications Services will pilot test process-chlorine-free, recycled content, and tree-free paper in their operations and in copy centers throughout the MIB and SIB.

environmentally Preferable Cleaning: The new custodial services contract for the Main Interior and South Interior Buildings was recently awarded and is based, in part, on the NBC commitment to use environmentally preferable cleaning products, recycled content products (RCPs), paper made without the use of chlorine, and enhance the recycling program within the buildings. A Cleaning Stewardship Committee including building tenants, the National Business Center, the contractor, and the contractor’s staff, will work together to enhance the effectiveness of the recycling program in the Interior Complex and oversee implementation of other "green cleaning" efforts within the scope of the contract.

Biodegradable Food Service Ware: EarthShell biodegradable plates and bowls, made from potato starch and limestone, are being used in the Main Interior Building cafeteria as part of a one year pilot project. Biodegradable food wastes and service ware are being segregated, collected in biodegradable bags. These wastes are being taken to the USDA Research Station in Beltsville, Maryland, where different compost methods are being applied to evaluate the rate at which it composts and the products of decomposition.

Bureaus are encouraged to conduct additional pilot projects to evaluate other green products. The Departmental webpages will be used to share information about these pilots and their progress.

The AEE will request that bureaus undertake at least one pilot project each fiscal year. The AEE also will encourage bureaus to pilot biodegradable, bio-based lubricants in DOI equipment where there is potential loss to the environment, such as marine outboards lawn mowers, chain saws, and snow mobiles.

GENERAL PROGRAM STRATEGIES

Establish goal tracking and auditing protocols.

A web-based survey tool will be developed to enable the collection of information for tracking against goals. A contract for the development of this system will be awarded. As envisioned, facility managers will be asked to respond once a year to brief survey questions regarding their waste generation and recycling, and their use of green products. The survey for measuring Waste Prevention and Recycling will prompt managers for information regarding how much solid waste and recycling commodities are generated in a given fiscal year. Volume to weight conversions will be imbedded in the system to help standardize units for reporting.

The survey for assessing progress against Green Procurement and Property Management Goals will be developed in conjunction with the Greening Interior Work Group, the Procurement Management Partnership Group and the Property Management Partnership Group.

Model auditing protocols will be developed to help evaluate a facility’s conformance to DOI goals and to determine whether it is implementing other greening efforts. These protocols will be available for use in bureau environmental auditing programs which have been established consistent with 515 DM 2 "environmental Auditing."

13. Establish benchmarks for recognition of facilities showing leadership in DOI by comprehensive adoption of these initiatives.

The Department will adopt three benchmarks for environmentally preferable operations to be developed by the Greening the Interior Work Group. The benchmarks will define management actions and types of equipment needed to operate in compliance with applicable environmental requirements in a manner that demonstrates leadership in "sustainable" operations.

Once the benchmarks are established, the Agency environmental Executive will call for facility manager to consider how they conform to the benchmark. If a facility manager thinks that their operations meet or exceed the benchmark, they can apply for recognition. The Green the Interior Work Group will review these applications and recommend facilities for recognition.

Benchmark 1 - DOI Green Fleet Standard

DOI will create a "Green Fleet Standard" based, in part, on a successful program created for the U.S. Postal Service by the non-profit organization, Green Seal. DOI’s Green Fleet Standard will address:

Use of less-hazardous substances for engine cleaning and maintenance
Fuel efficiency and alternative fuel use
Proper management of hazardous waste
Use of RCPs, (retread tires, re-refined oil, and reclaimed engine coolant)
Pollution prevention in vehicle washing
Preventive maintenance for sustainable equipment use
Good housekeeping and materials storage

Benchmark 2 - DOI Green Office Standard

The DOI Green Office Standard will include:

Use of CPG designated paper and non-paper office products
Paper-use minimization (double-sided copying, paper reuse, etc.)
Use of chlorine-free paper
Recycling
Trip-minimizing program for employees
Energy conservation measures
environmentally preferable cleaning
environmentally preferable landscaping and grounds maintenance

Benchmark 3 - DOI Green Building Standard

Development of a DOI Green Building Standard will be considered along with the efforts outlined in Action 13 having to do with Model Facilities. The Interior Energy Management Leadership Task Group, the Interior Planning, Design, Construction and Maintenance Council, and the Greening the Interior Work Group will decide how best to proceed with a DOI Green Building Benchmark.

Develop model facilities within each bureau, including the Main Interior Building, which exemplify sustainable design principles and which utilize green construction products.

(per Section 704 of EO 13101)

In accordance with Section 704 in the E.O, the Department and individual bureaus will incorporate and demonstrate the following in their construction and renovation programs:

environmentally preferable and bio-based construction products

Increased variety and use of RCPs

Sustainable design principles endorsed by the U.S. Green Building Council

Expanded recycling and source reduction programs

Organics composting

Public/private partnerships for marketing recovered materials generated in DOI recycling programs

Energy efficient and water conserving technologies

DOI will showcase these products, technologies, and green building design concepts at model facilities for the benefit of other DOI managers and the public. The Agency environmental Executive will ask all Bureau heads to initiate at least one model facility project each fiscal year.

The Main Interior Building modernization project will include green building elements, focusing on energy-efficient and water-conserving practices and technologies, environmentally preferable paints, recycled content carpeting, and demolition waste minimization.

15. Ensure that building space leased by DOI (or for DOI by GSA) incorporates sustainable design, green products and services, recycling, energy management and water conservation in building development and operation.

(per Section 702 in EO 13101)

Section 702 in EO 13101, "Real Property and Acquisition Management," directs executive agencies to address EO 13101 mandates in leases. The Department initiates and executes leases when it has delegated leasing authority. If DOI does not have delegated authority for a particular organizational unit, GSA solicits and leases space on behalf of the Department. Under EO 13123 "Greening the Government Through Energy Efficient Management," GSA is developing a model "green lease." Use of this model green lease by GSA will be "customer driven." Therefore, it is critical that, regardless of whether DOI or GSA is negotiating the lease, DOI managers are aware of and actively engaged in the "greening" our leases. Green leases may encompass:

Recycling, and waste-management reporting
Energy-savings performance incentives
environmentally preferable landscaping and grounds management
environmentally preferable cleaning products
Recycled-content products in building operations (bathroom tissue, paper towels, trash bags)
Green energy sources

If the space will be built or renovated for the

tenant’s occupancy, the lease should specify that the building will include:

Use of RCP, EPP, and BCP
Energy efficient and water conserving technologies
Sustainable design

The Department will draft policy to direct that all new leases include a minimum set of green building and operations clauses. This policy will differentiate between leases that are for all or most of a building and leases where DOI will be a single tenant in a multi-tenant building, occupying a small percentage of the building space. It may be more difficult to convince landlords to make significant changes to their operating procedures under the latter scenario. The policy will identify the role and responsibility of DOI space lease managers in negotiating and monitoring these leases. To facilitate this work, the AEE will request that each bureau create a list of projected leasing activities for the next two years. The Department property-management staff will distribute model "green lease" language and provide technical assistance. Success stories, as well as work in progress, will be communicated on Department websites.

Recognize outstanding efforts within the Department to promote mandates of EO 13101.

(per Section 802 in EO 13101)

Since 1995, DOI has recognized outstanding environmental accomplishments by individuals, bureaus, and contractors. This award program currently meets the intent of Section 802 in the EO. Bureaus are encouraged to develop internal environmental-awards programs. The Department will coordinate the selection of nominations to be sent to the White House Closing the Circle Awards from those received for the DOI environmental Achievement Award.

17. Host "Greening the Interior" Workshops to further discourse and understanding of sustainability as it applies to DOI operations.

DOI will host workshops on the topic of sustainability as it relates to DOI operations for executives, senior managers, and program managers from all bureaus and offices. These workshops will seek to promote an on-going dialogue around and awareness of a broader "greening agenda," seeking to identify how we can operate DOI facilities with more environmental-sensitivity. These workshops will include the presentation of case studies of "green" DOI facilities, and will involve experts from outside Interior who can discuss "greening" trends in the private sector and environmental issues that are driving these initiatives.