National Park Service Plastics Elimination and Reduction Plan
NPS Plastics Elimination and
Reduction Plan
June 2023
National Park Service Plastics Elimination and Reduction Plan
Table of Contents
Executive Summary ........................................................................................................................................ i
Introduction .................................................................................................................................................. 1
Sustainability in the NPS ....................................................................................................................... 1
About This Plan ..................................................................................................................................... 2
Strategic Goal ............................................................................................................................................ 2
Implementation Principles ........................................................................................................................ 3
Implementation Principle 1: Foster a sustainability ethic and empower employees and partners, in
alignment with the Green Parks Plan ................................................................................................... 3
Implementation Principle 2: Work with partners, internal and external to DOI, to achieve the
Secretarial goal...................................................................................................................................... 3
Implementation Principle 3: Prioritize source reduction when developing and implementing phase-
out and reduction policies .................................................................................................................... 4
Implementation Principle 4: Apply systems-based and life-cycle approaches informed by data and
science ................................................................................................................................................... 5
Implementation Strategy .............................................................................................................................. 7
Plan Schedules and Annual Targets .......................................................................................................... 7
Years 1-2 (2023-2024): Collect Information, Set a Baseline, Analyze Alternatives, Determine
Schedules and Initial Targets, Begin to Update Policies, and Begin to Initiate Implementation.......... 7
Years 3-4 (2025-2026): Expand Implementation .................................................................................. 8
Years 5-9 (2027-2031): Full-Scale Deployment ..................................................................................... 8
No Later than Year 10 (2032): Achieve 100% Phase-Out (Elimination) of Single-Use Plastics ............. 9
1. Define Scope and Exemptions .............................................................................................................. 9
Exemptions............................................................................................................................................ 9
Voluntary Efforts Beyond NPS Requirements ..................................................................................... 10
2. Collect Data ......................................................................................................................................... 10
Account for Plastics ............................................................................................................................. 10
Review Contracts, Concessions, and Procurement Mechanisms ....................................................... 11
Review Existing or Planned Work to Address Plastic Reduction ........................................................ 12
3. Analyze Alternatives ........................................................................................................................... 12
4. Plan and Prioritize the Approach ........................................................................................................ 13
Apply Decision Criteria ........................................................................................................................ 13
Prioritize Products and Operations ..................................................................................................... 14
Identify Infrastructure Needs .............................................................................................................. 14
National Park Service Plastics Elimination and Reduction Plan
Learn from Partners and Other Bureaus ............................................................................................. 14
Develop Contingency Plans ................................................................................................................. 14
5. Develop Tools and Resources ............................................................................................................. 15
6. Fund the Work .................................................................................................................................... 15
7. Implement the Plan ............................................................................................................................ 15
Adopt Policies and Programs Service-Wide ........................................................................................ 16
Apply Plastic Reduction to Commercial Services Provider Authorizations ......................................... 17
8. Conduct Outreach and Education to Shift Public Behavior ................................................................ 17
Employee and Partner Engagement and Culture ............................................................................... 17
Visitor Outreach and Education .......................................................................................................... 18
Outreach and Education Best Practices .............................................................................................. 18
9. Measure and Report ........................................................................................................................... 18
Measurement ...................................................................................................................................... 19
Reporting............................................................................................................................................. 20
Appendices .................................................................................................................................................. 21
Appendix 1: Secretary Order No: 3407 Department-Wide Approach to Reducing Plastic Pollution . 21
Appendix 2: Implementation Guidance: Secretary Order No: 3407 Department-Wide Approach to
Reducing Plastic Pollution ................................................................................................................... 24
Appendix 3: Glossary of Terms ........................................................................................................... 26
Appendix 4: Rules, Regulations, and Guidance................................................................................... 28
Appendix 5: Applying the Waste Management Hierarchy ................................................................. 30
Appendix 6: Single Use Plastic Alternatives ........................................................................................ 31
Appendix 7. Crosswalk between This Plan and the DOI Template for Sustainable Procurement Plan
............................................................................................................................................................ 32
i
National Park Service Plastics Elimination and Reduction Strategic Plan
Executive Summary
On June 8, 2022, the Secretary of the Interior issued Secretary’s Order 3407 (SO), which aims to reduce
the procurement, sale, and distribution of single-use plastic (SUP) products and packaging, with a goal of
phasing out SUP products on Department-managed lands by 2032. The SO builds upon Executive Order
14057 (EO) which calls for agencies to increase waste diversion from landfill and prioritize sustainable
acquisition and procurement. The National Park Service’s (NPS) mission to preserve the natural
environment for the enjoyment of this and future generations is uniquely aligned with the goals of SO
3407. The NPS, its commercial service providers, and partners have a significant opportunity to lead and
serve as a model in its plastic-reduction efforts.
The NPS Green Parks Plan (GPP) provides a sustainability vision for NPS operations across key
sustainability goal areas, including a goal to Buy Green and Reduce, Reuse, and Recycle which aims to
achieve net-zero waste and sustainable procurement. Aligned with the Department of Interior’s goal,
and the GPP, this NPS Plastics Elimination and Reduction Plan outlines the implementation principles
and strategy the NPS will use to phase out the procurement, sale, and distribution of SUP. Consistent
with the GPP net-zero waste goal, the NPS will also explore reduction of other plastics where practicable
and/or as resources allow even as SUPs are prioritized.
Implementation Principles
The following four implementation principles shall inform decisions and the Implementation Plan as the
NPS pursues its single-use plastic reduction goal.
1. Foster a sustainability ethic and empower employees and partners, in alignment with the GPP.
2. Work with partners, internal and external to DOI, to achieve the Secretarial goal.
3. Prioritize source reduction when developing and implementing phase-out and reduction
policies.
4. Apply systems-based and life-cycle approaches informed by data and science.
Implementation Plan
The Implementation Plan outlines steps for planning and executing plastic phase-out and reduction
efforts. The Implementation Principles will guide how goals are achieved.
Plan Schedules and Annual Targets. SO 3407 sets the goal of phasing out SUP on DOI-managed lands by
2032. The NPS will pursue an implementation schedule that aims to meet this goal. The NPS will identify
targets—e.g., as percentages or as specific products—based on research and assessment of alternatives.
The steps in the plan include:
1. Define Scope & Exemptions. Under the SO, SUP refers to plastic items intended to be disposed of
immediately after use, including plastic and polystyrene food and beverage containers, bottles, straws,
cups, cutlery, and disposable plastic bags. In addition, the NPS will identify other plastics for reduction or
elimination, where practicable and as resources allow even as SUPs are prioritized. The NPS may make
exemptions to the phase out of SUP in certain circumstances, including, if necessary, for medical, public
safety, public health, or scientific items, or for items for which there is a well-functioning circular
ii
National Park Service Plastics Elimination and Reduction Strategic Plan
economy. Short-term exemptions may also be made if no alternative products currently exist or if
alternative products are not practical due to supply or other factors.
2. Collect Data. The NPS will determine an appropriate methodology to gather and analyze the plastics
profile at parks and utilize this information to better understand how plastic is purchased, used and
disposed of at parks; collect data and lessons learned from past studies and demonstration projects
across different settings in parks; review authorizations (e.g., contracts) to identify plastic reduction
opportunities and challenges; and review existing or planned work to reduce plastic use.
3. Analyze Alternatives. The NPS will conduct an analysis of alternatives to plastic products. Per SO
3407, alternatives may include compostable or biodegradable materials, or 100 percent recyclable or
100 percent recycled materials (with a circular economy plan) as defined in section 2 of the Save Our
Seas 2.0 Act. Per Implementation Principle 3, the NPS will prioritize source reduction over compostable,
biodegradable, or products that are 100% recyclable or made from 100% recycled materials. The NPS
will analyze alternatives from a life-cycle perspective and based on the existing science and data, per
Implementation Principle 4.
4. Plan and Prioritize Approach.
The NPS will develop decision criteria to determine which products to
target first; prioritize policies or programs that can be adopted Service-wide and/or are targeted
location-specific efforts that have a high return on investment; identify and catalog infrastructure needs;
and learn from other bureaus.
5. Develop Tools and Resources. The NPS will develop tools and resources to aid parks in the
implementation of plastic reduction strategies. The NPS will create a central repository, such as a
SharePoint site, to house existing tools and resources, as well as other tools and resources to be
developed.
6. Fund the Work
. The NPS will quantify the funding needed to implement park plastic reduction efforts.
The NPS will seek funding through traditional appropriations process and from philanthropic partners to
transition away from and reduce SUP.
7. Implement the Plan. The NPS will implement the identified strategies, guided by the Implementation
Principles. Implementation will include adopting policies service-wide, conducting pilots where
appropriate to test approaches and create case studies to learn from, and applying plastic-reduction
strategies to authorizations (e.g., contracts).
8. Conduct Outreach and Education to Shift Public Behavior
. The NPS will collaborate with employees,
residents, contracted entities, partners, as well as visitors through proven strategies and best practices
tailored to educating and engaging with these target audiences. Outreach and education to these
stakeholders will be critical to the success of this plan.
9. Measure and Report. The NPS will implement measurement and reporting practices to track progress
towards plastics reduction goals.
1
National Park Service Plastics Elimination and Reduction Strategic Plan
Introduction
On June 8, 2022, the Secretary of the Interior issued Secretary’s Order 3407 (SO), which aims to reduce
the procurement, sale, and distribution of SUP products and packaging, with a goal of phasing out SUP
products on Department-managed lands by 2032. The SO builds upon Executive Order 14057 (EO) which
calls for agencies to increase waste diversion from landfill; aggressively reduce the amount of SUP
products procured, sold, and distributed; prioritize products that can be reused, refurbished, or
recycled; and purchase products that contain recycled content or are biobased. As stated in the SO, the
United States is one of the world’s largest generators of plastic and other types of waste, and the U.S.
Government is the largest purchaser in the world with significant market power and ability to drive
change through its waste reduction and procurement policies (Council on Environmental Quality
).
See Appendix 4: Rules, Regulations, and Guidance for additional information on these and other
relevant policies.
Sustainability in the NPS
The National Park Service (NPS), its commercial service providers, and partners have a significant
opportunity to lead in plastic-reduction efforts. The NPS’s mission to preserve the natural environment
for the enjoyment of this and future generations is uniquely aligned with the goals of SO 3407.
Furthermore, the NPS has the unique ability to reach its more than 300 million annual visitors and the
broader public, to spread awareness of the urgency to reduce plastic use.
The NPS strives to make park operations and infrastructure more sustainable, advancing the agency’s
mission of environmental stewardship. Since 1998, the Department of the Interior’s (Department or
DOI) policy is that each of its bureaus develop, implement, and conduct thorough recycling programs
that ensure compliance with the spirit and intent of applicable federal, state, and local recycling
requirements and provisions; promote sound environmental practices by preventing pollution and
recovering resources through recycling; and educate and monitor for recycling participation at all of its
activities, including those of contractors and concessioners (DOI Manual Part 515: Environmental
Management, Chapter 3: Recycling).
The NPS Green Parks Plan (GPP) provides a sustainability vision for NPS operations across key
sustainability goal areas, including a goal to Buy Green and Reduce, Reuse, and Recycle. Specifically, the
GPP (2016) calls for the NPS to achieve a 50% annual diversion rate across the agency. The updated GPP
(2023) calls for achievement of net-zero waste and sustainable procurement.
From composting and dedicated recycling bins to water bottle filling stations and propane canister
recycling, the NPS continues to implement new and innovative approaches to reduce waste sent to
landfills and reduce the greenhouse gas emissions that cause climate change. In 2021, the NPS diverted
26.5 percent of its waste from landfills or waste-to-energy facilities through recycling programs at 296
2
National Park Service Plastics Elimination and Reduction Strategic Plan
parks.
1
Many NPS sites provide materials and programs to inform and educate park visitors on the
benefits of recycling, reducing waste generation, and composting.
Commercial service providers (i.e., concessioners, commercial use authorization (CUA) holders, leases)
cooperating associations, and other NPS partners have already implemented various plastic reduction
strategies and continue to incorporate sustainable practices into their procurement processes, internal
activities, and sales to visitors. Some recent examples include the Be Straw Free campaign, increasing
the sale of reusable water bottles, eliminating plastic bags in retail stores, eliminating single-use toiletry
products in plastic containers in hotel rooms, and installing water bottle refilling stations.
About This Plan
This NPS Plastics Elimination and Reduction Plan builds upon this foundation and outlines the
implementation principles the NPS will use to eliminate SUP and the specific steps for planning and
executing plastic reduction efforts across the NPS.
Strategic Goal
Plastic products, including SUP, are used throughout the NPS—including in park operations, and by
commercial service providers, partner operations, and visitors. Sources range from offices, food and
beverage services, retail services, lodging and campgrounds, to name a few. In accordance with the EO
and SO, the NPS will work to reduce, and ultimately eliminate, the procurement, sale, and distribution of
1
The 2021 diversion percentage was obtained from the Department of Interior’s Solid Waste Management (SWM)
Database which requires annual reporting by all park units of NPS building and non-building waste for which the
NPS is responsible for waste management or holds the waste and recycling hauling contracts. While the SWM
Database is not intended to collect data from commercial service providers and partners, when the NPS is
responsible for waste management or holds the waste or recycling hauling contract for buildings where those
service providers and partners operate, and that waste cannot be disaggregated from NPS operations waste, that
data may be included parks’ reported data.
The NPS Plastics Elimination and Reduction Plan Supports the Green Parks Plan
The NPS Green Parks Plan (GPP) provides a sustainability vision for NPS operations across key
goal areas. The GPP is the GHG mitigation component of the NPS response to Climate Change
and is closely coordinated with the NPS Climate Change Response Strategy (CCRS) which is
being released in the spring of 2023. The updated GPP (2023) recognizes NPS sustainability
accomplishments and the current administration’s ambitious carbon-neutrality goals to
maintain the NPS in its position as leading environmental stewards in the face of a changing
climate.
The NPS Plastics Elimination and Reduction Plan supports the GPP's goal to Buy Green and
Reduce, Reuse, and Recycle goal to achieve net-zero waste and sustainable procurement.
3
National Park Service Plastics Elimination and Reduction Strategic Plan
SUP no later than 2032. Consistent with the GPP net-zero waste goal, the NPS will also explore
reduction of other plastics where practicable and/or as resources allow even as SUPs are prioritized.
Implementation Principles
The following four implementation principles shall inform decisions as the NPS pursues its plastic
reduction goals.
1. Foster a sustainability ethic and empower employees and partners, in alignment with the GPP.
2. Work with partners, internal and external to DOI, to achieve the Secretarial goal.
3. Prioritize source reduction when developing and implementing the phase-out policy.
4. Apply systems-based and life-cycle approaches informed by data and science.
Implementation Principle 1: Foster a sustainability ethic and empower employees
and partners, in alignment with the Green Parks Plan
Meeting both the EO and SO requires support, commitment, and creativity from every level of the
organization. Implementation will require commitment of time and financial resources and action shall
be taken by leadership to meet the financial and resource needs associated with each step of the plan,
such as infrastructure investments, higher prices for products without plastic content or that are more
durable, and staff time to conduct waste stream monitoring. Additionally, given staffing limitations,
limited expertise, and to reduce the burden on parks, contracted support may be necessary to conduct
studies, analyze waste management efforts, and monitor impacts.
Implementation Principle 2: Work with partners, internal and external to DOI, to
achieve the Secretarial goal
The NPS will not achieve plastic reduction goals in isolation. Collaboration across parks, regions, and
program offices will ensure key stakeholders are engaged, their expertise informs decisions, and there is
shared responsibility. Engagement and collaboration with commercial service providers (e.g.,
concessioners), contractors and other partners will be needed to identify and execute near and long-
term solutions.
Relationship between the Implementation Principles and Implementation Plan
Given NPS’s size and complexity, a robust decision-making and implementation process will
be needed to ensure that the plan is executed effectively. The four implementation principles
shall inform decisions as the NPS implements its plastic reduction plan, from data collection
through measurement and reporting. For example, when analyzing alternatives to single-use
plastics, NPS will leverage Implementation Principle 3: Prioritize source reduction, by
prioritizing source reduction over compostable, biodegradable, or products that are 100%
recyclable or made from 100% recycled materials. The Implementation Principles are
referenced throughout the Implementation Plan to further underscore how they will be used
during implementation.
4
National Park Service Plastics Elimination and Reduction Strategic Plan
The NPS will also work closely with external partners to develop, phase, and execute actions in the
implementation plan. The NPS will tap into expertise and leverage research and resources of other DOI
bureaus and offices, federal and state agencies, suppliers, gateway communities, non-profits,
universities, and others.
Implementation Principle 3: Prioritize source reduction when developing and
implementing phase-out and reduction policies
Because of the limitations of recycling and the life-cycle environmental and social benefits that are
unlocked by preventing waste at the source (i.e., by avoiding the production of plastic in the first place),
decisions and actions to reduce plastic use in the NPS will prioritize source reduction.
The term “source reduction” derives from the Pollution Prevention Act (PPA) which Congress passed in
1990. Pollution prevention is reducing or eliminating waste at the source by modifying production
processes, promoting the use of nontoxic or less toxic substances, implementing conservation
techniques, and reusing materials rather than putting them into the waste stream. The term also
includes redesign of products and substitution of raw materials. Pursuant to the requirements of PPA,
the Environmental Protection Agency (EPA) has taken the statutory definition of pollution
prevention/source reduction and applied it to specific programs. The EPA’s
Sustainable Materials
Management Program’s Non-Hazardous Materials and Waste Management Hierarchy prioritizes source
reduction and shall guide the elimination of SUP and significant reduction or elimination of other
plastics.
2
The U.S. EPA hierarchy, from most to least preferred, includes:
• Source Reduction and Reuse
• Recycling and Composting
• Energy Recovery
• Treatment and Disposal
2
The EPA is now in the process of reviewing the waste hierarchy to determine if potential changes should be made
based on the latest available data and information. When a new hierarchy is finalized, this plan shall be updated to
reflect any changes.
5
National Park Service Plastics Elimination and Reduction Strategic Plan
Actions at the top of the waste hierarchy should be prioritized before descending the hierarchy. As a
result, actions that reduce waste at the source and encourage reuse practices will be prioritized first and
foremost. Where source reduction and reuse are not currently feasible, recycling and composting should
be prioritized next.
Implementation Principle 4: Apply systems-based and life-cycle approaches
informed by data and science
The NPS shall prioritize systems thinking and life-cycle decision making, informed by the latest science
and data, to achieve its plastic reduction goals.
Systems and Life-Cycle Approach
The NPS will use a systems-thinking approach to identify opportunities for success. Systems thinking
looks at an issue in terms of relationships rather than by splitting it into its individual parts. Part of a
systems approach is to consider the upstream and downstream, or life cycle, impacts of decisions, as
different alternatives have different impacts to climate, land, and water.
As such, life-cycle perspectives, approaches and tools shall guide the NPS in the selection of plastic
alternatives. Components of this approach include:
• Source reduction should be prioritized to achieve life-cycle benefits, per the U.S. EPA Waste
Management Hierarchy and Implementation Principle 3: Prioritize source reduction when
developing and implementing phase-out and reduction policies.
• Alternatives should be chosen based on consideration of multiple aspects (e.g., climate impact,
sourcing from sustainably managed forests, recyclability, toxicity).
• Alternatives that use materials and products that have been designed to be more durable,
reusable, repairable and recyclable at their highest value.
Circular Economy
Both source reduction (Implementation Principle 3) and a systems and life-cycle approach
(Implementation Principle 4) are consistent with a circular economy. As defined by the U.S. EPA, a
circular economy reduces material use, redesigns materials, products, and services to be less
resource intensive, and recaptures “waste” as a resource to manufacture new materials and
products. The Save Our Seas 2.0 Act refers to an economy that:
• uses a systems-focused approach and involves industrial processes and economic activities that
are restorative or regenerative by design,
• enables resources used in such processes and activities to maintain their highest value for as
long as possible, and
• aims for the elimination of waste through the superior design of materials, products, and
systems (including business models).
Source: U.S. Environmental Protection Agency
6
National Park Service Plastics Elimination and Reduction Strategic Plan
• Alternatives should be price competitive but must look at the full cost, not just the initial cost of
the product.
• Alternatives should maximize co-benefits and not create worse or unintended problems.
Science-Driven Approach
The NPS shall use the best, currently available science, and state of research to inform decisions. Vast
expertise, research, and resources have been and are being developed by partners, and the NPS will
look to them for the latest information.
In order to ensure scientific integrity when using science and data to inform decision making during the
implementation of the plastics strategy, the NPS will abide by federal transparency and data integrity
principles and look to guidance from the Scientific Integrity Official per
Presidential Memorandum on
Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking issued in
January, 2021.
Data-Driven Approach
The NPS will leverage existing and future data to be collected to drive decisions about how to prioritize
implementation actions.
See Collect Data for more on data collection and utilization.
7
National Park Service Plastics Elimination and Reduction Strategic Plan
Implementation Strategy
This implementation strategy outlines specific steps for planning and executing plastic reduction efforts
across the NPS. Work on several steps of the implementation strategy will have to occur concurrently.
Plan Schedules and Annual Targets
SO 3407 sets the goal of phasing out SUP on Department-managed lands by 2032. The NPS will pursue
an implementation schedule that aims to meet that goal, ensuring sustained, long-term adoption.
Years 1-2 (2023-2024): Collect Information, Set a Baseline, Analyze Alternatives,
Determine Schedules and Initial Targets, Begin to Update Policies, and Begin to
Initiate Implementation
Collect Information, Establish a Baseline, and Develop a Tool: In the first year of implementation, the
NPS will focus on collection of information and establishment of a baseline for plastic procurement, sale,
and distribution. The NPS will adapt existing reporting mechanisms and/or establish new reporting
mechanisms to collect data and monitor progress on an annual basis. In Year 2, the NPS will implement
a tool to account for plastic being procured, sold, and distributed to track progress toward the ultimate
phase-out.
Analyze Alternatives: Also in the first year, the NPS will conduct an analysis of alternatives to SUP
products. The NPS will then prioritize rollout based on the outcomes of the Plan and Prioritize the
Approach step, to ensure policies and programs have high impact and use resources efficiently.
Define
Scope
Collect
Data
Analyze
Alternatives
Plan &
Prioritize
Develop
Tools
Fund
Implement
Educate
Measure &
Report
NPS Plastic
Elimination
and Reduction
Strategic Plan
8
National Park Service Plastics Elimination and Reduction Strategic Plan
Determine Schedules and Initial Annual Targets: The NPS will determine a timeframe for the policies to
be implemented. Based on the prioritization process in the Plan and Prioritize the Approach section, a
draft schedule for updates to acquisition and procurement policies and practices is:
• High Priority: 6-9 months
• Medium Priority: 9 months to 1 year
• Lower Priority: 1-2 years
The NPS will identify targets—e.g., as percentages or as specific products—based on research and
analysis of alternatives.
Begin to Update Acquisition and Procurement Policies and Practices: The NPS will update acquisition
and procurement policies and practices to reduce SUP and other plastics. The NPS will identify existing
policies that, if changed or enforced, would result in substantial Service-wide impacts and prioritize
updates to those policies. Implementation of changes in established contracts will need to take place at
the time those contracts are up for renewal, but policies to be incorporated into future renewals and
new contracts will be prepared and ready to be deployed. In the meantime, efforts should be made to
modify the contracted activity based on operations and maintenance plans as feasible, provided that the
change is not a material change to the contract operationally or financially.
Begin Implementation of Service-Wide Policy: The NPS and its partners have already started reducing
plastic use, such as through waste management plans, green purchasing programs, and recycling
programs. The Zero Landfill Initiative, a partnership between NPS, the National Parks Conservation
Association, the National Parks Foundation, and Subaru of America, also helps parks reduce plastic use
and increase recycling of all materials through the Don’t Feed the Landfill program. The NPS will
leverage completed pilots and demonstration projects to begin rolling out Service-wide policy and/or
targeted location-specific efforts with a high return on investment. The NPS will ensure that policies and
strategies align with each of the Implementation Principles laid out in this strategic plan and are scaled
to the size and operations of the park.
At the end of Years 1-2, the NPS will affirm current processes and priorities and modify subsequent year
activities as needed.
Years 3-4 (2025-2026): Expand Implementation
During Years 3 through 4, the NPS will further implement strategies and requirements Service-wide,
continue to gather the latest research and studies, and continue to gather metrics and indicators
through reporting mechanisms set up in Years 1-2. Broad-scale deployment will require new funding
sources, so the NPS will continue to commit leadership support to resourcing and continue to work with
partners to expand available funding sources.
Years 5-9 (2027-2031): Full-Scale Deployment
The NPS will deploy successful programs across all NPS operations and park commercial service
providers building upon the efforts initiated in Years 3-4. NPS expects to pick up speed as strategies,
infrastructure, access to vendors, etc. expand and become more mainstreamed across the NPS system
and in the US generally. The NPS will continue to gather information and track progress via the tool
developed in previous years. The NPS will modify its implementation plan to reflect changes in either
9
National Park Service Plastics Elimination and Reduction Strategic Plan
recycling or composting markets, availability of alternatives, or changes in internal process as needed to
ensure the full phase-out will be achieved on schedule.
No Later than Year 10 (2032): Achieve 100% Phase-Out (Elimination) of Single-Use
Plastics
No later than Year 10, the NPS will achieve its goal to phase out 100% of SUP, establish a circular-
economy, and reduce other plastics. The NPS strives to achieve this goal prior to the 2032 year set out in
the SO, based on the GPP goal to achieve net-zero waste.
1. Define Scope and Exemptions
The SO focuses on SUP products that are procured, sold, and distributed by NPS park units. Under the
SO, the term "single-use plastic products" means plastic items intended to be disposed of immediately
after use, including plastic and polystyrene food and beverage containers, bottles, straws, cups, cutlery,
and disposable plastic bags. In parks, these items are typically associated with food service or retail
services and can be generated in either back-of-house (e.g., internal NPS operations, commercial service
providers, or partner operations) or front-of-house (i.e., visitor-facing) operations.
Consistent with the GPP net-zero waste goal, the NPS will also explore reduction of other plastics where
practicable and/or as resources allow even as SUPs are prioritized. Other plastic may include (1) other
problematic and unnecessary plastic (e.g., products with toxic chemicals and black plastics since the
black pigment in black plastic is often not detectable by sorting technologies at recycling facilities), and
(2) plastic that originate outside NPS boundaries, as a study in the three Zero Landfill Initiative pilot
parks (Grand Teton, Denali, and Yosemite National Parks) revealed that two-thirds of visitors disposed of
items brought from outside park boundaries within the parks. NPS will address those plastics specifically
called out in the SO while at the same time addressing waste reduction of other waste streams including
other plastics in accordance with NPS policy. NPS recognizes that efforts to reduce other plastics are
secondary in priority to the SUPs in the SO.
Exemptions
The NPS may make exemptions to the phase out of SUP in certain circumstances. Exemptions may be
made, if necessary, for medical, public safety, public health, or scientific items, or for items for which
there is a well-functioning circular economy.
Short-term exemptions may be made if no alternative products currently exist or if alternative products
are not practical due to supply or other factors. Before short-term exemptions are made, substitute
Common SUP products, named in the SO, include:
• Plastic and polystyrene food and beverage containers,
• Plastic bottles,
• Plastic straws,
• Plastic cups,
• Plastic cutlery, and
• Plastic disposable plastic bags.
10
National Park Service Plastics Elimination and Reduction Strategic Plan
products or processes must be evaluated based on the U.S. EPS’s non-hazardous materials and waste
management hierarchy and steps to identify alternatives to existing plastic product use must be
documented.
Short-term exemptions may also be made for the term of an existing contract if the contract cannot be
modified. However, efforts should be made to modify the contracted activity based on operations and
maintenance plans as feasible, provided that the change is not a material change to the contract
operationally or financially.
The NPS will continually seek to shorten the list of exempted product uses. For example, where short-
term exemptions were made when alternative products were deemed impractical due to supply or
other factors, the exemption will be reassessed as technology improves, supply of alternatives becomes
available, and as practical alternatives emerge.
The NPS will issue separate guidance on who is responsible for seeking and approving exemptions.
Voluntary Efforts Beyond NPS Requirements
For parks, commercial service providers, and partners that want to take plastic elimination or reduction
actions before annual targets are established, they shall collaborate with the Washington D.C. Area
Support Office (WASO) about specific activities for their park unit or property. The NPS will establish a
process for working with parks (e.g., through a superintendent’s request) to approve pilot programs.
The NPS will issue separate guidance for how parks, commercial service providers, and partners can seek
approval by the WASO office for a voluntary pilot.
2. Collect Data
Currently, data on the use and disposal of plastic in the NPS are limited. In line with Implementation
Principle 4: Apply systems-based and life-cycle approaches informed by data and science, the NPS will
collect data to inform decisions and the approach to elimination efforts. This section outlines an
approach to collect information on current plastic use and establish a baseline of both data and current
understanding of plastics generation.
Account for Plastics
Currently, solid waste data are reported for NPS operations via the DOI Solid Waste Management
Database and by concessioners via annual reporting as directed under terms of their contracts, but a
breakout of plastics-specific data are in these reports is relatively limited. The NPS will determine an
appropriate methodology to gather, analyze, and track the plastics profile at parks and utilize this
information to establish a baseline and measure the effectiveness of this effort.
First, the NPS will determine which data on plastic will be collected. Data sources may include:
• Plastics data from the DOI Solid Waste Management (SWM) Database for park operations.
• Plastics data from concessioner environmental management software (EMS) sustainability
reports and/or reporting on solid waste.
• Park-level waste characterization studies (for example, the Zero Landfill Initiative, which
includes extensive data and analysis for three parks).
11
National Park Service Plastics Elimination and Reduction Strategic Plan
• Qualitative data on plastic brought into parks by visitors to understand external sources of
plastic generation and quantitative data, as data are available based on park waste
characterization studies or future studies.
Questions to ask to determine additional data sources include:
• How products are purchased (i.e., purchasing mechanisms, including micro-purchases)
• Who makes the purchase (e.g., park operations, residents, suppliers)?
• How products are distributed (either for end use or for resale, if applicable)?
• Who is the primary end user?
• What is the post-use management (e.g., disposal, reuse, recycling)?
Next, the NPS will determine how data on plastic procurement, sales, and distribution will be collected,
such as by:
• Identifying methods and approaches others have used to collect plastics data.
• Identifying plastic procurement reports available through concessioners or suppliers.
• Developing a standard approach for data collection that can be used if none exists or adapting
existing methods (e.g., expanding the data call in the DOI’s Solid Waste Management Database).
• Developing a tool to track plastic procurement and disposal data in a centralized manner.
• Developing a format for presenting the data to facilitate decision-making by various
stakeholders.
Review Contracts, Concessions, and Procurement Mechanisms
The NPS will review authorizations (e.g., contracts) to identify plastic reduction opportunities and
challenges. Specifically, the NPS will review authorizations related to:
• Contracting and procurement for internal NPS operations including the use of purchase cards.
• Commercial service providers (concession contracts, commercial use authorizations, and leases).
• Grants and Cooperative Agreements (e.g., for other in-park operators such as Residential
Environmental Learning Centers Learning Centers [RELCs] and Cooperating Associations).
• Special Park Uses (e.g., for special events, rallies, and demonstrations).
• Scope of Sales for Cooperating Associations and Partnerships held at the park-level.
The NPS will develop a protocol for collecting and maintaining basic information for the various
categories of contract and procurement mechanisms identified above. The NPS will also develop a
format for collecting this information and determine how it will be presented to facilitate decision-
making by various stakeholders.
12
National Park Service Plastics Elimination and Reduction Strategic Plan
Review Existing or Planned Work to Address Plastic Reduction
The NPS has several ongoing or planned programs, pilots, case studies, initiatives, and/or policies that
address elimination and/or significant reduction of the purchase, use and disposal of SUP products as
well as other plastics. The NPS will gather information about these programs to understand current
efforts and their impacts across different settings in parks (e.g., back-of-house, front-of house,
campgrounds, stores) and synthesize best practices and lessons learned. To further identify best
practices, the NPS will also review successful efforts to reduce single use plastics made by external
entities, such as local governments, universities, and the private sector.
The inventory should include projects from:
• NPS parks and regions
• Other bureaus within DOI
• Other federal agencies
• State and local governments
• Large institutions such as universities
• Private sector
• Other countries (e.g., European Union Directive on SUP, United Kingdom ban on SUP)
For these projects, data collection will include the following to the extent feasible:
• Information about innovative acquisition and procurement strategies and policies.
• Information about innovative circular economy/waste management strategies and policies (e.g.,
extended producer responsibility).
• Infrastructure needs and how they were addressed.
• How organizations prioritized their efforts.
• How environmental justice was considered.
• Lessons learned.
The NPS will rely on existing compilation of projects on plastics as much as possible, particularly for
those outside of the NPS and DOI.
3. Analyze Alternatives
The NPS will conduct an analysis of alternatives to plastic products. Per SO 3407, alternatives may
include compostable or biodegradable materials, or 100 percent recyclable or 100 percent recycled
materials (with a circular economy plan) as defined in section 2 of the Save Our Seas 2.0 Act.
Per Implementation Principle 3: Prioritize source reduction, the NPS will prioritize source reduction over
compostable, biodegradable, or products that are 100% recyclable or made from 100% recycled
materials. In addition, per Implementation Principle 4: Apply systems-based and life-cycle approaches
informed by data and science, the NPS will analyze alternatives from a life-cycle perspective, based on
multi-attribute decision making, and based on the existing science and data.
13
National Park Service Plastics Elimination and Reduction Strategic Plan
To determine SUP alternatives, the NPS will:
• Leverage commercial service providers and partners’ expertise to gather information on
alternatives, in particular those that have already transitioned to alternatives in many parks (per
Implementation Principle 2: Work with partners, internal and external to DOI, to achieve the
Secretarial goal).
• Rely on Department-level or other federal agencies’ (e.g., EPA, GSA, or USDA) analyses and
research on alternatives to plastic products.
• Review science-based recommendations and employ results of life-cycle analyses and tools such
as the Understanding Packaging Scorecard
.
• Develop an annotated list of resources, including existing reports and case studies on
alternatives.
• Draw from alternative systems and products that have been used in pilot projects
• Investigate operational alternatives that result in lower use of single use plastics (e.g., plastics in
materials handling), in addition to one-for-one product alternatives.
• Identify a graphic, or develop a graphic if one does not exist, that shows the various entities that
impact the manufacture, distribution, purchase, use and management of SUPs and other
plastics, the processes involved, and disposal pathways. This graphic will help the NPS and its
partners understand the inputs and outputs of plastic use in the NPS and how different
alternative systems and products might be most effective within the life cycle.
4. Plan and Prioritize the Approach
The goal to phase out SUP and to reduce or phase out other plastics will require interim steps and
iterative efforts. Progress will require prioritizing efforts, setting realistic goals, planning for
implementation, establishing a feedback loop, and fostering strong commitment at all levels of the
organization. Active participation by parks, employees, commercial service providers, partners, and
visitors will contribute to the success of the plan. Below are areas where the NPS will establish priorities.
Apply Decision Criteria
The NPS will develop a decision matrix to determine which products to target for reduction and
elimination first. For example, the decision matrix may consider criteria that target:
• Products that are most impactful to climate change and the environment.
• Products with toxic chemicals.
• Products that hinder or disrupt the recyclability or compostability of other items.
• Products with the highest likelihood of litter or ending up in the environment.
• Products that have established or ongoing promising practices at a park or parks.
• Products that have sustainable alternatives which are readily available and are price-
competitive.
These criteria reflect the need to understand each of the products from a life-cycle and systems
perspective.
14
National Park Service Plastics Elimination and Reduction Strategic Plan
Prioritize Products and Operations
Based on the decision criteria above, the NPS will develop a list of high-, medium-, and low-priority
plastic product streams and operations to address via specific strategies. The NPS will develop a timeline
to address each category of products based on this prioritization. For each category of products, the NPS
will assess applicable best practices and strategies from the Collect Data step above, and determine
geographic priorities (e.g., whether to roll out elimination efforts Service-wide, in particular regions, or
by park or operations type). Ultimately, this prioritization should balance maximizing the impact of
efforts with implementing low-hanging fruit.
Identify Infrastructure Needs
The NPS and its partners will identify and catalog the infrastructure needs, including reducing plastic use
at the source and ensuring that alternatives are diverted from landfill. Infrastructure may be needed to:
• Support reuse systems (e.g., water bottle refill station, dishwashing infrastructure).
• Improve waste collection systems and equipment to contribute to a robust and healthy
secondary recycling materials market.
• Explore new technologies for waste reduction.
• Improve visitor education (e.g., pre-trip planning and better signage).
• Improve composting programs to divert bio-based and compostable alternatives to plastic from
landfills.
• Coordinate with local gateway communities on infrastructure solutions.
Learn from Partners and Other Bureaus
NPS commercial services providers such as concessioners and leaseholders, and other partners, such as
cooperating associations, have already implemented many innovative plastics reduction and waste
management solutions. The NPS will continue to leverage their expertise as they identify solutions and
collaborate with them for use throughout the Park Service.
Further, the NPS will work collaboratively with other bureaus and agencies to develop expertise on
different strategies based on the main types of plastic each group generates and share those strategies.
For example, DOI has already established a collaborative workgroup related to plastic reduction which
includes NPS Sustainable Operations and Maintenance Branch (SOMB) and Commercial Services
Program. Sharing strategies will advance the goal of combining purchasing power to move the market
towards elimination and alternatives.
Develop Contingency Plans
As demonstrated during the COVID pandemic, natural disasters or other circumstances may cause a
disruption in normal operations either in the short-term or for extended periods. The NPS and its
partners should stipulate the continued prioritization of source reduction, reuse, and plastics
alternatives in contingency plans for unforeseen events and disasters.
If, per Implementation Principle 4: Apply systems-based and life-cycle approaches informed by data and
science, there is a need to revert to the use of plastic to protect public health and safety, efforts should
reinstate plastic reduction efforts as soon as possible after the resolution of the event.
15
National Park Service Plastics Elimination and Reduction Strategic Plan
5. Develop Tools and Resources
The NPS will develop tools and resources (e.g., data collection templates, model language for concession
contracts, sample implementation plans, outreach materials) to aid parks in the implementation of
plastic reduction strategies and initiatives. The NPS will create a central repository, such as a SharePoint
site, to house existing tools and resources, as well as other tools and resources to be developed. The
central repository can also link to other existing SharePoint sites, such as the Zero Landfill Initiative’s
SharePoint site.
Access to these tools and resources through the central repository will be critical for seeking input on
and socializing new policies, sharing best practices as Service-wide policies go into action, and sharing
the latest science and research.
The NPS will continually add to the available resources to reflect the latest set of successful programs
and research, ensuring that all information is up to date.
6. Fund the Work
Funding will be required throughout implementation, from data collection, tracking, and reporting to
infrastructure projects. Broad-scale deployment will require new funding sources, so the NPS will
continue to commit leadership support to resourcing and continue to work with partners to expand
available funding sources.
The NPS will develop a strategy to fund and execute park plastic reduction efforts based upon its
assessment of opportunities. Examples of possible efforts which will require funding include:
• Conducting a baseline study of the generation of plastic and ongoing studies to monitor how
plastic reduction efforts impact plastic generation over time.
• Staff positions dedicated to in-park project coordination for sustainability efforts, as staff will be
one of the greatest NPS assets for implementation.
• Infrastructure projects, such as water bottle refill stations, reuse programs, and recycling
infrastructure.
The NPS will seek funding through traditional appropriations process and from philanthropic partners
such as:
• Funding from park partners like the National Park Foundation (NPF) and Friends groups.
• Funding partnerships with universities to support data collection, data analysis, and research.
• Research internship programs to support data and research efforts.
To facilitate the identification and execution of funding, the NPS will develop strategies and tools for
parks to use to seek funding or form partnerships to carry out aspects of implementation plans.
7. Implement the Plan
Based on the steps above, the NPS will implement the identified strategies, guided by the
Implementation Principles and established schedules and targets. Implementation will include updates
to authorizations (e.g., contracts); implementation of policies for source reduction; and other strategies
16
National Park Service Plastics Elimination and Reduction Strategic Plan
to eliminate SUP and reduce other plastic at all stages of the supply chain. Throughout implementation,
the NPS will evaluate the effectiveness of strategies and further hone its approach to address
stakeholder feedback, encourage adoption of strategies, identify efficiencies and economies of scale,
identify barriers to adoption, and improve outcomes.
Given the different material streams and activities leading to the procurement and use of plastic, the
NPS will need to take a diversified approach based on product type and entity. A single strategy may not
work for all products so there will need to be a mix of strategies for different products or groups of
products.
Adopt Policies and Programs Service-Wide
The NPS will prioritize policies or programs that can be adopted Service-wide and/or targeted location-
specific efforts that have a high return on investment. Examples of policies to examine for possible
Service-wide adoption include:
• Implementing a reusable product system for plastic items, such as refillable water bottles and
reusable food serviceware and drinkware.
• Implementing phase-out schedules on certain products as determined based on research and
assessment of alternatives.
• Conducting pre-trip and in-park outreach and education for certain visitor behaviors (e.g.,
discouraging bringing SUP into parks; encouraging use of water refill stations and reusable hot
beverage containers; encouraging proper sorting for recycling or composting).
• Requiring consistent, universal labels and signage about the phase out of SUP and reduction of
other plastic products, including clear labeling on what products and materials can be recycled
or composted.
• Strengthening push and pull policies to reinforce recycled plastics markets (e.g., ensuring a
supply of high value secondary plastics through better collection of contamination-free
materials and increasing the purchase of recycled content products).
• Requiring Grants and Cooperative Agreements recipients and other partners in parks to phase
out the purchase of SUP and reduce the purchase of other plastic, if using funds from the NPS.
• Revising Scope of Sales templates and guidance to require phasing out the purchase of SUP and
reduce the purchase of other plastic.
• Conducting pilots, where appropriate, to test approaches and create case studies to learn from.
This is not a comprehensive list; consideration of which policies to include for the prioritization exercise
should be based on initial and ongoing information gathering and monitoring of progress.
After a list of policies is developed, the Implementation Principles should guide the criteria used for
implementation.
17
National Park Service Plastics Elimination and Reduction Strategic Plan
Apply Plastic Reduction to Commercial Services Provider Authorizations
The NPS will apply these plastic-reduction strategies for service providers with authorizations to
operating on the parks. Prioritization of implementation of these contract changes may be based on:
• Authorizations with best market/economic potential for procuring single-use plastic alternatives
(e.g., high value contracts; large market share; opportunities to combine purchasing power with
another bureau, agency, or department).
• Authorizations with relative high amounts of plastic procurement.
• Authorizations with products that have high quantities of plastic packaging or plastic used for
transport (e.g., plastic wrap around pallets)
• Authorizations that are up for renewal (versus contracts already issued where there may be
limitations to requiring the contracted entity to adopt plastic reduction practices although they
may be encouraged).
• Other criteria based on initial and ongoing information gathered.
8. Conduct Outreach and Education to Shift Public Behavior
Outreach and education to NPS employees, residents, partners, and visitors will be critical to the success
of this plan, as employees and visitors are a predominant source of plastic generation in the NPS. This
section details strategies and best practices for engaging ad collaborating with these target audiences.
Employee and Partner Engagement and Culture
Training and engagement of employees of NPS, commercial service providers, and partners will be
critical to achieving the goals of this initiative. To this end, the NPS will identify and implement strategies
to engage employees.
Strategies may include:
• Developing materials to encourage in-park employees to reduce plastic use and increase
recycling of plastics and plastic alternatives (e.g., glass or aluminum) and composting in work as
well as in residential settings.
• Connecting messaging about plastic reduction to other park messages, such as protecting
wildlife or historical sites, to make communication consistent and reinforce familiar messages
that build on shared values.
• Connecting plastic reduction to other organizational goals, plans, and requirements.
• Providing training on plastic reduction efforts to both permanent and seasonal employees as
well as to commercial service providers and partners, including both in-person and virtual
webinar trainings.
• Seeking employee input and ideas on projects and programs to eliminate SUP and reduce the
use of other plastic.
• Understanding what types of plastics employees bring into the park and ways to reduce that
source of plastic generation, such as investigating opportunities for collaboration within
gateway communities and businesses to reduce plastic commodities coming into parks.
18
National Park Service Plastics Elimination and Reduction Strategic Plan
Organizations, including the NPS, often rely on employee champions who are passionate about
environmental and social issues to initiate and execute sustainability efforts. While champions are great
assets to the NPS, the NPS must incorporate plastic reduction (and other sustainability) goals into the
normal workflow of all employees.
Visitor Outreach and Education
Visitor outreach and education is another crucial component of reducing plastic use. Plastics in parks is
generated through in-park sales and is also brought in by visitors from outside the park. Maximizing
plastic reduction efforts will require varied approaches to visitor outreach and education. Strategies may
include:
• Understanding the explicit details of what types of plastics visitors bring into the parks to
provide targeted outreach and education for these types of plastics.
• Updating and enhancing online trip planning resources to prepare visitors for NPS-wide efforts
to reduce plastic and eliminate SUP, along with zero-waste and pack-it-in, pack-it-out policies,
and bringing their own water bottle.
• Developing information and messaging specific to the plastic reduction initiative and providing it
to prospective visitors (e.g., 5 things visitors can do now to help with this effort).
• Providing visitor choice plastic reduction strategies (e.g., provision of water bottle filling
stations, low-cost reusable water bottles, dry mix for energy drinks, more recyclable packaging
such as beverages in aluminum bottles), and then educating visitors about their options
available within the park for alternative product purchases and reuse programs and why their
choices matter (e.g., established recycling processes and markets and for recycled aluminum).
• Developing and sharing resources for interpretative rangers, including resources for the Junior
Ranger programs and visitor center displays and activities.
• Standardizing signage and labeling on recycling, composting, and waste receptacles throughout
offices, parks, and commercial service provider operations to ensure recyclable and
compostable materials stay out of the landfill and remain in the circular economy.
Outreach and Education Best Practices
Since different audiences respond to different types of messaging, outreach and education must be
tailored to the specific audience. The NPS will leverage studies that demonstrate which specific
messages resonate with different audiences to influence behavior change most effectively. For example,
the results of a study at three national parks found that messages emphasizing ease concepts were two
times more effective at changing campground visitor waste disposal behaviors than control conditions
(Taff et al., 2022). To implement these outreach and education efforts, The NPS works collaboratively
with its commercial service providers and partners to align messaging and strategies.
9. Measure and Report
The NPS will implement measurement and reporting practices to track progress towards plastics
reduction goals.
19
National Park Service Plastics Elimination and Reduction Strategic Plan
Measurement
Based on the information and data gathered under Collect Data, the NPS will develop appropriate and
replicable measurement techniques to estimate the amount of plastics procured, sold, and distributed
in waste streams.
The NPS will track standardized metrics for both plastic waste and procurement data. The NPS will
develop standardized metrics; a starting list may include:
• Overall estimate of plastic generation, as shown in waste streams, by NPS operations, by
commercial service providers and partners, and from sources outside park boundaries.
• Plastic procurement data by NPS operations and commercial service providers and partners
3
.
• Percentage of NPS park unit operations and commercial services providers and partners that
have transitioned to plastic alternatives, reuse systems, etc.
• Percentage of commercial services providers and partners that have clauses requiring SUP
phaseout; other plastic reduction, where practicable; and data tracking on plastic procurement.
• Percentage of suppliers that have committed to phasing out plastic in packaging.
Evaluating the makeup of the NPS’s waste streams will provide a holistic picture of what is being
procured, sold and distributed by the NPS as well as what is being brought into parks from outside park
boundaries to help inform decisions. The NPS will utilize waste characterization studies as available for
park, concessions, and partner operations to determine current park plastic waste profiles, and to
collect ongoing samples at select parks to monitor the impact of plastic reduction efforts. Data from
waste characterization studies can be used to extrapolate systemwide plastic generation and diversion
rates and monitor plastic reduction performance over time.
A limitation of waste characterization studies is their inability to attribute waste to the generator (i.e.,
whether the item was sold in the park or brought in from outside the park boundary). Similarly, they can
be resource-intensive so should be used when best able to inform decision-making and program design
and should not delay the other implementation steps. Where waste characterization studies are not
feasible, the NPS will use existing studies (e.g., waste characterization studies at similar parks or local
entities) to estimate this information.
Observational studies can also be conducted to observe procurement and waste-related behavior, such
as documenting products sold in stores or provided in lodging and observing visitor sorting behavior at
waste receptables.
Measurement practices may also involve exploring the climate change and carbon reduction impacts of
plastic reduction efforts (e.g., reduced hauling).
3
The ability to obtain waste and procurement data is dependent upon the authorization type and the terms of the
authorization. The NPS has the authority in the standard contract to obtain reports determined necessary by the
Service. The NPS is sensitive to the burden that can be placed on commercial service providers through various
data and report requests. The NPS would coordinate and collaborate with them to ensure that the information
being collected is needed and can be accomplished in a manner as efficient as possible.
20
National Park Service Plastics Elimination and Reduction Strategic Plan
Reporting
Parks report annually on park-generated waste to the DOI Solid Waste Management Database and
concessioners report solid waste data under the terms of their contracts. Reporting requirements and
mechanisms will need to evolve as the plastics reduction strategy is implemented. In particular, the NPS
will centralize existing reporting mechanisms as well as additional reporting mechanisms from the
various stakeholders, including the NPS, commercial service providers, and partners.
The NPS will prepare annual reports tracking progress toward plastic reduction goals and modify its
reduction plans as needed to continuously improve.
21
National Park Service Plastics Elimination and Reduction Strategic Plan
Appendices
Appendix 1: Secretary Order No: 3407 Department-Wide Approach to Reducing
Plastic Pollution
22
National Park Service Plastics Elimination and Reduction Strategic Plan
23
National Park Service Plastics Elimination and Reduction Strategic Plan
24
National Park Service Plastics Elimination and Reduction Strategic Plan
Appendix 2: Implementation Guidance: Secretary Order No: 3407 Department-Wide
Approach to Reducing Plastic Pollution
25
National Park Service Plastics Elimination and Reduction Strategic Plan
26
National Park Service Plastics Elimination and Reduction Strategic Plan
Appendix 3: Glossary of Terms
Circular Economy: A circular economy reduces material use, redesigns materials, products, and services
to be less resource intensive, and recaptures “waste” as a resource to manufacture new materials and
products. The Save Our Seas 2.0 Act refers to an economy that uses a systems-focused approach and
involves industrial processes and economic activities that are restorative or regenerative by design,
enables resources used in such processes and activities to maintain their highest value for as long as
possible, and aims for the elimination of waste through the superior design of materials, products, and
systems (including business models). It is a change to the model in which resources are mined, made
into products, and then become waste. (Source: U.S. Environmental Protection Agency,
https://www.epa.gov/recyclingstrategy/what-circular-economy
).
Commercial Service Providers: NPS commercial service providers, consisting of concessioners,
leaseholders, and commercial use authorization holders.
Commercial Visitor Services
4
are authorized under a concession contract or commercial use
authorization in accordance with P.L. 89-249 issued in 1965 (the 65 Act) and P.L. 105-391 issued in 1998
(the 98 Act) (recodified in Title 54 U.S.C. Chapter 1019) and regulations at 36 CFR 51. Concession
contracts provide commercial visitor services that are determined to be necessary and appropriate for
public use and enjoyment of park units. There are about 500 concession contracts. Many of these
activities, such as lodging, food and beverage and retail services, involve SUP and contribute to park
solid waste streams. Commercial Use Authorizations (CUAs) may be issued for commercial services
which are appropriate, but not necessary, and which have a minimal impact on the resources and values
of the park unit. CUAs provide a wide variety of services including guided hiking, rafting, backpacking,
bicycle tours, climbing, and kayaking, as well as equipment rentals, transportation services including air
taxi and water taxis, and food trucks. Occasionally CUA holders may have facilities assigned to them as
part of their operations. There are over 6,000 CUA-holders and their operations may at times include
direct or incidental food service and other activities that could involve SUP. Leases are issued by the
NPS as an adaptive means to reuse NPS facilities no longer necessary for the Service's use. Leases are
authorized in accordance with the NPS General Leasing Authority contained in 54 U.S.C. 1021 and the
Historic Leasing Authority, 54 U.S.C. 306121. Services offered by a leaseholder must be appropriate but
are not necessary. They may include visitor services such as lodging, restaurants and retail. They may
also provide services that are not used by park visitors such as office space or private residences. Many
of these services utilize SUP and other plastic.
Cooperating Associations are private, non-profit corporations which support the education, scientific,
historical, and interpretative activities of the NPS in a variety of ways (e.g., form Management
Policies). One such way is through the assignment of space, or a building and operation of park retail
stores, often located in the park visitor center. Several cooperating associations operate in multiple
parks, while others operate only in one park. In addition to selling interpretive items, they may also hold
4
For the purpose of this document, leases are grouped under commercial visitor services, as the leases that would
be most affected by a plastic reduction strategy are those that provide services to visitors (e.g., hotels,
restaurants).
27
National Park Service Plastics Elimination and Reduction Strategic Plan
a CUA or a concession contract to sell convenience items such as sunscreen, insect repellant, toilet
paper, and bottled water, etc. These retail activities may involve the use of SUP and other plastic.
Interagency Agreements: Some other agencies may utilize NPS facilities under an Interagency
Agreement. These organizations may utilize SUP or other plastic, and contribute to NPS solid waste
streams.
Pollution Prevention: Pollution prevention is reducing or eliminating waste at the source by modifying
production processes, promoting the use of nontoxic or less toxic substances, implementing
conservation techniques, and reusing materials rather than putting them into the waste stream.
Problematic and Unnecessary Plastic: Plastic packaging items, components, or materials where
consumption could be avoided through elimination, reuse or replacement and items that, post
consumption, commonly do not enter the recycling and/or composting systems, or where they do, are
detrimental to the recycling or composting system due to their format, composition, or size. (Source:
U.S. Plastics Pact’s Problematic and Unnecessary Materials Report
)
Residential Environmental Learning Centers (RELCs):
5
RELCS provide benefits to scientists, educators,
youth programs and visitors though permitting, guidance on field work, providing science education
programs and other activities. There are 18 RELCs in the NPS. Many RELCs are provided with park
facilities to operate including housing and food service. Some centers are authorized through a
cooperative agreement to operate an RELC for both educational purposes and for other revenue
generating activities events such as weddings and receptions.
6
Single-Use Plastics (SUP): Plastic items intended to be disposed of immediately after use, including
plastic and polystyrene food and beverage containers, bottles, straws, cups, cutlery, and disposable
plastic bags. (Source: Secretarial Order 3407
)
Source Reduction: The term “source reduction” derives from the Pollution Prevention Act (PPA) which
Congress passed in 1990. Pollution prevention is reducing or eliminating waste at the source by
modifying production processes, promoting the use of nontoxic or less toxic substances, implementing
conservation techniques, and reusing materials rather than putting them into the waste stream. The
term also includes redesign of products and substitution of raw materials. Pursuant to the requirements
of PPA, EPA has taken the statutory definition of pollution prevention/source reduction and applied it to
specific programs. This includes the Sustainable Materials Management Program’s Non-Hazardous
Materials and Waste Management Hierarchy which the NPS Strategy references and relies upon. The
hierarchy prioritizes source reduction.
Special Park Uses are issued for activities in parks the provide a benefit to an individual, group, or
organization rather than the public at large and which are not initiated, sponsored, or conducted by the
Service and are not concessions, CUA or lease activities or recreation activities for which the NPS
charges a fee. These may include activities such as weddings, road-races, and others. These activities,
5
The name RELCs is under review and may change to "Outdoor Schools" in the future. This document will be
updated if this change occurs.
6
Recent decisions with Financial Assistance (FA) are that the legal mechanisms for operating an RELC for both
educational purposes and for other revenue generating activities will primarily be a cooperative agreement, not
Commercial Use Authorizations or Special Park Uses, except in very specific instances.
28
National Park Service Plastics Elimination and Reduction Strategic Plan
largely conducted without NPS direct oversight may include the use of SUP and other plastic, and
contribute to NPS solid waste streams.
Appendix 4: Rules, Regulations, and Guidance
Several policies include requirements and authorization for the NPS to reduce plastics. This section
provides an overview of relevant rules, regulations, policies, and guidance that support the elimination
of SUP and waste reduction efforts in the NPS.
• Executive Order 14057— Catalyzing Clean Energy Industries and Jobs Through Federal
Sustainability. released in December 2021 by the Biden Administration, sets a goal to annually
divert from landfills at least 50 percent of non-hazardous solid waste, including food and
compostable material, and construction and demolition waste and debris by fiscal year 2025;
and 75 percent by fiscal year 2030. In addition, the EO calls for agencies to prioritize products
that can be reused, refurbished, or recycled.
• Secretarial Order 3407— Department-Wide Approach to Reducing Plastic Pollution. SO 3407
prioritizes Department action to reduce the procurement, sale, and distribution of SUP products
from current levels with a goal of phasing out SUP products by 2032. "Single-use plastic
products" means plastic items intended to be disposed of immediately after use, including
plastic and polystyrene food and beverage containers, bottles, straws, cups, cutlery, and
disposable plastic bags.
• Departmental Manual, Part 518: Waste Management, Chapter 1: Comprehensive Waste
Management. 518 DM 1 prescribes policy, responsibilities and functions related to management
of solid and hazardous materials, and certain hazardous substances. The policy outlines four
principles for comprehensive waste management:
a) Wherever feasible, the Department will seek to prevent the generation and acquisition
of hazardous wastes.
b) Whenever waste generation is unavoidable, the Department will work to reduce the
amounts (toxicity or risk) generated through the use of sound waste management
practices.
c) The Department will manage waste materials responsibly to protect not only the
resources entrusted to it, but the many people who live and work on Departmental
managed lands, and those who enjoy those lands and facilities each year.
d) Wherever feasible, the Department will move aggressively to clean up and restore areas
under its care that are contaminated by pollution.
The requirements are applicable to all Departmentally managed lands and facilities including
with external groups such as concessionaires, contractors, permittees, and lessees.
• Departmental Manual, Part 515: Environmental Management, Chapter 3: Recycling Programs.
515 DM 3 provides policy, responsibilities and functions related to recycling programs. The
policy requires each bureau and office to develop, implement and conduct a thorough recycling
program to:
a) Assure compliance with all applicable Federal, State and local requirements.
b) Promote sound environmental practices by preventing pollution and recovering
resources through recycling.
29
National Park Service Plastics Elimination and Reduction Strategic Plan
c) Educate and monitor for recycling participation at all activities (including
concessionaires, contractors and others).
d) Identify and assign recycling responsibilities.
The policy outlines certain program criteria, e.g., specifying that the programs should be as
inclusive as practicable to allow for maximum employee participation and collection of the
widest number of resources. The policy also details the different categories of proceeds from
recycling and how these proceeds can and cannot be used.
• NPS 2006 Management Policies: The Guide to Managing the National Park System. NPS 2006
Management Policies is the Service-wide document that sets out the laws, policy, and other
guidance for stewardship of the national park system and NPS programs. Highest of three levels
of guidance documents in the NPS Directives System, adherence to policy is mandatory. Meant
to inform all management decisions, the document outlines all aspects of NPS functions and
responsibilities including park management, park system planning, land protection, natural
resource management, cultural resource management, wilderness preservation and
management, interpretation and education, use of the parks, park facilities, and commercial
visitor services. The policy document addresses only those policies applicable to management of
the national park system and does not address NPS-administered programs that serve
conservation and recreation but are not directly related to the national park system (e.g., The
Rivers, Trails and Conservation Assistance Program, National Historic Landmark Program,
National Register of Historic Places, etc.).
• NPS Green Parks Plan (GPP). The Green Parks Plan provides a sustainability vision for NPS
operations across 10 goal areas, including a goal to Buy Green and Reduce, Reuse, and Recycle.
Specifically, the GPP calls for the NPS to achieve a 50% annual diversion rate across the agency.
• Federal Acquisition Regulations (FAR) Part 23. FAR Part 23 details the environmental and
occupational safety aspects of Federal Acquisitions. This includes Sustainable acquisition policy,
energy and water efficiency and renewable energy, the use of recovered materials and biobased
products, contracting for environmentally preferable products and services, and ozone depleting
substances and greenhouse gases.
• Federal Acquisition Regulations (FAR) Part 52. FAR Part 52 Contains the required contract
clauses for biobased product certification, affirmative procurement, recovered material
certifications, EPA-designated item recovered material content, energy efficiency, and service
and construction contracts.
• Save Our Seas 2.0 Act. This Act, signed into law in December 2020, seeks to enhance the United
States’ domestic programs to address marine debris, international engagement to combat
marine debris, and domestic infrastructure to prevent marine debris.
30
National Park Service Plastics Elimination and Reduction Strategic Plan
Appendix 5: Applying the Waste Management Hierarchy
This U.S. EPA materials management hierarchy
7
serves as an approach to implementation. The actions in
this Appendix are under development will be updated as more practices and strategies are developed
and/or identified through research and pilot projects.
Source Reduction and Reuse
• Eliminate the need (e.g., by changing a process or practice that requires SUP).
• Purchase and use more durable products.
• Adjust practices and develop infrastructure to allow for reuse options.
• Find and use non-single use plastic alternatives.
• Purchase in bulk and reduce or eliminate plastic and other packaging.
• Request that manufacturers redesign products to eliminate plastic
• Purchase items with packaging that have been light-weighted.
Applying these types of practices within the NPS would require looking for opportunities with:
• FAR contracts
o Large contracts
o Micro purchases
• Commercial Services contracts.
o Leases - Note: Leaseholders are given a property right to use facilities and the NPS does
not typically dictate significant operational requirements on leaseholders. Thus,
consultation with leaseholders will involve awareness and education.
o Commercial service provider contracts. Purchase of recycled goods.
o Commercial Use Authorizations
• Public Behavior. Conduct visitor outreach through NPS-wide and park-wide social media
encouraging visitors to avoid bringing plastics into parks.
7
The EPA is now in the process of reviewing the waste hierarchy to determine if potential changes should be made
based on the latest available data and information. When a new hierarchy is finalized, the NPS will update this plan
to reflect any changes.
31
National Park Service Plastics Elimination and Reduction Strategic Plan
• Product replacement. Find and use alternatives to products that contain plastic.
• Operations. Look for opportunities to reuse or fix things rather than replace.
Recycling and Composting
• Double-check to see if any of the above strategies can be applied before moving to this stage in
the hierarchy.
• Purchase plastic products that can be easily recycled and are locally recycled.
• Purchase compostable products as an alternative to single use plastic products. Not all biobased
products are compostable so make sure that the item can be composted.
Applying these types of practices within the NPS would require looking at:
• Operations
o Purchase recycled, recyclable or compostable products.
o Identify and socialize funding streams (e.g., Environmental Management Program,
National Parks Foundation, and DOI) for recycling or composting infrastructure (e.g.,
compactors and trailers) and employees’ salaries.
o Find partners with which to partner in recycling operations (e.g., DOD and big-box
stores).
o Find markets for recycling or composting.
• Commercial service provider contracts. Increase recycling or composting. Require purchase of
recycled, compostable, or recyclable products.
• Public Behavior. Encourage proper recycling and composting at parks through signage and
infrastructure.
Energy Recovery
• Energy recovery from waste is the conversion of non-recyclable waste materials into usable
heat, electricity, or fuel through a variety of processes, including combustion, gasification,
pyrolization, anaerobic digestion, and landfill gas (LFG) recovery.
Treatment and Disposal
• Least desirable management option. Prior to disposal, treatment can help reduce the volume
and toxicity of waste. Treatments can be physical (e.g., shredding), chemical (e.g., incineration),
and biological (e.g., anaerobic digestor).
Appendix 6: Single Use Plastic Alternatives
This appendix, currently under development, will provide common single-use plastic alternatives and
case studies from implementation of single use plastic transitions from across the NPS. Some examples
include the Be Straw Free campaign; sales of reusable water bottles and water in aluminum bottles and
paper cartons; installation of water bottle refilling stations; elimination of plastic utensils and Styrofoam
products; elimination of single-use toiletry products in plastic containers in hotels; new and improved
electronic/battery recycling; and implementation of zero-waste strategies.
32
National Park Service Plastics Elimination and Reduction Strategic Plan
Appendix 7. Crosswalk between This Plan and the DOI Template for Sustainable Procurement Plan
DOI Template Section
Name
DOI Template Section Description NPS Plastics Reduction
Strategic Plan &
Implementation
Strategy
NPS Section Description
1. Executive Summary This paragraph includes a summary of the
Bureau/Office Sustainable plan.
Executive Summary. This section includes a summary of NPS's
plan.
2. Schedules and
Annual Targets
Addressing the
Reduction of
Procurement, Sale, And
Distribution of Single-
Use Plastic Products
This paragraph includes the bureau
schedules and targets to make annual
progress toward reducing the
procurement, sale, and distribution of
single-use plastic products from current
levels with a goal of phasing out single-
use plastic products by 2032. If a review
of contracts, concessions, and
procurement mechanisms to identify
single-use plastic product reduction
opportunities and challenges has not yet
been done, include plans to complete in
this section.
Section: Plan Schedules
and Annual Targets.
This section includes NPS's year by year
schedule, including NPS's plan to set a
baseline and then determine a schedule and
initial annual targets in Year 1 (2023/2024).
The review of contracts, concessions, and
procurement mechanisms will be done under
the Collect Data step and is planned for Year
1 (2023-2024).
3. Updates to
Acquisition and
Procurement Policies
and Practices
This paragraph includes schedules for
updates to acquisition and procurement
policies and practices to reduce single-
use plastic products.
Section 7. Implement
the Plan.
This section includes NPS's plan to implement
updates to procurement policies as well as
apply plastic-reduction strategies to
authorizations (e.g., contracts).
33
National Park Service Plastics Elimination and Reduction Strategic Plan
4. Data collection
methods, metrics, and
reporting requirements
to reflect the specific
approaches proposed
to phase out single-use
plastics by the end of
2032
This paragraph includes a schedule for
reporting on how they will phase out
single use plastic products by 2032.
Section 2. Collect Data
and Section 9. Measure
and Report.
The Collect Data section includes NPS's plan
for establishing a plastics data baseline and
the Measure and Report section includes
NPS's plan to develop and track standardized
metrics to track progress. The Plan Schedules
and Annual Targets section indicates that
data collection and setting of the baseline will
incur in Year 1 (2023-2024).
5. Analysis of
Alternatives to Single-
Use Plastic Products
This paragraph includes an analysis of
alternatives to single-use plastic
products, such as compostable or
biodegradable materials, or 100 percent
recyclable or 100 percent recycled
materials (with a circular economy plan)
as defined in section 2 of the Save Our
Seas 2.0 Act (Public Law 116-224).
Section 3. Analyze
Alternatives to Single-
Use Plastics
This section includes NPS's approach to
conducting an analysis of alternatives to
plastic products. For example, NPS will
prioritize source reduction (Implementation
Principle 3), will analyze alternatives from a
life-cycle perspective (Implementation
Principle 4), and will leverage other federal
agency and partner research
(Implementation Principle 2).
6. Opportunities to
Shift Public Behavior to
Reduce Single-Use
Plastic Products
This paragraph includes an approach to
identify opportunities to shift public
behavior to reduce single-use plastic
products, such as installing additional
water fountains and reusable water
bottle filling stations.
Section 8. Conduct
Outreach and Education
to Shift Public Behavior
This section includes NPS's approach to
identifying opportunities to shift public
behavior to reduce SUPs.
7. Single-Use Plastic
Short-Term
Exemptions, If No
Alternatives Currently
Exist
This paragraph includes short-term
exemptions if no alternatives currently
exist, or for the term of an existing
concession or procurement contract, if
justification is provided.
Section 1. Define Scope
& Exemptions
This section explains when short-term
exemptions may be made, if justification is
provided.
34
National Park Service Plastics Elimination and Reduction Strategic Plan
8. Single-Use Plastic
Exemptions for
Medical, Public Safety,
Public Health, Or
Scientific Items
This paragraph includes exemptions for
medical, public safety, public health, or
scientific items, or for items for which
there is proof of a circular economy plan,
if justification is provided.
Section 1. Define Scope
& Exemptions
This section explains that exemptions may be
made for medical, public safety, public
health, or scientific items, if justification is
provided.
9. Funding Requests This paragraph includes funding requests,
if justified, for implementation costs.
Section 6. Fund the
Work
This section includes potential funding
sources for the NPS and possible efforts that
would require funding.
