1. Book Industry Environmental Council (BIEC) By: Bill Upton, Malloy, Inc Gary Jones, Printing Industries of America

2. Origin & Mission Founded June 2008 by Green Press Initiative (GPI) Coordinated by GPI and Book Industry Study Group (BISG) Mission: Follow through on opportunities for environmental improvements identified in the March 2008 report:  Environmental Trends and Climate Impacts, Findings from the U.S. Book Industry Published jointly by BISG and GPI

3. BIEC Membership AbitibiBowater Edwards Brothers Glatfelter International Paper Lindenmeyr Malloy Maple-Vail Midland Paper NewPage RR Donnelley Sheridan Books Thomson-Shore Webcom Xerox BMI Members

4. BIEC Membership Bethany Press McNaughton & Gunn Pinnacle Press Other Book Manufacturers

5. BIEC Membership Baker Publishing Group Chelsea Green Chronicle Books Continuum Int’l Hachette HarperCollins Hyperion McGraw-Hill Northern Illinois Univ. Press Pearson Random House Rodale Scholastic Simon & Schuster Sterling Publishing Publishers

6. BIEC Membership Andrew Van Der Laan Am. Assoc. of University Presses Am. Library Assoc. Am. Booksellers Assoc. Anderson Merchandisers Book Industry Study Group Bookbuilders West Borders Canopy Cascades Eco Libris Green Press Initiative Melcher Media New Leaf Paper Sam’s Club Other Groups & Individuals

7. 4 Major Initiatives 1. Establish Climate Goals 20% industry reduction in CO 2 emissions 2006 to 2020 80% industry reduction in CO 2 emissions 2006 to 2050 2. Track Industry Progress on Environmental Goals Annually survey all segments of industry supply chain Obtain responses from 75% market share for each segment 3. Publisher Certification & Eco-labeling Certify environmental practices of publishers Certified publishers can print eco-label in all their books Certification based on point system and documented avoidance of use of fiber coming from endangered forests 4. Reduce Returns & Keep Books Out of Landfills Just getting underway

8. Eco-Labeling Project

9. BIEC Eco Label Awards certification to publishers for use on product Certification based on scorecard and endangered forest requirements Three tiers of certification Documentation will be required to prove publisher claims

10. Scorecard 22 metrics divided into 5 broad categories

11. 3 Levels of Eco-Label Certification Certification Level Points Required (out of 1,000) % Fiber Proven as Non-Endangered Forest* Upper40095% Middle50085% Lower60080% *One proposed amendment would require 100% of fiber be proven as coming from non-endangered forests for all certification levels. A small allowance (up to 5%) could be granted for specific circumstances, such as when verification is not possible.

12. What Qualifies for EF Requirement Recycled Fiber (pre or post-consumer) Agricultural residue or on-purpose crop fiber (kenaf, bagasse, hemp, cotton, etc.) FSC certified papers Fiber that meets the controlled wood standard Paper with CoC documentation showing it is not sourced from a region with endangered forests

13. Content of Book Paper I. Content of Book PaperPossible Points (% of total) a. Postconsumer Content225 (22.5%) b. 3 rd Party Certification175 (17.5%) c. Preconsumer Content50 (5.0%) d. Papers Made With Renewable Energy 25 (2.5%) e. Use of Agricultural Residue or Alternative Fiber 25 (2.5%) Total500 (50%)

14. Reducing Paper Waste II. Reducing Paper WastePossible Points (% of total) a. Scrapped/Discarded Books85 (8.5%) b. Reducing Returns75 (7.5%) c. Basis Weight Reduction60 (6.0%) d. Use of Office Paper10 (1%) Total230 (23%)

15. Minimizing Climate Impacts III. Minimizing Climate ImpactsPossible Points (% of total) a. Transportation53 (5.3%) b. Heating and Cooling45 (4.5%) c. Renewable Energy25 (2.5%) d. Efficient Lighting20 (2.0%) e. Carbon Offsets7 (0.7%) Total150 (15%)

16. Toxics and Pollution Prevention IV. Toxics and Pollution PreventionPossible Points (% of total) a. Bleaching Process40 (4.0%) b. Volatile Organic Compounds30 (3.0%) Total70 (7%)

17. Corporate Policies and Goals V. Corporate Policies and GoalsPossible Points (% of total) a. Goals for Recycled Content18 (1.8%) b. Goals for Certified Fiber13 (1.3%) c. Goals for Reducing Climate Impacts10 (1.0%) d. Preference for ECF/PCF/TCF Bleaching 3 (0.3%) e. Preference for Low VOC Inks3 (0.3%) f. Transparency of Policy3 (0.3%) Total50 (5%)

18. Verification Publishers will be required to submit documentation verifying claims including Letters from suppliers 3 rd party certification Receipt/invoices Internal documentation Signed statements for some lower value items GPI approved to be initial certifier A portion of certifications will be audited by 4 th party to ensure integrity

19. BMI/PIA Comments Point Assignment Approach No clear basis for weighting each aspect  Use of PCW fiber is worth up to 230 points vs preventing pollution and the use of toxics only worth up to 70 points Unclear why FSC certification worth almost twice as many points as SFI, CSA, or PEFC certification No reasoning for the distribution of points for various types of renewable energy used by mills What is the basis for alternative fiber point value  No definition of alternative fiber

20. BMI/PIA Comments Point System Approach The point system may be counterproductive  Three levels may cause confusion for consumers  No incentive for publishers to move up Tiers Publishers may be discriminated against for only achieving the lower levels of certification Publishers may drop down a tier through no fault of their own  For example, a supplier going out of business or discontinuing the manufacture of a particular product

21. BMI/PIA Comments Recycled Fiber Content Scorecard does not recognize limitations exist in use of recycled fiber for various types of sheets and applications  Scorecard should be modified to reflect limitations High levels of recycled content in coated papers cause weakness and unsmooth surfaces High point levels for recycled content may be unachievable in certain publishing markets  El-Hi market MSST requires specific strength levels

22. BMI/PIA Comments Recycled Fiber Content Difficult to achieve high bulk and low basis weight with high levels of recycled content Difficult to achieve high levels of recycled content for sheeted paper than roll paper Digital printing devices are limited in the sheets they can run  Some require special surface treatments not compatible with the use of recycled fiber

23. BMI/PIA Comments Recycled Fiber Content High levels of recycled content can cause insufficient paper strength for withstanding binding processes that require puncturing the paper  Smyth sewing and saddle stitching

24. BMI/PIA Comments Climate Impact Scorecard awards 25 points if 80% of a publisher’s books are printed within 100 miles of its book distribution center. It is not logical to single out this leg of the book distribution process over all others. We recommend awarding points for printing in North America and avoiding trans-oceanic shipments.

25. BMI/PIA Comments Toxics and Pollution Prevention Scorecard awards up to 40 points for the use of TCF, PCF, or EECF bleaching.  Insufficient capacity at North American mills using these bleaching processes to serve this industry. Unclear as to why is ECF bleaching not included as an acceptable process  ECF has reduced releases of dioxins to non- detectable levels.

26. BMI/PIA Comments Toxics and Pollution Prevention Scorecard awards up to 30 points for the use of inks containing less than 5% VOC content.  Only dry toners and vegetable based CMYK inks for sheetfed printing can currently achieve this level.  Inks for other printing processes (e.g. nonheatset or heatset web, ink jet, flexo) and spot color inks can not achieve a VOC level of 5% or less. VOC content is not the same as VOC emissions.

27. Status of Eco- Labeling Project

28. BIEC Response to Comments October 20, 201 full meeting of BEIC 11 amendments on eco-labeling program were up for vote Question raised: “Do we want to proceed with this structure?” Concerns mentioned:  Are we creating “logo confusion”? BIEC, FSC, SFI, recycled, recyclable, etc. Will consumers understand it is the publisher, not the book, that is certified?  Will publishers view the criteria as too complex and burdensome to apply for certification?  Compliance with FTC guidelines Published a draft of its revised “Green Guide” on 10/6/10 with public comment period ending 12/10/10. Will BIEC’s program conform to the new guidelines?

29. BIEC Response to Comments Ambiguous result of vote on proceeding  More than half of members abstained Since certification is for publishers, should this question be decided by just the publishers? More members voted in favor than against Publishers were evenly split, for and against Decision  Table the project for now, while: BIEC executive committee gets input from publishers not present at 10/20/10 meeting Wait to see requirements coming from FTC on “green” labeling