Consumer Federation of California

Summary of CFC’s Arguments Against Use of CPVC Pipes

Early last year, CFC commended the Department of Housing and Community
Development (‘HCD’) for finally agreeing to proceed with an EIR after
initially proposing to approve CPVC pipe without any environmental
review. CFC stated that the document should address the concerns that
we raised, fully evaluate and disclose the project’s potential impacts,
and be an open, impartial decision making document based on real
science.

Unfortunately, the Final EIR that HCD is being asked to ratify today
fails in all of these respects. Rather than resolving the controversy
over CPVC once and for all, the EIR continues to dodge the issues
raised by our comments.

The inadequacy of the EIR is both baffling and frustrating. The
Coalition has submitted extensive comments detailing the impacts and
evidence that require further evaluation. We identified relevant
studies and reports that had not been evaluated. We also identified
additional data or research needed from industry in order to adequately
evaluate their product.

In sum, we provided HCD a roadmap for producing a legally adequate EIR
that would address, once and for all, the long-standing concerns over
the potential environmental, health and safety impacts of CPVC.
Regrettably, the RDEIR failed to take advantage of this roadmap.
Instead, HCD has chosen, once again, to resist a meaningful analysis of
CPVC.

For example, studies show that the current one-week flushing
requirement is inadequate to mitigate leaching issues because CPVC
leaches significant amounts of chemicals such as tetrahydrofuran,
methyl ethyl ketone, acetone and organotins for several months or
longer. Recent reports also demonstrate that the current flushing
requirements are almost universally ignored. The Final EIR, however,
simply ignores this evidence as if it doesn’t exist.

From leaching toxic chemicals and rupturing prematurely to spreading
fires more quickly, CPVC is associated with impacts that are dangerous
for consumers. The expanded approval of CPVC without full disclosure
and mitigation of its impacts only make sense for builders looking to
maximize profits through cheap and fast construction, not for the
millions of Californians that have to live with the consequences.

Builders, construction companies and developers gave $15.9 million in
contributions to the governor’s campaign chests ‘ making the building
and development industry his most generous contributor.

The Governor appointed Lynne Jacobs and Lucetta Dunn, the current and
previous directors of HCD, both of whom are industry insiders and
former leaders of the Building Industry Association. That’s like
assigning wolves to guard the henhouse.

These plastic pipes only make sense for builders looking to maximize
profits through cheap and fast construction, not for the millions of
Californians that have to live with the consequences. That’s why the
building industry has tried for decades to ease environmental
protections and gain approval from the state to use dangerous building
materials that pad their bottom line at the expense of the health and
safety of Californians.

Californians deserve a ban on any materials that have not been proven
to be of no risk to the environment, public safety and workers’ health.