California Carpet Stewardship Plan 2023-2027 - Carpet America Recovery Effort


SCH Number
Public Agency
California Department of Resources Recycling and Recovery
Document Title
California Carpet Stewardship Plan 2023-2027 - Carpet America Recovery Effort
Document Type
NOE - Notice of Exemption
Document Description
The Product Stewardship for Carpets law (Public Resources Code sections 42970-42983) requires manufacturers of carpets sold in this state, individually or through a carpet stewardship organization, to submit a carpet stewardship plan to CalRecycle. The carpet stewardship plan must be designed to increase the amount of postconsumer carpet that is diverted from landfills and recycled into secondary products or otherwise managed in a manner that is consistent with the state’s hierarchy for waste management practices. Carpet America Recovery Effort (CARE) designed and implements the carpet stewardship program described in its stewardship plan. Since 2011, CARE has collected and managed postconsumer carpet in California by providing financial incentives for carpet reuse and recycling and supporting drop-off sites that are open to the public, typically at landfills and materials recovery facilities. On March 29, 2023, CARE submitted to CalRecycle a new carpet stewardship plan, titled California Carpet Stewardship Plan 2023-2027. CalRecycle approved the plan on April 21, 2023.

Contact Information

Robyn Gillum
Agency Name
California Department of Resources Recycling and Recovery
Job Title
Environmental Scientist
Contact Types
Lead/Public Agency


Other Information
California Code of Regulations, Title 14 (14 CCR), section 18943(5) requires the carpet stewardship organization, through its plan, to provide consumers with opportunities to manage postconsumer carpet in each county. The approval of the plan is not a “project” under 14 CCR section 15378(a).

Notice of Exemption

Exempt Status
Type, Section or Code
CEQA Guidelines sections 15308, 15061(b)(3), 15378(a)
Reasons for Exemption
CalRecycle’s approval of stewardship plans is not a “project.” A “project” is an activity “which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment (14 CCR section 15378(a)). CalRecycle stewardship plan approvals have no direct effect on the environment and no reasonably foreseeable indirect impacts on the environment. There are no requirements in the stewardship plan from which any environmental impacts, direct or indirect, can be discerned. There are no standards or targets set in the stewardship plan on which to base an objective analysis of any potential impacts. To impute any general or specific environmental effects from the approval of stewardship plans would be entirely speculative, and CEQA does not require a lead agency to speculate as to potential impacts. Even if the approval of a stewardship plan could be considered a project, it would be categorically exempt pursuant to section 15308 of the CEQA guidelines, as the approval of the stewardship plan is to assure the maintenance, restoration, enhancement, or protection of the environment (see Public Resources Code section 42570). CalRecycle is one of the agencies specified in Public Resources Code section 21159.4 required to perform environmental analyses for the adoption of certain rules and regulations pursuant to Public Resources Code section 21159 and section 15187 of the CEQA guidelines. However, CalRecycle’s approval of the stewardship plan does not create any requirement for the installation of pollution control equipment, or a performance standard or treatment requirement. As such, no environmental analysis is required pursuant to Public Resources Code section 21159.


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