f,_ .,    .;     A;rr   Protectiov   g^Resp°nse   . EpA53o^;°°r

      «-EPA   Summary of Comments
              On the Proposed Paper Products
              Recovered Materials Advisory
              Notice (RMAN)
                   Photocopied on recycled paper that contains at least 50 % recycled fiber

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V

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        ; \  •   •-.     •     '   .  '   CONTENTS     •        .     •;•••'.  ..   -"
                              ••'•''      •           '        '•'.••'      ... Page
  LIST OF COMMENTERS	......;.;.......... ...... 1
  INTRODUCTION . . .	. .		 . '.'.	;.;4
  SUMMARY OF COMMENTS BY TOPIC                                        ;
  Section                                     '    '
  1      General Comments	..............	.5
  2      Comments on EPA's Objectives .................;.	 12
  3      Comments on EPA's Approach	'.	 15
-4      Comments on;EPA's Methodology  ...;...-.......... ,..•	..-.-19
  5      Comments on EPA's Content,Recommendations for Designated Paper Products .... 20
  .      Printing and Writing Paper	 20
             Coated Printing and Writing Paper  .";	 ..;. .......,:  ! 25
             Bristols	-. •	27
          •   Newsprint	....;..	.		 28
        Tissue'Products  ..'........		-...-..'.	 29'
        Paperboard and Packaging Products 	:...".	...'......	"..... 32
        Miscellaneous Paper Products	.-..	;....... 36
  6      Comments on Measurement, Specifications,  and Recyclability	 37
  7      Comments on Definitions	 43
            ; Postconsumer			 43
             Waste Paper, Recovered Fiber, and Clarification on' Repulping Requirements   47
             Mill Broke	:......,	....;........	I-.-...........;'.'.. 50

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                  •             •           _   •                  .        ••.••••-   v
                            .               .             -                 ..             •  • v
8      Miscellaneous Comments	;	                     55
             Further Delineating or Deleting Designated Items	         55
             Recovered Material Certification and Verification	        56
             Sawdust as Recovered Fiber			.'            •    57
             Energy .Issues and Cost/Benefit Implications of Paper Recycling ,	: .' 58
             Recovered Fiber Supply Shortage	   	         59
             Information on Tray Liners		      62
             Information on Greeting 'Card Stock	         52
            Information on Specialty Tissue Products	•	'.'...	'.   62
            Information on Paperboard and Packaging  ..................:....... 63

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                                 COMMENTERS
Docket
Tracking
Number   .Organization
    1

    2
    3
   •4

   5
   6

   7
   8
   9
 HMSO'Paper
 Mohawk Paper Mills, Inc.
 Repap Wisconsin,-Inc.
' International Paper

 Wisconsin Tissue/Chesapeake Corp.
 Union Camp Corporation

Appleton Papers, Inc.
Conservatree Information Services
International Paper
   10      James River Corporation

   11      Scott Paper Company
   12      Fort Howard Corporation
   13      Pptlatch Corporation

   14'      Chesapeake Paper Products Company
   15      Mead Corporation
 •16      Markets for Recycled Products
   17      Magazine Publishers of America
   18      City of San Diego, CA Waste Management
          Department   .
   19      Riverwopd International Corporation
  20      Kimberly-Clark Corporation
  21      Bowater Incorporated
 Type of Business/Organization
           V     .               '
 British government printing
 organization
 Printing-writing producer
 Tissue producer
 Printing-writing, paperboard
 producer   .
 Tissue producer
 Printing-writing, paperboard
. producer      .       ;
 Carbonless producer
 Recycling advocacy organization
 Printing-writing,, paperboard
 producer
 Printing-writing, tissue, paperboard
 producer
 Tissue producer
 Tissue producer
 Printing-writing, tissue, paperboard
 producer
 Containerboard producer
 Paperboard producer     -,
 Recycling advocate
 Trade association
 City government     "

 Paperboard producer
 Tissue producer           .
 Newsprint,  printing-writing
 producer
                                       -1-

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Docket
Tracking
Number
   ==
   22
   23

   24

   25

   26

   27

   28
  29

•  30

  31

  32

  33
  34
  35.
  36
  37

 38
 39

 40
 41
 42
   Organization
   Newspaper Association of America
   American Forest & Paper Association
   Containerboard & Kraft Paper Group
   Union Camp Corporation, Packaging
   Division                         ,
  American Forest & Paper Association
  Printing-Writing Paper Division
  American Forest & Paper Association
 . Recycled  Paperboard Division
  American Forest & Paper Association
  Bleached  Paperboard Division
  American Forest & Paper Association
  American Forest & Paper Association
  Newsprint Division
 American Forest & Paper Association
 Tissue Division
 Northeast  Maryland Waste Disposal
 Authority
 Rainy River Forest Products U.S.
 Corporation
 Finch, Pruyn & Company, Inci
 Procter &  Gamble Company
 International Paper, Fine Business Papers
 Lincoln Pulp & Paper Co., Inc.
 Georgia-Pacific Corporation

 Canadian Pulp & Paper Association
James River Corporation

Paperboard Packaging Council
Tennessee  Valley Authority
Random House, Inc.  •
  Type of Business/Organization
  Trade association
  Trade association.

  Paperboard producer

  Trade association

  Trade association   •

  Trade association

  Trade association
  Trade association

  Trade association

  Local government

 Newsprint, printing-writing
 producer
 Printing-writing producer
 Packaged goods manufacturer
 Printing-writing producer
 Pulp, printing-writing producer
 Printing-writing, tissue, paperboard
 producer
 Trade association
 Printing-writing, tissue, paperboard
 producer
 Trade association
Federal agency
Book publisher
                                      -2-

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Docket  .
Tracking
Number
Organization
Type of Business/Organization
   43      Tissue Producers Coalition on the EPA
           Procurement Guidelines
   44      Jeff Lindsay                  :.
  " 45      Lindenmeyr Paper Company
   LI      National Recycling Coalition
   L2      Chesapeake Paper Products Co.
   L3      Tissue Producers Coalition
   L4      Direct Marketing Association
   L5      Paper Recycling Coalition .        .
                                          Industry coalition       .

                                         -Individual
                                          Fine paper merchant
                                          Environmental advocacy group
                                          Containerboard producer
                                          Industry coalition
                                          Trade association
                                          Industry coalition
                                       . -3-.

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                                   INTRODUCTION
        This document summarizes comments by topic on the U.S. Environmental  Protection
 Agency's (EPA's) Draft Paper Products Recovered Materials Advisory Notice (RMAN), which was
 published in the Federal Register on March -15, 1995.  Within each topic, comments are listed
 according to the order in which they were received.

        EPA invited public comment on the draft paper products RMAN for a 60-day period and
 received 45 comments during that period, as well as five comments after the end of the comment
 period.   Public comments and relevant documents are  available for viewing  in the RCRA
 Information Center (RIC), located in Room M2616 at .the U.S. Environmental Protection Agency,
 401 M Street, SW., Washington, DC 20460, in docket number F-95-PPRN-FFFFF. The RIC is open
 from 9 a.m. to. 4 p.m., Monday through Friday, except federal  holidays.  To review document
 materials, the public must make an appointment by calling 202 260-9327. Materials may be copied
 for S0.15 a page.

       For copies  of the draft paper products RMAN and related supporting analyses, call the
 RCRA Hotline at 800 424-9346 or, in the Washington, DC, metropolitan area, 703 412-9810.  These
 documents  are  also  accessible through EPA's  Public  Access Server  on  the Internet, at
gopher.epa.gov.  For technical information On the draft paper products RMAN, contact Dana
Arnold of the .Recycling Section in EPA's Office of Solid Waste at 703 308-7279.
                                         -4-

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                                         SECTION 1

                                  GENERAL COMMENTS

          Mohawk Paper Mills, Inc. (#2) disagrees with the proposed recycled content standards
   for printing and writing papers because;the recommended levels would place nonintegrated
   manufacturers of text and cover papers at a severe disadvantage in markets that treat text, cover,
-  and offset papers as interchangeable products. It also questions whether current technology can
   adequately deink mixed office waste.

          Wisconsin Tissue/Chesapeake Corp. (#5) does not support government intervention in
   establishing these guidelines. It believes that recovered paper utilization should.be dictated by
  . market forces rather than government mandates. It also states that the collection of
   postconsumef paper is not keeping up with U.S. and global demand, so manufacturers need to
   have the flexibility to alter their utilization of postconsumer fiber in response to these market
   conditions.                          •               ;           '

         Conservatree Information Services (#8) supports the proposed revisions to the 1988 EPA
   paper guideline as welcome corrections to previously flawed guidelines for high-grade papers.  It
   suggests that to maintain a healthy market, it is crucial to provide incentives for manufacturers to
   keep making printing and writing papers at higher content levels.

         International Paper (IP, #9) disagrees with  the guidelines and would like EPA to
 - emphasize that the content levels in the RMAN are recommendations for use solely by federal
  agencies.  It does not agree with further government intervention in paper recycling, because  %
  specifying content levels is a demand-side management tool that is detrimental' to the industry.
  Encouraging the: use of these content levels in the private sector shows a complete lack, of
  understanding of customer end-use requirements, fiber availability, supply shortage, global
  economic trends, cost, manufacturing capabilities, and the complex interaction of these variables.
  Most of the  major world economies do not distinguish between pre- and postconsumer sources of
  fiber, so the content standards would put the U.S. paper industry at a competitive disadvantage
  in international markets. The company is also concerned that a cost analysis was not done to
  assess the  financial impact of the guidelines. IP, however, does applaud EPA's inclusion of the
           •     .  .'    •".      •   .        '-5-''       ;.            '      •'..-•''.•

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 grades matrix which clarifies different grades and eliminates confusion.  To create a single
 definition of recycled paper, it also supports the categorization of most common office-use
 papers as requiring 20 percent postconsumer and 80 percent virgin fiber.          '     '

        Potlatch (#13) disagrees with an increase  in postconsumer recovered fiber content
 because the price-increases in the paper market will spread through the commercial 'market,
 causing significant negative economic impacts.   '

        Chesapeake Paper Products (#14) opposes further increases in recovered.fiber content
 •because new incentives to recover more, fiber are simply not needed in competitive global paper
 markets.           •                        • .            •

       Mead (#15) strongly opposes the concept of government-imposed recycled content
 requirements. It states that the guidelines effect the energy balance, because virgin fiber mills
 are very efficient in converting waste material into energy.  Use of recycled fiber, however,
 reduces the amount of these waste products'and increases use of nonrenewable energy sources.
 In addition, current demand has driven prices upward, so EPA should include in the RMAN a
 candid .discussion on whether the environmental benefits expected to occur with the adoption of
 these guidelines offset the potential economic costs to consumers.                 .

       Markets for Recycled Products (#16) states that the proposed RMAN does not recognize
that paper and paperboard are made with ingredients that are not fiber.  Virgin chemical and
mineral additives are used commonly in paper, which can create a manufacturing problem if
EPA recommends 100 percent recycled content levels.                       •  .  .
                                          -6-

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           Magazine Publishers of America (#17) requests that EPA confine the scope of-its
    guidelines to paper purchases by federal agencies without suggesting that the private sector adopt
    these recovered fiber content levels.  Given the limited availability and high cost of many paper
    products containing postconsumer fiber, there could be significant negative financial impacts if
 .   the private sector adopted these recommendations.  EPA needs to undertake' a much, more   .
    extensive analysis of market conditions and financial impacts before making any  '
    recommendations of posteohsumer and recovered fiber content levels for use by the private
    sector      .  '     ....'-.'.       •   .•   •.      .-    ;•    :;             • '•.  • ^  '-..

          The City of Sa;n Diego, CA (#18) believes that the RMAN recommendations would  .
    greatly strengthen markets for postconsumer recycled paper by raising the standards of minimum
    postconsumer content for a variety of paper products.

     .   .  Kimberly-Clark (#20) believes that the RMAN is unnecessary in light of current
    recycling levels  and initiatives under way in the marketplace. The proposals for recovered
    material  ranges will stifle innovation and reduce the  flexibility that manufacturers  need to be
    competitive in the marketplace.                        '"'.,.

          Bowater (#21) believes that the RMAN exceeds statutory authority and intent and is an
    unconstitutional restraint on commercial speech. Congress's objective of diverting waste from
    landfills is needlessly jeopardized by the draft RMAN's narrow definition of "preconsumer" and
    "ppstconsumer" waste.  Bowater contends that its employees will have a difficult time
    distinguishing between postconsumer and preconsumer waste old magazines (OMG), making the
.    recovery process so complex that Bowater would have to cease producing its computer forms
   paper from recovered material.    .                  .'..'..

          The Newspaper. Association of America (#22) believes that the proposed guidelines are
   unnecessary, and that EPA should focus its efforts'on working with industry and'local
   governments to maximize the recovery of old newspaper and other recovered papers.
   Furthermore, it encourages EPA to postpone revisions to the procurement guidelines for
   newsprint until it becomes clear that sufficient supplies of recovered fiber are available to meet
   the current and anticipated long-term needs of newsprint manufacturers.

 •"'.-••'    '.    V  •'    .          -7-   •'••:  : .  ''.           ...'•'    '    '   -

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         .Union Camp (#24) is opposed to arbitrary mandatory recycled content levels because'
   they are- unmindful of local concerns, and they add costs and destabilize markets without
   meaningfully enhancing recycling or recycling markets.  The RMAN also negates the efficient
   channeling of paper waste and undermines industry competitiveness.                 ''..'•

         The Printing-Writing Paper Division of the American Forest & Paper Association (#25)
• supports efforts to revise the guidelines because the markets have changed since the previous
  guidelines went into effect. -The RMAN is correct in suggesting lower recycled content levels for
  printing-writing grades achievable both by large and small mills, :assuming sufficient supplies of
  recovered fiber are available.  In light of tight markets for recovered fiber, virgin .pulps, and
  paper products, however, printing-writing paper manufacturers strongly urge EPA to clearly
  indicate that the RMAN applies to federal government purchases only.

        The Recycled Paperboard Division of the American Forest & Paper Association
  (RPD, #26) takes  strong exception to EPA's goal to have its content standards adopted by the
 private marketplace, at least until the marketplace can respond  to the demand for recovered
1 paper. Given the current fiber supply shortages, mills will only add capacity when they can be
 assured that they will have an adequate supply of fiber at reasonable cost.  RPD also believes
 that it is irrelevant  whether EPA uses the term  recycled content "standards" or "levels," because
 the effects will be the same.  RPD questions how many more minimum content levels EPA will
 seek to recommend, because it is already micromanaging the industry.

       American Forest & Paper Association (AF&PA, #28) supports the use of content levels
 for federal agencies but does not support the use of content levels in the private sector/consumer
market.  It states that the guideline should be based on data reflecting current market conditions,
that recovered paper markets have matured, and that EPA should instead focus on removing the
overarching barriers to increased recovery and recycling because  content levels would be
counterproductive unless there was assurance of adequate recovered  fiber supply. AF&PA also
asserts, that distinguishing between pre- and postconsumer paper  puts the United States at a
competitive disadvantage in the world economy,  and that EPA should perform a financial impact
analysis before making final recommendations.                 •'.,..
                                           -8-

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        The Newsprint Division of the American Forest & Paper Association (#29) states that  /
 the key issue is not stimulating markets for recovered paper but rather extending recovery.  With
 a shortage in supply, any policy that stimulates demand will result in businesses reducing
 investment in using recovered fiber. It is also inappropriate for EPA to establish procurement
 guidelines for the broad market because the current tightness in recovered paper,markets would
 .be exacerbated and recycling would be hurt .over the long term.                           :

        The Tissue Division of the American Forest & Paper Association (#30) states that the
 key.issue is not stimulating markets, for recovered paper but extending recovery. With a shortage
 in supply, any policy that stimulates demand iwill result in businesses reducing investment in using
 recovered fiber.  In addition, the recent surge  of recovered paper prices has increased the raw
 material costs of tissue producers that rely heavily on recovered paper. As a result, three
. companies have been forced to close their doors.            .                              ;

        The Northeast Maryland Waste Disposal Authority (#31) commends EPA for its efforts
 to increase purchases 6f recycled products by government agencies and believes that these
 revisions to the guidelines will help in this regard.

        Rainy River Forest Products (#32) disagrees with the distinction between pre- and
 postconsumer materials.  Because no world market distinguishes between pre- and postconsumer
                            ;?  -"       ',''"''*'•      '                .    ' -   .     • '
 sources of recovered paper, doing so puts the United States at a competitive disadvantage. In
 addition, the use of EPA content levels by the  private sector falls outside the scope of its
 statutory mandate, and without a cost benefit analysis EPA needs to carefully contrast federal    ;
 versus private marketplace standards;    -                                                -

        Procter & Gamble (#34) states that the RMAN does not pay adequate attention to the
 benefits of source reduction, and it suggests that tissue and towel products with EPA-approved
 source reduction features should be deemed co-equal with those products that utilize
 postconsumer fiber. Any reference to private sector activity, should be deleted from the RMAN
 because it exceeds the statute and because the marketplace has  made federal intervention
 unnecessary.                    ,
                                            -9-

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         Georgia-Pacific (#37) questions the need for new procurement guidelines.  Because
  paper mills are already negatively affected by the increased cost and supply shortage of recovered
  paper; the guidelines will exacerbate the problem. It is also concerned about EPA's legal
  authority to propose guidelines to the private sector.                              '''  •    • '

        The Canadian Pulp and Paper Association (#38) believes that the influence of the
  specifications will extend well beyond U.S. borders, and the guidelines fail to take into account
  the changes that have transpired over the past six to seven years in recovered paper markets. In
.addition, collection systems need to be improved and expanded rather than introducing stricter
 policies that would continue to place the entire burden on paper mills.  Government initiatives
 should be focused on generating economic supplies and incentives so that recycling goals can be
 achieved.                               ._'•.-                              •

        James River (#39) believes that in light, of the dramatic reversal that the proposed
guidelines represent and the complexity of its potential impacts on the market, the 60-day period
for public comment was unreasonably short.                        •

        Paperboard Packaging Council (#40) questions the appropriateness of stimulating
demand even further by the adoption of increased recycled content standards for federal
procurement of paper products.  It is concerned because current and projected supplies of
recovered paper and paperboard are inadequate  to meet market needs.

       Tissue Producers Coalition (#43) does not object to recycled content guidelines but was
shocked at the-extent of-the changes put forth in the new guidelines. It believes these changes
will have serious detrimental effects on its industry and the use of recovered fiber in the  United
States.  It notes a lack of any clear statutory authority for establishing new guidelines for the
consumer segment.  In addition, it finds it contradictory that EPA emphasizes the importance of
recognizing the energy balances and operating economics in setting postconsumer-only standards
for printing and writing grades, while ignoring these same considerations for tissue grades.  '
                                           -10-

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        National Recycling Coalition (#L1) generally applauds EPA's efforts in the. development
 of the RMAN and believes that it will greatly improve the ability of public and private sector '
 procurement officials to purchase recycled paper products at competitive prices.  However, it
 encourages EPA to consider efforts to monitor the implementation1 of affirmative procurement
 programs for recycled products within  each federal agency.      -            -

       ' Direct Marketing Association (#L4) believes that it is crucial that the guidelines apply
 only to federal agencies, not to the private sector. The continuing shortages of recovered fiber
 and high prices create substantial concerns about the potential impact of the guidelines on the
 availability of recovered fiber for private-sector paper purchasers.    .

     "  Paper Recycling Coalition (#L5) believes that EPA should not be trying to spur the
 demand for recycled paper when it.is lacking reliable data on the amount of material available to
 be recovered, and when the recycling industry is overwhelmingly concerned about shortages and
 future  supply of recovered paper. EPA should not encourage state and local agencies and
private industry to utilize the RMAN without first determining that there is existing mill capacity
and recovered paper Supply available to meet the potential demand.
                                          -11-

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                                      SECTION 2
                       COMMENTS ON EPA'S OBJECTIVES
     .   Repap Wisconsin (#3) states that, with rising waste paper prices, a narrow postconsumer
 definition will further intensify cost factors and will discourage increased usage of postconsumer
 fiber.             .          '

        Union Camp (#6) states that, with the continued expansion of facilities that utilize
 postconsumer'waste, the market will clearly tighten and the supply will decrease.

        International Paper (#9) contends that growth in demand for paper products and
 additional recycling capacity result in a tight supply of both recovered and virgin market pulp.
 This, coupled with the increased costs  of recovered paper, will be reflected in the price of
 recycled content products. In addition, specific mandated content levels will put rural mills in a
 potentially noncompetitive situation, which would work contrary to the RMAN objective of not
 compromising competition or product, performance.                     .......

       James River (#10) disagrees with EPA's attempt to stimulate the market, because any
 increased demand in a market that faces a supply shortage will be detrimental.  If all commercial
 towel and tissue products were manufactured with 100 percent recovered fiber content, the
 shortfall of fiber would result in higher prices, which could drive companies out of business.

       Scott Paper (#11)  disagrees with EPA's goal of maximizing recycled content in individual
 products.  Current utilization of recycled fiber is very uneven among the major tissue
 manufacturers. Instead, EPA should focus on encouraging companies to invest in equipment
 that directly contributes  towards achieving the highest recovery goal.

       Fort Howard (#12) states that  high prices for postconsumer fiber will not generate more
 supply of recycled paper products. Manufacturers will simply determine that they are  unable to
purchase waste paper because they would be unable to selLtheir end products at a competitive
price.

                                           -12-     •                            •

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        Potlatch (#13), commenting generally about all grades of paper, believes that EPA's goal
 to ensure the use of recovered fiber is already being met under the present levels of
 postconsumer fiber content.  Raising the levels, as EPA suggests, would only have an
 inflationary, negative impact on the economy.

        Mead (#15) acknowledges that EPA's objectives are worthwhile but believes that, for
 corrugated containers, the goals.have already been reached.  Mead claims that government
 intervention is unnecessary and unwanted.  If it must occur, however^ the objective should be to
 reduce the amount of paper and paperbpard ending up in landfills. .        '

        Markets for Recycled Products  (#16)  states that the two-part fiber content levels could"
 inhibit achieving the objective to increase use of postconsumer fiber.                  x   '

        Riverwood International (#19)  believes that, in striving to reach the stated objectives,
 EPA should consider the scarcity  and expense in obtaining suitable secondary fiber.  Research
 into the availability and price of recovered fiber, the physical location of the vast majority of
 mills using a high percentage of virgin fiber, and the comparative energy efficiency of present *
 operations should play a part in setting EPA's objectives.                          ,,'''.  .

       Bowater (#21) claims that the RMANY rigid fiber content levels for printing and writing
 papers will not achieve the goals set forth in the stated objectives because the levels will result in.
 fewer suppliers and higher prices.  The higher prices could even cause government procurers to
back away from the use of recovered-content paper products.                                 .

       The Container-board and Kraft Paper  Group of the American Forest & Paper
Association (#23) believes that, with the current acute shortage of recovered fiber and with
collection rates at historical highs, there would seem to be no need to specify recovered fiber
content levels. The postconsumer fiber content requirement does not, and will not, encourage
recovered fiber use in corrugated containers.
                                           43-

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         The Printing & Writing Paper Division of the American Forest & Paper Association
  (#25) states that text and cover fiber content levels should be grouped with papers covered
  under Section 504(a)  [of the Executive Order] at the singular 20 percent postconsumer fiber
  levels.
           1   .               .              •  '  '  '           '•"                   ?      '

         The Recycled Paperboard Division of the American Forest & Paper Association (#26)
•  claims that the two objectives set forth by EPA have already been met; and that the issuance of
  high recycled content recommendations at this time will not advance the objectives and may, in
  fact, hinder them.

        American Forest & Paper Association (#28) states that the distinctions between
  recovered and postconsumer fibers will not lead  to more recycling of postconsumer paper.

        The Newsprint Division of the American  Forest & Paper Association (#29) believes that
  classification of certain inked paper as preconsumer fiber runs contrary to the  RMAN's stated
  purpose of keeping solid waste from landfills.                                              •

        The Tissue Producers Coalition (#43) claims that the inclusion of consumer tissue in the
 RMAN goes against the stated objectives and will have a detrimental effect by arbitrarily
 increasing the price of recycled products rather than broadly extending recycled content into all
 brands, as intended.                               ~ '

        The National Recycling Coalition (#L1) agrees that the draft RMAN will help to achieve
 the objective of RCRA Section 6002 to maximize  the purchase of paper products containing
 postconsumer fiber by governmental procurement agencies and contractors.

        The Paper Recycling Coalition (#L5) believes that EPA must provide a more clearly
 defined objective for a quasi-regulatory exercise that may have a dramatic impact on the nature
 of many institutions and businesses.  The coalition offers several  interpretations and scenarios for
 the stated objectives, and concludes that every possibility is either irresponsible or ineffective.
                                           -14-

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                                       SECTIONS
                         COMMENTS ON EPA'S APPROACH
        Repap Wisconsin, Inc. (#3) supports the proposed two-tiered approach. Repap also
  believes that recommending the same level for both recovered and  postconsumer fiber does not
  create a true two-tiered structure because,manufacturers are not required to use recovered fiber
  beyond the specified postconsumer amount.
                                          -            i             , •
        Union Camp (#6) states that the ranges proposed for recovered and postconsumer fiber
  require clarification and suggests that EPA should specify the minimum in the marketplace and
  allow market forces to work to encourage supplies to offer higher levels.                   '
           •         ' ' .'    "   ' '   ' : ' "        '   •  ! ^   '  '    '  '         '     • ' -
        Conservative Information Services (#8) .supports EPA's proposed two-part content level
' approach and agrees that this approach will assure demand for all recovered materials.
 Conservatree also agrees with EPA's. use of ranges. It supports setting the low  end of the range
 so that it is meaningful and  feasible, and the high end of the range to show the  highest content
 levels available, even when products at those levels are not widely available.

        Scott Paper (#11) does not support a two-tiered'structure because it represents ah
 additional impediment to new investments.  Scott believes  that a postconsumer-only standard is
 needed to encourage greater investment  in deinking'capacity.             .

       Fort Howard (#12) supports recovered fiber content levels for tissue products but
contends that it is not necessary to establish separate postconsumer fiber content levels. Fort
Howard believes that recovered fiber levels,  by themselves, are sufficient to spur greater
collection and recycling of postconsumer  materials. If EPA deems postconsumer fiber levels
necessary, Fort Howard recommends establishing only minimum levels, thereby providing the
market with an incentive to increase postconsumer fiber use to the extent feasible.
                                          -15-

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        Mead (#15) supports a single recovered fiber content level rather than a dual standard,
 "because both recovered fiber and postconsumer fiber must be processed and deinked in the same
 manner.  This commenter feels that a single standard would simplify accounting and reporting
 requirements. •      .                  '      •                       -

        Markets for Recycled Products (#16) believes that a single, postconsumer-only level
 should be used, because new and planned capacity is designed for postconsumer feedstocks. A
 dual standard creates greater compliance and accounting complexity.

        The'City of San Diego (#18)  recommends the establishment of a single postconsumer
 fiber content level. By recommending recovered fiber content levels, industry is not given the
 flexibility to use1 other resources to their greatest efficiency.  San Diego also.disagrees with the
 use of ranges  because many purchasing agents are likely to comply only with standards that are
 clear and simply stated. While this commenter suggested that no top ranges be established, it
 suggests that preference be given to products that contain the highest content levels. San Diego
 believes that this will help ensure that manufacturers continue to expand the use of recovered
 fibers.

       Riverwood International (#19) supports the use of ranges and agrees with EPA's        '
 cautionary advice that products will tend to be more widely and economically available at the
lower end of the range.

       Newspaper Association of America (#22) does not believe a two-part content level is
appropriate in the  context of newsprint recycling. This commenter states that recovered
materials from many sources are routinely mixed during collection and processing, because both
recovered and postconsumer fibers are often equivalent in quality and appearance. As a result,
it is difficult and costly for a newsprint mill to distinguish between them.
                                           -16-

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        The Recycled Paperboard Division of the American Forest & Paper Association (#26)
 supports the use of recommended ranges for broad paper categories, rather than the minimum-
 content approach.  This commenter also states that a two-part content-level, while preferable to
 the use of a postconsumer-only standard, should'be replaced by a one-part standard based on
 total recovered fiber.  This commenter opposes setting a distinction between pre- and
 postconsumer fiber. .       .          ,                       ....•'.

        The Container-board & Kraft Paper Group of the American Forest & Paper Association
 (#23) states that the approach taken, which assigns across-the-board recovered fiber levels for
 broad paperboard categories, unfairly penalizes purchasers and manufacturers of products with
 properties not easily developed from recycled furnishes.  In addition, required recovered fiber
 content levels would put rural mills at a potentially severe competitive disadvantage to urban
 mills.  This commenter also believes -that content requirements would very likely give a
 competitive advantage to recycled containerbdard imported from countries that do not have such
 requirements because foreign producers could offer their, products at a lower price.

       American Forest & Paper Association (#28) suggests that recovered fiber is the best
 recycled-content standard. Tracking the'iise of pre- and postconsumer fiber is an unnecessary
 burden that will not lead to more recycling of postconsumer paper than would otherwise occur.

       Northeast Maryland Waste Disposal Authority (#31) supports the use of both pre- and
 postconsumer requirements where appropriate.  The Authority recommends, however, that one
 minimum-contend standard be set for each product, (containing postconsumer and recovered
 fiber standards as appropriate). This commenter believes that the use of ranges will not lead to
 the maximum use of recovered materials, in part because agencies seeking paper products at or
 near the high end of the ranges might find little or no availability at this level and return to
virgin sources. In addition, evidence for some of the higher ends of the ranges appears to be  .
limited.                               '••,-.•                                 -•

      .Canadian Pulp and Paper Association (#38) believes that minimum recycled-content
levels are unnecessary, suggesting instead the use of an average recycled-content level that
permits the purchase of a wide range  of recovered paper while achieving the overall goal.

                   •'    ' .      '   :         -17-"  '   :   •   '••.•".     '  -.'          '  •    •

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         Paperboard Packaging Council (#40) contends that EPA should focus on increasing the
  supply of recovered and recycled paper through public education and financial support of
  collection programs rather than revising the recycled-content levels to further stimulate demand.

        Tennessee Valley Authority (#41) supports the use of ranges in the proposed guidelines
 because this approach provides the Authority with flexibility to make its own determination
 about the most appropriate recycled-content levels for the different paper products it purchases,
 based on considerations of availability and cost-effectiveness.
                             **                                                   s

        National Recycling Coalition (NRC, #L1) supports the establishment of two-part content
 levels and agrees that it is necessary to specify a certain percentage of postconsumer content to
 encourage increased investment in deinking capacity.  NRC supports the use of ranges, which
 allows purchasing officials to factor in  the cost and availability of products that fall within the.
 recommended ranges. In addition, NRC suggests that the standards might include a "preferred"
 content level for all products based on EPA's research on the cost and availability of specific
 products.

       Paper Recycling Coalition (#L5) supports the use of a two-part content level, holding
 that in order to maximize the recovery'of postconsumer materials, it is necessary to encourage
 the use of all types of recovered materials in products. While the Coalition  feels that the
 distinction between pre- and postconsumer recovered paper is a burdensome and costly
 requirement for the industry, the Coalition agrees that RCRA statutory requirements might
preclude adopting .a one-tiered, recovered-materials-only standard. This commenter also noted
that the adoption of content ranges, while an improvement over minimum content standards, is  ,
not the most efficient means of increasing the utilization of recovered paper. The levels will
become, in practice, minimum content standards. The Coalition recommends establishing
aggregate recovered paper utilization goals  rather than sheet-by-sheet content goals.
                                           -18-

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                                     SECTION 4
                    COMMENTS ON EPA'S METHODOLOGY
       National Recycling Coalition (#L1) supports the establishment of procurement guidelines '
for the various.coated and uncoated printing and writing papers, the creation of a new guideline
under that category .for bristols, and most of the content levels proposed. The draft RMAN does
an excellent job of clarifying the different paper products covered by the procurement guidelines.

    .   Paper Recycling Coalition (#L5) believes that EPA's commitment to survey the industry
and revise the RMAN in the future to reflect changes in the market is an appropriate response
to changing markets and technologies.                     •                         >   .
                                        -19-

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                                    SECTIONS
       *                               ?    . "           • •
       COMMENTS ON EPA'S CONTENT RECOMMENDATIONS FOR
                       DESIGNATED PAPER PRODUCTS          ,
PRINTING AND WRITING PAPER
      General Comments      .

      Conservatree Information Services (#8) believes that it is essential to use ranges for high
grade papers, consistent with the use of ranges for other paper grades, and that the White House •
Executive Order standard-should be the lowest end of the range. Conservatree also asserts that,
because  fiber weight measurement requires less fiber than measurement by sheet weight, content
requirements for high grade papers must be higher (than those for sheet weight measurements)
to be meaningful.             .

      Markets for Recycled Products (#16) disagrees with the proposed recommendations for
printing paper because EPA should include the higher recycled content levels required by the
Executive Order as of December 31,1998.  .

      The City of San, Diego (#18) supports the levels set for postconsumer fiber content in
uncoated printing.and writing paper.      .  ,

      The Printing-Writing Division of the American Forest & Paper Association (#25)
disagrees with the proposed recovered and,postconsumer fiber content levels  for printing and
writing papers. If the levels were lower, more manufacturers would be encouraged to use some
recovered fiber because doing so would be more cost-effective and the fiber would be more
readily available.
                                         -20-

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        Northeast Maryland Waste Disposal Authority (#31) supports many of the
 recommendations in the RMAN, including the 20 percent postconsumer content level .for
 uncoated printing and writing papers. The Authority does, however, suggest that EPA set either
 postconsumer or recovered fiber content levels and include a footnote stating that the levels will
 be raised to 30 percent postconsumer by December 31, 1998.                  '   •

        Finch, Pruyn & Company (#33)  agrees with EPA's recommendation for recovered'and
 postconsumer fiber content- levels for uncoated printing and writing papers.  It believes that text
 and cover papers, however, should have  the same levels as other products in the category.

        International Paper (#35) suggests that EPA promote only a recovered content level of '
 20 percent for printing and writing papers, with no postconsumer content recommendation.

        National Recycling Coalition, Inc. (#L1) suggests  that EPA go beyond the Executive
 Order and reinstate a recovered fiber content level for printing and writing papers.  EPA should
 consult with states that have such a standard to determine the potential impact of a  federal
 guideline that does not include a recovered fiber content standard.
       Reprographic Paper               .         .
                                 •.."-•       .               •          f              •

       Conservatree Information Services (#8) disagrees with the proposed recovered and
postconsumer fiber content levels for reprographic paper. Conservatree recommends a 20 to 100
percent range for recovered fiber and a 20 to 50 percent range for postconsumer fiber because
the levels are measured by fiber weight father than sheet weight.              '
       Offset Paper                                                             .

       Conservatree Information Services (#8) questions the proposed recovered and
postconsumer fiber content levels for offset paper, and recommends a 20 to 100 percent range
                                          -21-

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for recovered fiber and a 20 to 50 percent range for postconsumer fiber because the levels are
measured by fiber weight rather than sheet weight.

       Mead (#15) recommends that papeterie papers be included in the category of "offset"
paper and provides information about that grade, which is used for greeting cards. .

       Magazine Publishers of America (#17) claims that offset papers (specifically; uncoated
groundwood paper) .should have the same levels of recovered and postconsumer fibers as
supercalendered and coated papers because all three are used in magazine publishing.' Any
differences among these, grades could create market imbalances detrimental to the magazine
publishing industry.  •            .                          .       •'

       The Printing & Writing Paper Division of the American Forest & Paper Association
(P&WPD, #25) believes that papeterie papers should be included under uncoated printing-
writing papers as a type of "offset" paper.          .                         .
       Tablet Paper

       Conservative Information Services (#8) disagrees with the proposed recovered and
postconsumer fiber content levels for tablet paper, and recommends a 20 to 100 percent range
for recovered fiber and a 20 to 100 percent range for postconsumer fiber.
       Forms Bond

       Conservatre* Information Services (#8) disagrees with the proposed recovered and
postconsumer fiber content levels for fornis bond, and recommends a 20 to 100 percent range for
recqvered fiber and a 20 to 50 percent range for postconsumer fiber.
                                           -22-

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        Envelope Paper      .                            .

        Conservatree Information Services (#8) believes that wove envelopes should have 20 to
 •100 percent recovered fiber and 20 to 50 postconsumer fiber, rather than EPA's proposed levels.
 It agrees with the proposed postconsumer fiber levelfor white/colored kraft envelopes but
 believes that they should have a 10 to 100 recovered fiber content. It also disagrees with the
 -proposed unbleached kraft envelope levels, and recommends  that they contain 10 to 100 percent
 recovered fiber and 10 to 30 percent postconsumer fiber.                .;        .     '
        Cotton Fiber.Paper               .                                •

        Conservatree Information Services (#8) disagrees with the proposed recovered and
postconsumer fiber content levels for cotton fiber paper, and instead suggests a 50 to 100 percent
range for recovered fiber and a 20 to 100 percent range for postconsumer fiber.

       International Paper (#9) agrees with the proposed recovered fiber content level for
cotton fiber paper.               .               •             >

:       Mead (#15) believes that a 20 percent recovered fiber content level would be
appropriate, to offset the, loss in acceptable material created by the proposed definitions of
"recovered" and "postconsumer" fiber. The company states that the proposed 50 percent level is
too high. -..,..''..                                           :

       The Printing and Writing Paper Division of the American Forest & Paper Association
(#25) accepts EPA's recommendations for recovered and postconsumer fiber content levels in
cotton fiber paper.   ,
                                          -23-

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       Text and Cover Paper ...

       Mohawk Paper Mills (#2) believes that the proposed recycled content standards will
place non-integrated, producers of text and cover papers at a severe disadvantage in markets that
treat text, cover, and offset papers as  interchangeable products.  Under the proposed standards,
integrated manufacturers will be allowed to use a high percentage of virgin fiber, which is
cheaper than postconsumer market pulp.  This will give them a cost and quality advantage over
non-integrated producers of text and cover papers.

       Conservatree Information Services (#8) disagrees with the proposed recovered and
postconsumer fiber content levels for text and cover paper, and recommends a 50 to 100 percent
range for recovered fiber and a 20 to 100 percent range for postconsumer fiber.

       International Paper (#9) claims that the proposed recovered fiber content levels for text
and cover papers are too high. The company recommends that the levels match those for most
other kinds of uncoated paper  (20 percent recovered fiber) because the higher levels will
compromise product quality.   ,                 :

       The Printing and Writing Paper Division of the American Forest & Paper Association
(#25) believes that text and cover paper should be classified, along with the majority of other
printing and writing papers, at recovered and postconsumer fiber levels of 20 percent.

       Finch, Pruyii & Company (#33)  disapproves of the recovered and postconsumer fiber
percentages for text and cover paper- because they would raise fiber procurement and energy
costs to a prohibitively high level.
     '  Supercalendered Paper

       Magazine Publishers of America (#17) agrees with the proposed recovered and
 postconsumer fiber content level for supercalendered paper.  .
                                           -24-

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        The Printing and Writing Paper Division of the American Forest & Paper Association
  (#25) supports the recommended ppstconsumer fiber content level for supercalendered paper.
        Check Safety Paper
        The Printing & Writing Paper Division of the American Forest & Paper Association
:(P&WPD, #25) believes that the presence of florescence and contaminants should exempt safety
 paper from the RMAN, which recommends a 10 percent recovered and postconsumer fiber
 content level. It is extremely difficult for mills" to source a consistent supply of fiber that does not
 contain.fluorescent dyes.     :•  '             ''•'.*               .              •   .
        Coated Printing and Writing Paper
       General Comments                            ,

       Potlatch (#13) agrees that coated printing and writing paper should have recovered and
postconsumer fiber content levels of 10 percent, supporting EPA's recommendation.

       The City of San Diego (#18) supports the postconsumer fiber levels for all types of .
coated printing and writing paper.
       Coated Printing Paper
                        ...                         -             i  - t

       Conservatree Information Services (#8) applauds the inclusion of coated printing papers
in the guidelines, but believes that the content levels should range from 10 to 100 percent for
recovered fiber and from 10 to 30 percent for postconsumer fiber, because EPA supports
measuring by fiber weight rather than by sheet weight. Many, coated sheets already contain
recycled content higher than the 10 percent proposed.

         •            .'''.'.    •          -25-      '        .       '•••.•-.    ,  ' -.'• -'    :

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       International Paper (#9) supports EPA's recommendations for recovered and   .
postconsumer fiber content levels for coated printing papers.  •

       Potlatch Corporation (#13) agrees with the proposed recovered and postconsumer fiber
content levels for coated printing papers.    •   '•

       Magazine Publishers of America (#17) agrees with the proposed recovered and
postconsumer fiber content levels -for coated printing papers.                        ,

       The Printing and Writing Paper Division of the American Forest & Paper Association
(#25) strongly supports the recommended recovered and postconsumer fiber content levels for
coated printing paper.       .  ,                        .
       Carbonless     :.•                                          •

       Conservatree Information Services (#8) disagrees with the proposed recovered and
postconsumer fiber content levels for carbonless paper.  Instead, it recommends a 20-100 percent
-range for recovered fiber and a 20-50 percent range for postconsumer fiber.  •

       The Printing and Writing Paper Division of the American Forest & Paper Association
(#25) believes that the recommended recovered and postconsumer fiber content levels for
carbonless paper are realistic.
                                           -26-

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       Bristols
       General Comments                                                   :

       International Paper (#9) disagrees with the proposed levels for. bristols.  Instead   •
(because products are not generally available at those levels), the company recommends. 10
percent recovered and postconsumer fiber content for bristols.          .        ,

     .  The City of San Diego (#18) believes that the recommended content levels for
postconsumer materials are adequate for all types of bristols.

       The Printing and Writing Paper Division of the American Forest & Paper Association
(#25) disagrees with the proposed levels for bristols, and recommends a range of 10-20 percent
postconsumer fiber for all products in this category.                      :
       File Folders                       .                         .

       International Paper (#9) claims that the proposed recovered-and postconsumer fiber
content levels for file, folders are too high because any level higher than  10 percent recovered
                             -           .                  .                 '
fiber will affect product quality.
                                           -27-

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       Cards
                  i ,         .                                         ''.,'(
       International Paper (#9) disagrees with the proposed recovered and postconsumer fiber
 content levels for indexi postal, and other cards.  While large companies such as IP have the   •
 capacity to produce card stock in sufficient quantities to meet customer demand for large
 quantities (such as the U.S. Postal Service), they cannot use 50 percent recovered fiber.  Several
 smaller companies can use 50 percent but do not have the capacity to fill, large-volume orders.
 IP suggests that-a 10. percent recovered and postconsumer fiber content level be adopted, instead
 of the proposed levels.
       Tags and Tickets

       International Paper (#9), operating under the assumption that tabulating cards are
 included in the tag and ticket category, disagrees with the proposed postconsumer fiber content
 level, because the current customer specifications for tabulating cards are very demanding, and it
.is unlikely that they can still be met with a 20 percent postconsumer content sheet. .        !
       Newsprint

       The City olf San Diego (#18) supports the proposed postconsumer fiber content levels for
 newsprint.    .                                           ...

       Newspaper Association of America (NAA, #22) disapproves of the recommended content
 levels for recovered and postconsumer. fibers in newsprint.  NAA feels that it is unnecessary and
 unwise to set such high levels, because the supply of recycled newsprint is small.

       Northeast Maryland Waste Disposal Authority (#31) disagrees with the recommended  v
 recovered and postconsumer fiber content levels for newsprint because the cost of adding
 recovered fiber would be prohibitive. It suggests a lower level of 25 percent recovered and
 postconsumer fiber.

                  .  •    •                   -28-   '.       '             '

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   -     Canadian Pulp and Paper Association (#38) claims that the recommended levels for
 newsprint will drive up the demand for old newspapers; and consequently the price of this:
 commodity to mills. This will discourage expansion ;of recycling capacity, which is contrary to the
 original objective of these draft guidelines.

        National Recycling Coalition (#L1) supports the proposed ranges of recovered and
 postconsumer fiber levels for newsprint.   ;

        Paper Recycling Coalition ,(#L5) questions the recommended postconsurrier fiber
 percentages for  newsprint, because it is likely that overissue newspaper and. magazines have been
 counted as postconsumer content.  Because EPA's definition of "postconsumer" does not include^ -
 overissue, the recommended postconsumer levels should be reexamined.
TISSUE PRODUCTS
       .General Comments

       James River (#10) does not support the RMAN as proposed because the shortage of
recovered material will force it to expand its search for fiber, thereby increasing both collection
costs and the amount of nonrenewable fuel used for transportation. As recycling increases, the
company also must appropriately dispose of greater amounts of deinked residue. Overall, James
River believes that EPA should not finalize the proposed guidelines in the towel and tissue area
because; the industry is already overstimulated and in short supply of recovered fiber.

       Scott Paper (#11) disagrees with the proposed standards for tissue products, because
they will gridlock further  investment as many existing large mills will delay their investments due
to uncertainty, especially  in light of recent price and availability problems for wastegaper. It
states that the market is overstimulated, a fact that EPA does not understand because it has not
property researched the consumer market.
                                          -29-

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       Fort Howard (#12) supports the proposed levels of recovered fiber content for all tissue
              ".       '                                            •.'.'•'
products, but believes that the differentiation between recovered fiber and postconsumer fiber is
unnecessary and potentially harmful.  If EPA must include postconsumer levels, they should be
no higher than those levels prescribed in EPA's existing paper guideline.

       Markets for Recycled Products (#16) believes that the postconsumer levels for tissue
products are feasible and push the market .just enough. This commenter disagrees, however, with
the recovered fiber levels for commercial tissue (and target for consumer tissue) because they
simply reward certain companies without allowing room to expand, while they close others out of
federal and other markets.  Lower percentages would also remove the requirement to calculate
percentages  of virgin and recovered fiber in mill broke and would allow for nonfiber virgin
additives.                               .       •  '   .                 '

       The City of San Diego (#18) disagrees with the.proposed postconsumer fiber content
levels for tissue products and believes that the standards should be stated as the lowest
acceptable postconsumer content percentage.

       The Tissue Division of the American Forest & Paper (#30) questions the need to revise
the percentages for tissue products, given the effectiveness of the 1988 guidelines.

       Northeast Maryland Waste Disposal Authority (#31) believes that the low ends of the
recovered and postconsumer fiber level ranges are appropriate but is concerned that the high end
of the range will limit the number of manufacturers that can provide such products.

       Georgia-Pacific (#37) questions the  need to change the standards for tissue products,.
because these products already contain such high levels of recovered fiber.  The strong market
for "recycled" tissue has already forced several small manufacturers out of business, and the new
recommendations' will only worsen the situation.                    .
                                           -30-

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        Tissue Producers Coalition (#43) takes issue with the levels recommended for tissue
  products and states that EPA should maintain the commercial tissue products content levels as
  established in 1988.  The coalition suggests lowering the percentages for commercial products to
 ' more realistic levels.                                        •                  ,
          , • '                     • '      '   i '    "       '         '      '   ,  *> '

        National Recycling Coalition (#L1) believes that EPA's recommended levels for
  recovered and ppstconsumer fiber levels are too low.  NRC believes that the lowest range for
 postconsumer fiber in commercial and consumer tissue  should be 40 percent.
        Designating consumer tissue products

        James River (#10) states that EPA has no legal basis and should not attempt to provide
 guidelines for consumer products, thereby removing consumer choice, dictating manufacturing
 technologies, and fueling the recovered fiber crisis facing the industry today.   '

        Scott Paper (#11) strongly believes that EPA should abandon content standards for
 consumer tissue products and should explicitly state that the RMAN is not intended for     .
 consumer products.                                         .     .'...'.

        Fort Howard (#12) believes that establishing different levels  for. commercial and
 consumer tissue products is unnecessary and potentially harmful because the same types of
 products are sold into both markets.  One EPA recommendation for tissue products would be
 sufficient.  Furthermore, Fort Howard does not believe that EPA should influence the
 purchasing preferences of government personnel for products used in the home.

       Potlatch (#13) states that extending the-guidelines to the consumer market will cause
 disruption in the market, increase fiber costs, and decrease product quality. This commenter
infers that consumer products should not be designated.
         -•"..'••       "         '7              '           '      "           '
       The Tissue Division of the American Forest & Paper Association (#30) opposes
including consumer tissue products in the RMAN.                  •      '

                ••'•'•  '-   •            -31-      '    :        "   '    :,   . .      : •

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        Tissue Producers Coalition (#43) suggests removing consumer tissue products from the .
 RMAN. '       '                   .               '  '.       '             .       '
       Bathroom tissue
        Potlatch (-#13) disagrees with the proposed recovered and postconsumer fiber content
 levels for consumer bathroom tissue. High recovered fiber content in consumer tissue products
 will give them a poor market reputation from which it might take years to recover.
       Industrial Wipers           .               ,           ,

       Kimberly-Clark (#20) believes that this category should be divided into General Purpose
 Wipers and Specialty Wipers. If EPA accepts this change, the proposed content levels are
 achievable and practical for the general purpose category.  In the specialty use category, the.
' company suggests a recovered fiber percentage of 0 to 100 percent and a postconsumer fiber
 percentage of 0 to 40 percent.                                            ,        •
 PAPERBOARD AND PACKAGING PRODUCTS
        General Comments     '..,-'•

        The City of San Diego (#18) believes that the proposed postconsumer content levels for
 paperboard and packaging products are adequate, except for brown paper.

        The Containerboard & Kraft Paper Group of the American Forest & Paper Association
 (#23) believes that forcing all containerboard to contain some arbitrary level of recovered and
 postconsumer fibers  restricts their freedom to tailor products to individual customers,and uses.
                                           -32-

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        The Recycled Paperboard Division oif the American Forest & Paper Association (#26)
 states that the specific percentages for all products in the paperboardand packaging category are
 too high, given the current and expected conditions in the recovered fiber supply market.  It also
 disagrees with the need to set individual content levels for the different kinds of paperboard
 products because the vast majority already incorporate 100-percent recovered materials.

        Paper Recycling Coalition (#L5) requests that the statement referencing "food grade uses
 of paperboard" and "footnote 2" be stricken from the document, because the casual reader might
 not distinguish among the different food packaging requirements and conclude that it is unsafe
 to package food in recycled or recycled content paperboard.  It also objects to the separate
 listing of carrierboard and cautions against setting separate requirements  for all potential end
 uses of paperboard, especially for applications where the government is not a major purchaser.
       Corrugated Containers

       International Paper (#9) disagrees with the proposed recovered and postconsumer fiber
content levels for corrugated; containers (<300 psi), because they do riot appear to be
economically or logistically feasible. .The company urges EPA not to set any specific minimum   '
recovered content levels for corrugated containers.

       Chesapeake Paper Products (#14) asserts that recovered and postconsumer fiber content
levels for corrugated containers should be 0 percent.  .The company believes that incentives to
use recovered fibers are no longer  required.            .

       Mead (#15) disagrees with  the proposed recovered, and postconsumer fiber content levels
for corrugated containers. The company suggests 25 percent for both recovered and
postconsumer fiber content.                                                      •
                                           -33-

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       The Container-board & Kraft Paper Group of the American Forest & Paper Association
 (#23) believes that the proposed content, levels for corrugated containers are impossible to reach
 industrywide. These levels ignore the fundamental requirements of the finished product, disturb
                                  • .  v.       '              '                       '
 the industry's competitive environment, promote inefficient use of raw materials, and encourage
 imports.  •                                              ."   •       '...",_

     "  Union Camp Corporation (#24) disagrees with the proposed recovered and
      i                      .                 •
 postconsumer fiber content levels for corrugated containers. The company states that the levels
 are impractical, jeopardize quality, and increase costs.

       National Recycling Coalition (#L1) applauds EPA for suggesting high recovered and
postconsumer content ranges but feels  that some flexibility is warranted because of current
supply shortages and increasing fiber prices.
       Folding Cartons

       The Recycled Paper-board Division of the American Forest & Paper Association
(RPD, #26) believes that EPA should remove the footnote to Table A-4, which indicates that
the recovered fiber content ranges for folding cartons "are not applicable to all types of         '
paperboard." RPD believes, that the footnote undermines both EPA's goal to encourage
purchases of paper products at the highest level of recovered fiber and its decision to rename the
entire category "Paperboard" rather than "Recycled Paperboard.11 RPD also believes that EPA
should not recommend separate content levels for solid bleached paperboard.

       The Bleached Paperboard Division of the American Forest & Paper Association (#27)
does not believe that EPA should recommend content levels for solid bleached sulfate.
                                           -34-

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        Carrierboard

       , Mead (#15) disagrees with the proposed fiber content levels for carrierboard, and
 recommends 10 to  100 percent recovered fiber content and 10 percent postconsumer fiber
 content levels.                     .     •                       -''••'

        Rivenvood International (#19) supports the inclusion of recovered content levels  for
 carrierboard and believes that they have been set at reasonable and technically achievable levels.
 Riverwood believes, however, that a better suggestion would be ranges of
   • ' •   -                     •'.-''                          >      *        '
 15 to 25 percent recovered and 10 to 15 percent postconsumer fiber content to give
 manufacturers some flexibility as technology changes.
       Brown Papers.

       Internationa! Paper (#9) disagrees with the proposed recovered and postconsumer fiber
content level for brown papers.  The company urges EPA not to. set any specific minimum  ,
recovered and postconsumer fiber content limits because they will only exaggerate the problems
associated with the current demand/supply imbalance in recovered paper grades.

       Chesapeake Paper Products (#14) disagrees with the proposed recovered and
postcorisumer fiber content levels for brown papers. The company believes that such high levels
will lead to poor product quality.                 .

       The City of San Diego (#18) believes that the postconsumer level for brown paper should
be set at 10 percent.     !                  "
                                          -35-

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MISCELLANEOUS PAPER PRODUCTS
       General Comments                      .

       The City of San Diego (#18) supports EPA's recommended content levels for
postconsumer materials in miscellaneous paper products.
       Trey Liners

      •International Paper (#9) disagrees with the proposed postconsumer fiber content level
for tray liriers because the definition of postconsumer fiber excludes printed, unread materials.
IP suggests retaining the 100 percent recovered fiber content level but lowering the postconsumer
level to 50 percent.             ..
                                         -36-

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                                     SECTIONS
           COMMENTS ON MEASUREMENT/SPECIFICATIONS, AND
                                  RECYCLABILITY
 COMMENTS ON MEASURING BY FIBER WEIGHT AND COUNTING THE RECOVERED
 MATERIAL PORTION OF MILL BROKE                           ,                    \
     .  Repap Wisconsin "(#3) agrees that recycled fiber percentages should be based on the
 fiber weight of a sheet of paper rather than the total weight of the paper.

       Union Camp (#6) agrees with a fiber-weight calculation of postconsumer and recovered
 fiber content but points out the need for additional clarification, because some-fillers are not
 fully removed in the repuiping and cleaning process.  Union Camp strongly recommends that the '
 numerator of the calculated fiber weight fraction allow for the inclusion of whatever material is
 carried with the actual fiber from a fiber recycling facility.                   .    .
 .•/"•'     •                      -        ,"'•'•        -   ,
       Apple ton Papers (#7) supports counting mill broke generated in a papermaking process
 using postconsumer and/or recovered fiber as a feedstock towards postconsumer fiber or
. recovered fiber content.

       Cqnservatree Information Services (#8) agrees with EPA's proposed fiber weight basis
 for recovered material content measurement. Fiber weight measurement, however, requires less
 fiber in high grade'papers; therefore, Conservative contends that content requirements must be
 set at higher levels than those previously used for sheet weight measurements to be meaningful.
                                                  ' •  \                       ,
       International Paper (#9) strongly supports EPA's recommendation to measure recycled
content based on fiber weight.
                                        -37-

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       Fort Hovyard (#12) supports EPA's determination to use a fiber weight method for
calculating recovered and postconsumer fiber content levels. Fort Howard also strongly agrees
that mill broke generated from recovered and postconsumer fiber feedstocks should count
towards recovered and postconsumer content in the end product:

      ' Mead (#15) supports EPA's use of fiber weight as the basis for calculating recycled
content.  Mead also supports the change that would allow mills to count broke from recovered
fiber feedstocks into the total calculation of recycled content.

       Markets for Recycled Products (#16) believes that the  fiber-weight basis tot calculating
recycled content poses  a few problems. Recovered paper and paperboard contain additives that
are carried through in the repulping process and are retained in the finished paper. This
commenter encourages EPA to allow for such "nonfiber furnish", and suggests the following
language be added to the measurement section in the RMAN:
       Nonfiber materials that are introduced into the paper manufacturing process as  •       I
       integral components of the recovered or postconsumer  fiber  furnish and that are        {
       retained in.the finished product shall count toward the  total  percentage of fiber
       weight when calculating recycled content.               .        .   .
This commenter also opposes crediting mill broke  generated from recovered feedstocks because
calculating the proportion that should be credited would be difficult for mills that use both virgin
and recovered feedstocks. This calculation would also create additional recordkeeping
requirements, increase costs, and invite dishonesty. Markets for Recycled Products encourages
EPA to set recovered fiber levels low enough so that mills can use their broke wherever it is
most cost effective, rather than setting recovered fiber standards at 100 percent (which precludes
broke from being credited even as a nonrecovered component  of the furnish).            .

       The Magazine Publishers of America (MPA, #17) agrees with EPA's methodology for
calculating recovered fiber content based on total fiber weight. MPA believes that this
measurement should exclude other materials used in the manufacture of paper, including
coatings, additives, inks, laminates, and fillers, because commercially viable technologies do not
currently exist to recover these other ingredients of paper.
                                           -38-

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        The City of San Diego (#18) concurs with EPA's recommendation that recycled content
 should be measured as a percentage of the weight of the fiber in paper or a paper product. This
 commenter disagrees, however, that broke from postconsumer feedstocks should be credited
 towards postconsumer content because.this would not help improve markets for recycled paper
 and would greatly complicate the verification and tracking process for postconsumer content
.'claims'.  '     .   "                   '          .

       The Recycled,Paper-board Divisioni of the American Forest & Paper Association
 (RPD; #26) strongly supports EPA's use of a relative comparison of weight of recovered fiber to
 total fiber because-it ensures that the calculation of recycled content is made on the basis of the
 pertinent raw material rather than on the basis of the extraneous weight of non-fibrous additives.
 RPD also,supports EPA's proposal to credit the recovered fiber and postconsumer fiber portion
 of mill broke in content calculations.                           '....••

       The American Forest & Paper Association (#28) strongly supports EPA's
 recommendation  on measurement of recovered fiber content by a relative comparison of weight
 of recovered fiber to total fiber;

       The National Recycling Coalition (NRC, #L1) supports the methodology proposed  in the
 draft RMAN for calculating the recovered fiber content of mill broke.  NRC also supports EPA's
 decision  to base the calculation of recovered fiber and postconsumer fiber on a percentage  of
'fiber weight as opposed to total product weight.

       The Direct Marketing Association (#L4) strongly supports EPA's confirmation that fiber,
weight should  be the standard for measuring recycled content.

       The Paper Recycling Coalition (PRC, #L5) commends EPA for adopting standard
industry practices with respect to the measurement of recycled content based on fiber weight.
PRC also praises EPA for acknowledging that the recycled content of mill broke can legitimately
be counted as.recycled content.                           ,   ,
                                          -39-

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COMMENTS ON SPECIFICATIONS
                                                                               •    •    «
       Appleton Papers (#7) agrees that specifications should be revised if they impede the use .
of postconsumer and recovered fiber but do not impede reasonable performance.  Appleton also
suggests that EPA streamline the-specification process to eliminate redundant and duplicative
GSA and GPO specifications.
COMMENTS ON RECYCLABILITY

    '  Union Camp (#6) states that industrial practices and the marketplace should emphasize
the 'recyclability of waste paper. While this cpmmenter expresses hope that RMAN       '    .
implementation will encourage the development of glues and adhesives that make recycling
easier, Union Camp does not endorse using a regulatory approach to address recyclability issues.

       •Appleton Papers (#7) strongly urges EPA to add recyclability as the third objective of the
RMAN.  EPA should discourage purchase of paper products that are not recyclable in the
normal office-paper waste stream. Appleton points out that over half of federal agency
purchases of multiple-part forms specify a nonrecyclable bond and carbon construction. The
carbon tissue can compose between 20 and 40 percent of a form, by weight.  Carbon paper,
however, is not readily available with recycled content nor is it normally recyclable, and
significantly degrades the value of the office-paper waste stream.          -            .

     '  International Paper (#9) believes that the wording of Section A-6 on recyclability implies
that the purchase of groundwood-containing printing and writing paper will reduce the
recyclability and/or dollar value of the Agency's office-paper recycling program. IP believes  that
this language is specifically aimed at its Springhill Incentive 100  and Hammermill Unity products.
It provides information on the recyclability of these products, and states that they are priced
competitively with their virgin counterparts and are substantially lower in cost than other
brighter, partially recycled content grades.  IP requests that the wording of Section A-6 in the
RMAN be  expanded so that agencies are instructed to consider  the overall economics of their
paper choices. IP also cautions EPA that, in encouraging agencies to assess the impact of paper

                                          -40-

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 purchases on their overall contribution to .the solid waste stream, that the recyclability issue could
 quickly turn into a life cycle assessment debate, an issue that goes beyond the scope of   ,
 purchasing guidelines.  IP further suggests that EPA revise Section A-6 on recyclability to read as
 follows: •                 '. .               '        ..      /         ,         .
        EPA recommends that procuring agencies consider the effect of a procurement .of
        a paper product containing recovered and postcon&umer fiber on their paper
        collection programs by assessing the impact of their decision on their overall
        contribution to the solid waste stream.  As an example, paper products with a '
        high groundwood  content may result in a lower receipt price for office wastepaper
        sales.  However, if the origmalpaper product waseconomically priced, the entire
        transaction may be viewed as beneficial. This is particularly true if the original    '  •
        paper 'product had postconsum'er fiber content exceeding that required by these
        procurement guidelines.                                        '

        The Recycled Paper-board .Division of the American Forest & Paper Association
 (RPD,  #26) agrees that recyclability is one of several factors that  procuring agencies" consider
 when making purchasing decisions, but cautions that  it should not be the sole determinant, in the.."..
 purchasing decision.  RPD does  not believe that procuring agencies wilf have difficulty finding
 markets for their recyclable paper.       '

        Northeast Maryland Waste Disposal Authority (#31) supports EPA's recommendations
 to consider recyclability.                      •-.  •

       American Forest & Paper Association (#28) encourages EPA to focus its recyclability
 efforts on the traditional contaminants that occur in collection programs, such as laminated,
waxed, or coated labels, food waste and paper  covered with food, residue; glass; hazardous
materials; rubber; metal; and plastic wraps, films, and tapes.      .                 .<-.

       National Recycling Coalition (NRC, #L1) supports the notion that procurement officials
should consider the  recyclability of paper products in addition to recycled content.  NRC also
believes that the purchasing decision should reflect the "upstream" environmental benefits of
recycling as well as the waste reduction benefits.
                                           -41-

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       Paper Recycling Coalition (PRC, #L5) believes that it is appropriate for EPA to provide
guidance-on the need,to consider recyclability in purchasing decisions. In addition to.citing
copier paper made with recovered groundwood papers as an example of a product that could
undermine paper recovery programs, PRC encourages EPA to provide guidance about other
contaminants, including glues and adhesives, which downgrade the quality of recovered paper.
                                          -42-

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                                      SECTION?
                           COMMENTS ON DEFINITIONS
 "POST-CONSUMER"
             •       '      -         *       • "    "      " r,     ''    '
        Repap Wisconsin (#3) favors  the Recycling Advisory Council definition of "postconsumer
 equivalent" that includes printed and/or materials requiring deinking. Repap believes that EPA's
 proposed narrow postconsumer definition will increase costs and -discourage increased use of
 postconsumer fiber.,     •    .   . .                                      -

       Union Camp  (#6) believes that the proposed postconsumer definition-misses the
 opportunity to recover printed or converted materials that require full processing in order to be
 used in a finished product. This commenter argues that materials such as printer overruns and
 fully converted materials that must be repulped, screened, deinked, .and reprocessed should
 qualify as postconsumer materials. In addition, Union Camp states that the more complex the
 definition of postconsumer, the more difficult it will be for an infrastructure to supply future  i
 feedstocks and ensure the removal of good fiber from landfills.                             ,

       Conservatree Information Services (#8) agrees with the proposed postconsumer
definition because it is appropriately consistent with the definitions contained in RCRA and in
Executive Order 12873.  Conservatree opposes expanding the definition to include preconsumer
deinking categories.
                                         -43-.

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        International Paper (IP, #?) cautions that EPA's specific elimination of overissue
 publications from the definition of postcpnsumer fiber is unnecessary and may result in
 additional waste moving to landfills. Denying postconsumer status to newsstand returns would
 render these materials as less valuable in recycling efforts.  IP cites previous industry attempts to
 persuade EPA to adopt the term "processed recovered fiber" to address this issue. This
 commenter also believes that publishers' practice of producing enough magazines and        •
 newspapers to meet anticipated customer demand is a competitive marketing decision beyond
 EPA's purview, but 'that EPA should ensure a market for returns that can be economically  .
 collected for deinking.        .          •      .     '                             '        ',

• '      Fort "Howard (#12) strongly opposes^ excluding overissue publications from the definition
 of "postconsumer."  This  commenter argues that RCRA 6002 (h) does not limit consumers to
 individuals or households, but rather includes businesses as consumers.  It further argues that
 excess or obsolete inventories of publications have fulfilled their intended end use by having been
 available for review or distribution, and that conceptually, over-issue publications are no different
 from unused letterhead paper or envelopes that have become obsolete.  Fort Howard requests •
"that, at the very least, EPA clarify what it means by "over-issue" publications so that it does not
 harmfully restrict sources of postconsumer fiber.
      *              ' s   -                        '                  .
        Potlatch (#13) believes  that the proposed postconsumer definition makes little sense
 because recovered paper from the converting plant at the tissue mill would be mill broke, while
 the same material at a separate converting plant would be recovered fiber.

       'Markets for Recycled Products (#16) supports the statutory definition of postconsumer
 as well  as the  proposed clarification. Together, they remove all ambiguity and agree with the
 postconsumer definition used for other products and materials in EPA's Comprehensive
 Procurement Guideline.        '
                                           .-44-

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.;         Magazine "Publishers of America (MPA, #17) believes that a broad interpretation of
   : postconsumer fiber is needed to encourage increased investment in recycling, capacity, ^specially
         ,                                   *                             ,
 .  in view of current and anticipated shortages in recycled pulp supplies. MPA also opposes any
   distinction between preconsumer and postconsumer materials because it serves no purpose.
   Limiting the definition reduces manufacturers' ability to obtain recovered fiber that can be
'•   counted towards postconsumer content. .                                          .    •

          The City of San Diego (#18) supports the proposed postconsumer definition and agrees
   that it should not include preconsumer materials that require deinfcing or contaminant removal.

         Bowater (#21) believes that excluding printers' overruns, converters' scrap and/or
   overissue publications from consideration as postconsumer materials clearly violates the statute
   [RCRA] and tramples protected speech. Bowater asserts that EPA's proposed definition
   contradicts codified Congressional objectives of keeping solid waste from landfills, promoting  .
   improved resource  recovery, and establishing cooperation between government and private
   enterprise. This commenter contends that Congress clearly stated that discarded overissue
   magazines are postconsumer materials, because they are papers that enter and are collected from
   the municipal solid waste stream. Bowater suggests that EPA revise the RMAN to  state that
   paper consumed in the publication process has reached its end use as a consumer item, either
   when it is purchased and. discarded by a reader or when it is returned from  the newsstand or
   printer as outdated. Bowater further asks EPA to clarify that paper consumed in the printing
   process and either discarded or diverted from the solid waste stream has also reached its end
   use, and therefore constitutes postconsumer waste.      .  :    '

         Newspaper Association of America (NAA, #22) believes that distinguishing between pre-
   and postconsumer sources of recovered paper is an unnecessary, unworkable, and burdensome
   step that has outlived its  intended purpose.                 .

         The Container-board and Kraft Paper Group of the American Forest & Paper
   Association (#23) opposes any distinction between pre- and postconsumer recovered fibers
   because they both come out of the waste stream, have similar properties, appear identical under
   a microscope, and cannot be separated by any known scientific test.   •

'   '    •     '••;'.•         .     •'.•    '  --45-     •    ••'••'.-     •   ..  •      .-

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       The Recycled Paperboard Division of the American Forest & Paper Association
(RPD, #26) asserts that any definition of "postconsumer" is arbitrary.               .

       The Newsprint Division of the American Forest & Paper Association (#29) believes that
EPA's proposed definition should be revised so that paper consumed, in the publication process
is counted as postconsumer fiber, because such paper has reached its end use as a consumer
item, either when it is purchased and discarded by a reader or when it is returned from the
newsstand or printer as outdated.  EPA should also clarify that paper consumed in the printing
process and either discarded or diverted from the solid waste stream has also reached its end use
and should be considered as postconsumer waste.                              ,
       L        \            f                    '               '               '
       Northeast Maryland Waste Disposal Authority (#31) agrees with the narrow definition of
postconsumer and that fiber derived from printers over-runs, converters scrap and overissue
publications is not postconsumer fiber.

       Random House (#42) believes that overissue publications.should be considered as
postconsurner, arguing that such a classification is necessary to make book recovery cost-efficient
and worthwhile.

       The Tissue Producers Coalition (#43)  maintains that separate categories for pre- and
postconsumer waste are not necessary. The distinction has no real meaning in  a recovered paper
market already utilizing all available supplies of preconsumer recovered materials.

       Lindenmeyr Paper (45) strongly urges EPA to classify overproduced books as
postconsumer material. Lindenmeyr believes that, by excluding overissue publications, EPA
reduces the waste value of a publisher's unsold inventory, thereby increasing the chance that such
inventory would be landfilled. EPA's narrow definition also deprives the book  publishing
industry of a source of potential postconsumer fiber.
                                          -46-

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        National Recycling Coalition .(NRG, #L1) recommends that EPA's postconsumer
• definition be expanded to include "comparable" materials as defined in the'Recycling Advisory
 Council's report, such as overissue publications and printers' 'scrap with printing or dye. NRC
 cautions  that EPA's proposed, narrow definition will increase the costs to produce recycled paper
 and therefore discourage its' use.  NRC .further asserts "that conforming to the postconsumer
 definition in Executive Order 12873 is not sufficient rationale for retaining a narrow definition in
 theRMAN, -'.''.    '    ' .  .    "•-.'••    ,      .        ;''.,-            '

        Paper Recycling Coalition (PRC, #L5) believes that the distinction between
 postconsumer and recovered paper is arbitrary, and contends that the only legitimate source- .
 based paper distinction is between virgin fiber and recovered fiber.  PRC cautions that EPA's
 clarification of the definition might have unintended consequences, because many manufacturers
 have been classifying overissue as postconsumer and have reported it as such to .EPA.  Thus,
 postconsUmer-content figures might be inflated because they include overissue. While PRC
 opposed a postconsumer distinction altogether, for the sake of clarity it suggests the following
 modifications to EPA's proposed postconsumer definition:

       »     The word "waste" should be removed from the term "mixed waste paper." The  "
             term "mixed paper" is sufficiently clear. Waste implies garbage, something that
             must be landfilled or incinerated.  .   •.  ,   ;
       •     The term "fibrous wastes" should be changed to "fibrous materials" to avoid
          .   implying that .materials recovered from the municipal waste  stream for recycling
             are still waste products.
"WASTE PAPER," "RECOVERED FIBER," AND CLARIFICATION ON REPULPING
REQUIREMENTS
       Repap Wisconsin (#3) .comments,."the statement that 'material must be repulped' is
confusing, unless the intent is that rolls/sheets are not repulped in water again and therefore
cannot be considered recovered fiber."
                                          -47-

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        Cojaservatree Information Services (#8) agrees with eliminating the waste' paper
 categories in the existing paper guideline and observes that waste paper often includes
* inappropriate mill broke materials.  This commenter also agrees that materials must be repulped,
 and that recovered fiber should exclude materials such as obsolete inventory and off-specification
 products generated at the mill after the papermaking process ends. Conservatree also agrees
 with the explicit exclusion of forest residues.

        James River  (#10) agrees that materialmust be repulped to count as recovered fiber.
 The company believes, however, that the proposed mill broke and recovered fiber definitions are
 confusing because mill-generated materials would be excluded,  while equivalent materials from
 paper merchants, wholesalers, dealers, printers, converters, or consumers would count as
 recovered fiber. James River suggests that EPA consider adopting a draft ASTM definition of
 recycled fiber that reads:  "fiber derived from recovered material, excluding wood residues and
 sawmilling residues, which has been repulped or reintroduced into the paper manufacturing
 process and made into a product or form  usable in the manufacturing process."

        Mead (#1'5) disagrees with the proposed definition of recovered fiber and suggests that
 EPA adopt the RCRA 6002(h) definition  of "recovered material," which includes fiber waste
 generated after the paper machine rewinder. Mead suggests adding a caveat, if needed,
 requiring that recovered fiber be repulped in order to be counted.                        .

        Markets for Recycled Products (#16) supports the proposed recovered fiber definition
 and agrees that npn-repulped paper should be excluded, along with sawdust and forest residues.

        The City of San Diego (#18) applauds EPA's use of the term recovered fiber in lieu of
 waste paper, as a means of communicating the value of the materials. San Diego also concurs
 with the requirement that materials must  be repulped.

        The Containerboard and Kraft Paper Group of the American Forest & Paper
 Association (CKPG, #23) has no  objection to the proposed definition of recovered fiber, but
 does oppose the exclusion of materials currently .considered recovered that would be  reclassified
 as mill  broke under the proposed broke definition.

                                           -48-    '.'•••

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        The Printing-Writing Paper Division of the American Forest & Paper Association (#25)
 -recommends that EPA should continued to use the definition of recovered materials in RGRA
'  6002(h) to create uniformity with the Executive Order and establish a clear understanding of
  where mill broke ends and recovered fiber begins.

        The Recycled Paperboard Division of the American Forest & Paper Association (RPD,
  #26) applauds eliminating the term waste paper. RPD also agrees with EPA's clarification that
  recovered fiber must be repulped and riot just recovered, to count toward recovered fiber
 content, and that forest residues do not count toward recovered fiber content.

        American Forest & Paper Association (#28) believes that  EPA should continue to use
 the well-established RCRA definition of recovered materials.                     •

       .The Tissue Producers Coalition (#43) suggests that EPA should add a statement under:
 recovered fiber that only repulped fiber can be classified as recovered fiber for  recycled content
 claims.   .                   .   .

       National Recycling Coalition (NRC, #L1) strongly supports EPA's proposal to
 discontinue using the  term waste, paper in favor of recovered fiber. NRC also supports excluding
 side trimmings, culls, end rolls, butt rolls, rejected stock, and obsolete inventories of unfinished
 paper from the definition of recovered fiber.  NRC believes, however, that converting scrap and
 obsolete inventories of finished product generated outside of the paper manufacturing process
 should qualify as recovered fiber.

       Direct Marketing Association (DMA, *L4) concurs with and supports EPA's proposed
terminology change from waste paper to recovered fiber. DMA also recommends that EPA
retain the RCRA definition for recovered fiber (e.g., recovered materials) to create uniformity
with the Executive Order and to establish a clear understanding of the point at which mill broke
ends and recovered fiber begins.                                  '
                                          -49-

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        Paper Recycling Coalition (PRC, #L5) commends EPA for ending its use of the term
 waste paper because it implies a second-rate product and is a barrier to recycling. PRC also
'supports the clarification that materials must be repulped, not just recovered, to count toward
 recovered fiber content.  PRC also agrees with clarifying that forest residues do not quality as
 recovered fiber, and asks EPA to eliminate any allowances for sawdust. PRC also suggests the
 following 'modifications to EPA's proposed definition of recovered fiber:

       . •     The word "waste" should be removed from the term "mixed waste paper."  The
              term "mixed paper" is sufficiently clear.  Waste implies garbage, something that
              must be landfilled or incinerated.
        •     The term "fibrous wastes" should be changed to "fibrous materials" to avoid
              implying that materials recovered from the municipal waste stream for recycling
              are still waste products. •    '       ,
 MILL BROKE

       Mohawk Paper Mills (#2) opposes the proposed expanded definition of mill broke
 because it will disqualify materials that have previously served ,as sources of preconsumer fiber.

       Wisconsin Tissue (#5) believes that EPA's revised definition is too broad. This      •
 commenter suggests using th6 proposed definition developed by ASTM, as follows: "Any paper
 generated in a paper mill prior to the completion of the paper manufacturing process .which is
 unsuitable for subsequent application but can-be reused in the  paper manufacturing process."

       Conservative Information Services (#8) agrees with expanding, the definition to include
 many of the materials generated in mill-based finishing processes.
                                           -50-

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        International Paper (#9) believes that the existing definition of mill broke is easily     '
 understood and universally accepted within the industry.  It urges EPA not to change from the
 1988 definition of the papermaking process [a component of the mill broke definition]. This
 commenter believes that the proposed broader definition is unnecessarily confusing, because
 obsolete inventories from paper manufacturers and recovered fiber generated in paper mill
 finishing operations would be considered as mill broke, while equivalent materials from paper
 merchants, converters, wholesalers, and others would qualify as recovered fiber.

        James River (#10) disagrees with EPA's proposed changes to ".mill broke" because scrap
 materials generated in finishing operations often include wet strength additives, coatings, dyes,
 arid inks that require extra processing prior to reuse. .These materials are recovered or diverted.
 from solid waste and are repulped to be reused as recycled fiber.  James River also believes that
 the proposed "mill broke" and "recovered fiber" definitions are confusing because mill-generated
 materials would be considered as broke, while equivalent  materials from paper merchants,
 wholesalers, dealers, printers, converters, or consumers would count as recovered fiber. This
 commenter urges EPA not to change the current definition of this term and tp consider adopting
 the draft ASTM definition that reflects general consensus: "any paper generated in a paper mill
 prior to the completion of the paper manufacturing process which is unsuitable for subsequent
 application but can be reused in the paper manufacturing  process."

       Scott Paper (#n) supports and incorporates by reference the specific recommendations
 offered by the American  Forest & Paper Association on this topic.    :
                       '        ."   • •   -      t      '       •       - , ,  '    .             . .     |
       Mead (#15) disagrees with the proposed definition and suggests that EPA adopt the
 RCRA 6002 (h) definition.    '                 .                                 '.

       Markets for Recycled. Products  (#16)^supports the  proposed definition, stating that it Is a
fair compromise because  most types of easily measured paper mill scrap  are excluded.
                                          -51-

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       The Container-board and Kraft Paper Group of the American Forest & Paper
Association (CKPG, #23) strongly opposes the proposed broadening of the definition because it
is confusing, unfair, and unenforceable. CKPG strongly  encourages EPA to continue to use the
                                   • '_                "               '               ,i
mill broke definition found in RCRA, which is also used in the Executive Order.

       The Printing-Writing Paper Division of the American Forest & Paper Association (#25)
recommends that EPA should continued to use the definition for mill broke in RCRA 6002(h) to
create uniformity with the Executive Order and to establish a clear understanding of where mill
broke ends and recovered fiber begins.                        .            •

       The Recycled Paperboard Division of the American Forest & Paper Association (#26)
objects to the proposed expansion of the mill broke definition.  It believes that the existing
definition is easily understood and universally used within the paper industry and that
introducing a new definition would be unfair and  unwarranted.

       American Forest & Paper Association (AF&PA, #28) believes that EPA should continue
to use the well-established definition of mill broke because it is easily understood and universally
used within the industry. AF&PA also contends that introducing a new definition after seven
years of education and widespread use would be unfair.  In addition, the proposed broadened
definition is confusing because it would include fiber generated in a paper mill that is equivalent
to recovered materials generated by converters and others. AF&PA also believes that it is  ,
arbitrary to consider obsolete inventories from paper manufacturers as broke, while obsolete
inventories of the same paper grades held by paper merchants, wholesalers, and others would
qualify as recovered fiber.

       The Newsprint Division of the American Forest  & Paper Association (#29) believes that
the current RCRA. definition of mill broke should be retained. The proposed definition is
confusing because it includes items that are equivalent to converting scrap and other materials
that clearly count as recovered fiber. The newsprint industry has also made substantial
investments in education and capital based on the existing definitions.
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          *1.6 Tissue Division of the American Forest & Paper Association (#30) believes that the
  current RCRA definition of mill broke should be retained. The proposed, expanded definition is
  confusing because it includes  items that are equivalent to converting scrap and other materials.
  that clearly count as recovered fiber. The tissue industry has also made substantial investments
  in education and capital based on the existing definitions.

        Northeast Maryland Waste Disposal Authority (#31) supports excluding the specific
 items identified by EPA as mill broke from counting as recovered fiber.

        Rainy River Forest Products  (#32) supports the existing definition of mill broke because
 it is easily understood and widely used within the industry.                                 .

        International Papers, Fine Business Papers (#35) believes that excluding mill broke does
 not accomplish anything. Not allowing mill-generated broke to count as recovered material
 would /result in landfilling much of it. In addition, mills cannot afford to produce recycled
 business papers without using  their own broke.              '

       Georgia-Pacific (#37) takes strong exception to-EPA's proposed changes to mill broke
 and questions why EPA would propose something that would raise the costs associated with
 recycling while do nothing about recovering more paper for recycling.

       The Tissue Producers Coalition (#43) believes that the  current mill broke definition
 should be retained.

       National Recycling Coalition (NRC, #L1) supports the proposed broader definition of
 mill broke and the exclusion of side trimmings, culls, end rolls, butt rolls, rejected stock, and
obsolete inventories of unfinished paper from the definition of recovered fiber.  NRC believes,
however, that converting scrap  and obsolete inventories of finished product generated outside of
the paper manufacturing process should qualify as recovered fiber.
                                          -53-

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       Direct Marketing Association (#L4) recommends that EPA retain the RCRA definition
of mill broke to create uniformity with the Executive Order and to establish a clear
understanding of the point at which mill broke ends and recovered fiber begins.

    .   Paper Recycling Coalition (PRC, #L5) asserts that the proposed revision to the mill  .
broke definition is vague and .potentially troublesome for the paper industry. The definition has
the potential to cause confusion because it does not specifically distinguish between mill-site
byproducts and offsite byproducts. PRC also believes that classifying byproducts of the finishing
operation as mill broke is a problem," because certain converting operations might also be
considered "finishing" operations. PRC suggests further clarification that only the byproducts of
finishing at the mill will be classified as mill broke., PRC also suggests that the definition of mill
broke should specifically state that the recycled content of mill broke can be counted in
determining the recycled content of the finished product. As drafted, the definition does not
accurately reflect the guidance provided in Table 13, which clearly distinguishes between  fiber
recovered from the mill and fiber recovered from outside the mill.  Similarly, PRC  suggests that
EPA distinguish between finishing operations that take place within the mill from similar
operations undertaken in a converting process at a separate location.
                                            -54-

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                                      SECTIONS
                          MISCELLANEOUS COMMENTS
                           \     • '                . .     .

 FURTHER DELINEATING OR DELETING DESIGNATED ITEMS

        International Paper (IP, #4) requests clarification on the scope of items covered in the
 "supercalendered" category. IP's Nicolet Division produces a line of supercalendered papers for
 pressure-sensitive backing papers and glassine. 'The backing papers are used for pressure
 sensitive labels, and the glassine is used for envelope windows and direct food contact packaging.
 IP also requests that EPA exclude tabulating cards.  IP asserts that, due to exacting physical
 requirements (particularly dimensional stability requirements), this grade can only accommodate .
 limited amounts of recovered materials (primarily forest residues), and no postconsumer fiber.

       James River (#10) takes issue with the fact that EPA has proposed only 10 percent
 total/postconsumer content for supercalendered but proposes 20 percent for  uncoated
                      - -  - •    -      _           ,        '                        j.
 groundwood specialties, because these grades compete with each other. James River
 recommends that the recycled content for all groundwood printing and writing papers purchased
 by the U.S. Government be set at a minimum of 10 percent postconsumer fiber. For
 groundwood forms bond, however, James River believes that there may be a  valid reason to set
 the level at 20 percent.

       The Container-board & Kraft Paper Group of the American Forest & Paper Association
 (#23) believes that rnultiwaH paper sacks, retail and fast food bags, grocery.bags, and wrapping
 papers should not be lumped together under "brown papers" because they all have different
 functional requirements and can accommodate different amounts of recovered fiber. Likewise,
 tubes, cores, drums, and cans are different products and should not be lumped together.

       The Printing & Writing Paper Division of the American Forest & Paper Association
 (P&WPDj #25) believes that machine finished (MF) uhcoate,d groundwood papers should carry
a 10 percent postconsumer fiber content level for technical and competitive reasons.
                                         -55-

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RECOVERED MATERIAL CERTIFICATION AND VERIFICATION

       Union Camp (#6) questions EPA's statement that the level of information in the
marketplace is adequate to track postconsumer'and preconsumer materials.  This commenter
asks for EPA to explicitly state that the "operating standards" that are defined (presumably by a
producer of pulp or paper .claiming recovered material content) should, suffice for defining the
fraction of postconsumer material in a given feedstock. Union Camp believes that such
clarification is necessary to avoid misinterpretation and possible legal implications.

       International Paper (#9) contends that," because there is no test to distinguish pre- and
postconsumer fiber, extensive and costly reporting and recordkeeping are required by all involved
parties.

       Scott  Paper (#10) recommends that EPA clarify the measurement and time requirements
for the certification of recycled content. Scott points out that the 1988 paper guidelines assume
that all paper products are made-to-order. Tissue products, however, are made-to-stock and the
actual recovered fiber content varies with normal operating conditions.  Without EPA guidance,
there is no assurance that content is measured in a uniform manner through the marketplace.
Scott recommends a quarterly certification that requires achieving at least 80 percent of the
standard per quarter, with 100 percent achievement over a four-quarter average.
                                                         .  '   • .         .     '-..•/'
       Mead (#15) observes that mills cannot control the amount of usable recycled fiber.that is
•utilized in each  roll of paper, and asks EPA to clarify the issue of recycled content certification.
Mead recommends that mills be allowed to provide certification based on a documentable 90-day
'average, but  suspects that federal procurement law may restrict the use of reasonable averaging.

       Bowater (#21) believes that EPA is optimistic in stating that there is sufficient
 information for mills to track postconsumer material  to certify recycled content.  The RMAN
 definition of postconsumer will  require tracking that will result in higher costs for some mills,
 according to Bowater.      .               .           .                 .
                                           -56-

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        The Newsprint Division of the American Forest & Paper Association (#29) states that by
 adopting the RMAN definition of postconsumer, EPA would require that mills add costly
 tracking and sorting steps to paper procurement to ensure that they are meeting the
 postconsumer content requirement.  :          •   .
 SAWDUST AS RECOVERED FIBER
           >•**'.'           . -,.              '•      '    ' • ;           •      V
        Conservatree Information Services (#8) believes that the substitution of sawdust for
.postconsumer content allowed in the Executive Order and the current EPA guideline should be
 eliminated.               .     •        •                                      •

      •James River  (#10) finds a discrepancy between EPA and Executive Order 12873 on how.
 forest residues, including sawdust, are considered with regard to recycled content, and urges EPA
 to clarify its guidance regarding these recovered materials.

       Lincoln.Pulp & Paper Co. (#36) reiterates support for the alternative materials provision
in Executive Order 12873. Lincoln also provides information on its use of wet sawdust to make
recycled paper and states that such use has essentially eliminated new waste sawdust piles in
Maine.                                       :                 .

       National Recycling Coalition (#L1) opposes allowing sawdust and other alternative •
materials to count towards recovered fiber content.

       Paper Recycling Coalition (#L5) urges EPA to seek elimination of any allowances for
sawdust.  .
                                          -57-  '

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ENERGY ISSUES AND COST/BENEFIT IMPLICATIONS OF PAPER RECYCLING

       James River (#10) believes that there is adequate and substantiating evidence indicating
that paper-to-energy is a viable and good method of disposal for some streams of recovered
paper materials that cannot be economically recycled. James River believes that EPA should
consider the energy impacts of its RMAN recommendations.              .          •

       Potlatch  (#13) believes that EPA should explicitly address studies conducted by the U.S.
Department of Energy on the  environmental impacts of recycling paper versus using recovered
paper as a fuel.        .                                                       .

       Riverwood International, Inc. (#19) says that it takes more fossil  fuel to produce recycled
paperboard than it does for Riverwood to produce solid unbleached sulphate.

       The Containerboard & Kraft Paper Group of the American Forest & Paper Association
(#23) believes that source reduction is itself a worthy environmental goal.  In addition, this
commenter also observes that  kraft (virgin) pulping creates large amounts of energy from a
renewable resource.         .           .  .

       Canadian Pulp & Paper Association (#38) suggests that some RMAN levels may actually
have negative environmental implications if the depletion .of nonrenewable resources used in
transport are taken into consideration.

       Jeff Lindsay (#44) believes'that an  environmental cost-benefit study should be published
to justify the belief that an increase in recycled content will result in a better use of resources.

       Chesapeake Paper Products (#L2) provided a technical paper on life cycle assessment
that apparently contradicts the positive benefits that EPA anticipates in promulgating the paper
products RMAN. Chesapeake requests EPA's review of the paper and further comment on the
environmental and economic benefits of mandating recycled fiber content.
                                          -58-

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  RECOVERED FIBER SUPPLY SHORTAGE

         Scott Paper (#11) states' that, in light of recent wastepaper price and availability.
  problems, EPA's proposed standards will gridlock further investment in paper recycling. This
  commenter cites a 275 percent, price increase for the staple postconsumer grades used for
  recycled tissue products.

        Fort Howard (#12) believes that the high end of the postconsumer ranges recommended
 in the RMAN will worsen the unprecedented turmoil currently afflicting wastepaper markets.

    •    Potlatch  (#13) contends that postconsumer content regulations contribute to higher
 prices for recovered fiber, causing a, disruption in the paper recycling infrastructure.  Potlatch
 observed that in the past year, three  recycled tissue manufacturers declared bankruptcy because
 of reported cash flow problems related to fiber markets.
_.               .           .    .   _            #.         '.-            ,",'
        Chesapeake Paper Products (#14) states that  increasing demands for old corrugated
 containers (OCC) have pushed prices considerably above those of virgin pulp, clearly indicating
 that further recovery incentives are not needed.     ,  ,      .                   •

       Magazine Publishers of America (#17) believes that current and .anticipated recycled
 pulp supply  shortages indicate a need for a broader interpretation of postconsumer fiber.

       The  City of San Diego (#18) believes that it is unlikely that the current fiber  shortage
will continue indefinitely, and that the standards, recommended in the proposed RMAN will  .
challenge industry to maximize use of recycled fiber.                              .

       Riverwood International (#19) states that supply of acceptable postconsumer  fiber is
severely limited and therefore recommends a low-end  range for carrierboard. In addition, the
fiber shortage makes it difficult to incorporate a predictable amount of postconsumer fiber.
                                          -59-

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       Newspaper Association of America (#22) says that many newsprint mills are having
difficulty obtaining new supplies of recovered old newspapers and magazines to meet their raw
material needs.                  .    •              .

       The Container-board & Kraft Paper Group of the American Forest & Paper Association
(#23) believes that there is no need to specify recovered fiber content levels in corrugated
containers because of the current fiber shortage and high collection rate for OCC/

       The Recycled Paperboard Division of the American Forest & Paper Association
(RPD, #26) believes that the  recycled content levels in the draft RMAN will exacerbate the tight
fiber supply. Current fiber shortages exemplify the need to abolish the postconsumer mandates
included in the RMAN.  RPD cautions that mills will reduce postconsumer content or stop using
recovered paper because of escalating costs.                    .

       The Bleached Paperboard Division of the American Forest & Paper Association (#27)
commented that it does  not seem reasonable to recommend recycled content, levels in bleached
paperboard when the availability of suitable recovered fiber is already limited.

       American'Forest & Paper Association (#28) contends that government-imposed
numerical guidelines exacerbate stressed recovered paper markets by causing different industry
segments to compete against each other, a scenario that gives higher value end products a
commanding advantage. In addition, now is not the proper time to tighten standards, when fiber
supplies are stressed.         .             -                                          •

       The Newsprint Division of the American Forest & Paper Association (#29) cites
enormous price increases for  old newspapers and old magazines and expects even tighter supplies
in the future.  Eliminating the distinction between pre- and postconsumer fiber would help ease
the fiber supply problem.
                                           -60-

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        Northeast Maryland Waste Disposal Authority (#31) believes that the fiber shortage will
 result in a temporary tightening of availability of some recycled paper products* but that EPA
 should resist reacting to the current market situation. Instead, EPA should help increase
 recovery of fiber needed to make recycled paper prbducts.                                   '

        Procter & Gamble (#34) believes that EPA should be stimulating supply (of recovered
 fiber) rather than demand, and should reconsider the approach taken in the RMAN.

        Canadian Pulp & Paper Association (#38) states that it is becoming increasingly
 uneconomical for paper  producers to use recycled fiber because supply is insufficient to meet
 needs, causing skyrocketing prices.   ./'  '  -'        •                     :    .

       Tissue Producers. Coalition ,(#43) comments on the current fiber shortage and resulting
 high prices for recovered paper, particularly for sorted office paper and sorted colored ledger. It
 cites a recent study showing that, even with no change in federal guidelines, there will be a one
 million ton-shortfall in recovered paper by 1997.

       Direct Marketing Association (DMA, #L4) observes that the RMAN does not recognize
 the recovered fiber supply shortage. DMA urges EPA to state that the RMAN applies to the
 federal government only  and not to the private sector because to.do so would only exacerbate an
 already difficult recycled  paper products market. DMA also condones EPA for postponing
 action on guidelines that  would take effect in 1998.

       Paper Recycling Coalition (#L5) states that the current  fiber shortages exemplify the
negative impact of the postconsumer requirements of RCRA Section 6002 because they
artificially constrain the supply of available fiber and provide  disincentives for increased
investment in additional recycling capacity.
                                         . -61-

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INFORMATION ON TRAY LINERS

       Fort Howard (#12) believes that GSA's apparent concern with the use of postconsumer
fiber in food tray liners is unfounded,  this commenter contends that these products can be
made with recovered and/or postconsumer fiber'without posing,any meaningful risk to human
health or safety.                        . "      '
INFORMATION ON GREETING CARD STOCK

       Mead (#15) provides information on .papeteries, a unique paper grade used for greeting
cards.  Mead suggests that papeteries be categories as a type of "offset" paper.

    '   Markets for Recycled Products (#16) suggests that Recycled Paper Products, Inc., a
manufacturer of greeting cards with high postconsumer content, should be contacted to gather
additional information on this topic.  •                                        .

       The Printing  & Writing Division of the American Forest & Paper Association (#25)
provided additional information about greeting card stock, pointing out that several paper grades
can be used to manufacture greeting cards.  •                                .   •

       Lincoln Pulp  & Paper (#36) states that the President, Vice President, and probably other
government officials  send many greeting card and that it is consistent that EPA add
postconsumer and recovered fiber content recommendations for greeting cards. Lincoln
produces paper containing 50 percent recovered/20 percent postconsumer content for greeting
card manufacture.                                     .             ,
 INFORMATION ON SPECIALTY TISSUE PRODUCTS                             .

        Markets for Recycled Products (#16) provides information on one producer of wrapping
 tissue (Paper Service Ltd., Hinsdale, NH) that uses 100 percent postconsumer fiber.

                                          '-62-

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 r
s
            INFORMATION ON PAPERBOARD AND PACKAGING

                   International Paper (IP, #9) provides additional information on solid bleached sulfate
            (SBS). Over 90 percent of SBS goes into packaging for fluids, into food service items, or into
            folding cartons for ice cream, butter, frozen foods, and other retail goods.  Direct content food
            packaging must meet strict consumer safety regulations such as FDA 176.260. IP believes that
            setting any recycled content levels for SBS represents an unwarranted regulatory intrusion into
            industry production and policy, and strongly urges EPA not to  initiate any recommendations with
            regard to SBS until after an extensive review of all related issues.-

                  Mead (#15) provided information on paperboard and packaging, responding to many
            questions posed by EPA in the RMAN.                                  '

                  Markets for Recycled Products (#16) observes that the footnote on page 20 of the
           RMAN contains an error. The footnote reads,'"limited availability of suitable material precludes
           widespread use of recovered or postconsumer fiber in food-grade paper products." This
           commenter points out that the limitation pertains only to wet and oily foods, and that dry foods
           have been packaged in coated boxboard for many years. This comraenter also discusses use of
           double-lined kraft clippings in both linerbqard and corrugating  medium, and provides
           information on content levels for miscellaneous paperboard products. She also observes that
           Westvaco's Covington, VA, mill uses recovered  fiber in SBS,           .       v      •       .

                  The Container-board & Kraft Paper Group of the American Forest & Paper Association
           (#23) provides answers to some of EPA's questions about corrugated containers.
                                                     -63-

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        The Recycled Paperboard Division of the American Forest & Paper Association
 (RPD, #26) believes that EPA gives an incomplete and misleading picture of the current
 situation regarding the use of recycled fiber in food grade paper and paperboard. This
 commenter cautions that its members have been producing 100 percent recycled paperboard for
 food packaging for decades, and that market and technology changes are creating new food   .
 packaging opportunities for the grade. RPD suggests that EPA needs to better understand the  •
 regulations regarding use of recovered fiber in food grade paperboard and to distinguish between
. packaging for dry foods versus packaging for fatty and aqueous products.

        RPD provides additional information on coated paperboard, indicating that coating per se
 is not a determinant of postconsumer'fiber use in folding cartons, and that individual content
 levels for coated and uncoated folding cartons are not necessary. In addition, RPD states that
 EPA should not recommend separate content levels for SBS and should eliminate the footnote
 to Table A-4.                     "     •       ",        .      .

        Paper Recycling Coalition (#L5) provides additional information on paperboard and
 generally comments that EPA should not recommend different content levels for industrial
 paperboard products.
                                            -64-

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