EPA-600/1 -76-01 /A
Socloeconomlc Environmental
Studies Series

Water Quality Guidance
        DEVELOPMENT OF

             RESIDUALS
 MANAGEMENT  STRATEGIES
                       AN  EXECUTIVE
                       SUMMARY
     U.S. Environmental Protection Agency
           Washington, D.C.  20460

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1
      THE SUBJECT OF THIS SUMMARY
      THE INTENDED AUDIENCE
      THE PURPOSE OF THE STUDY
      DEFINITIONS

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                    1.   INTRODUCTION
THE SUBJECT OF THIS SUMMARY .  . .
      is a study of the development of strategies for managing the residuals
      that  result  from     human  activity. Conducted  by  Indiana
      University's School of Public and Environmental Affairs, for the U.S.
      Environmental  Protection Agency, the study offers an
      approach to the problem of residuals management.
      Residuals—"leftovers" that inevitably result  from  all  human
      activity—are often referred to as "wastes" or "pollutants." The idea
      of residuals management  includes  both  the concept of waste
      management and pollution control.
      As any manager or administrator knows, it is often difficultto decide
      which approach to a  residuals problem will work best. This study
      contains  step-by-step guidelines for identifying alternate residuals
      management strategies and then evaluating and selecting a strategy.
      The  selected strategy  will provide  decision  makers with an
      economical and  effective means of solving their problems.
THE INTENDED AUDIENCE . .  .
      of this study includes all of the people who make informed decisions
      about residuals management:
                  1. Elected  officials—mayors  and  governors,  city
                    councils, and state and national legislators;
                  2. Appointed administrators—commissioners of city
                    departments, directors of state agencies;
                  3. Public interest groups—special interest groups and
                    groups with  general environmental objectives;
                  4. Planners and  analysts  for city  and state
                    government;
                  5. Managers of residuals generators, both publicly and
                    privately owned.

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THE PURPOSES  OF THE STUDY  ... ARE TWOFOLD
     Generally, the study is designed

           1. To identify and describe a number of means for achieving
             environmental quality in a fair and cost-effective way;
           2. To help decision makers and managers find and implement
             the best  ways for them to manage residuals in order to
             enhance environmental quality.

     Specifically, the study seeks

           1. To help administrators develop and maintain flexibility in
             selecting  methods for improving the environment;
           2. To protect citizens from inequities and hardships which
             result from implementing  environmental controls without
             considering a range of possible alternatives;
           3. To reduce the costs of environmental quality to the general
             taxpayer by
                • reducing  the  need  for publicly financed  residuals
                   treatment works;
                • reducing  operation  and  maintenance  costs  of
                   publicly owned and operated facilities;
                • reducing  the  cost  of   public  supervision  and
                   regulation  of  discharging  residuals  into   the
                   environment; and
                • shifting the cost of environmental protection and
                   improvement  to residuals generators  and  dis-
                   charges.

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DEFINITIONS
      Physical Methods: Technological orstructural actions which result in
      a change of the quantity, type, timing, or spatial location of residuals
      discharged  into the ambient  environment  and/or improve  the
      assimilative capacity of the natural  environment.  Examples of
      physical  actions are changes in production process technologies,
      changes in the operating rate of the production process, treatment of
      residuals (changing form), in-stream aeration, and so on.
      Implementation  Measures:  Non-structural  actions such  as laws,
      regulations  and  ordinances to  induce implementation of desired
      physical   methods.  Implementation   measures   also   achieve
      established  goals  and  objectives  consistent  with established
      policies.   Examples  of   implementation  instruments  include
      performance and  product  specifications, emissions  (residuals)
      limitations, zoning, federal funding for treatment plants, accelerated
      depreciation for pollution control devices, phosphate limitation on
      home laundry detergents, and so on.
      Institutional Arrangements: The established public organizations at
      all levels which establish goals and objectives, which  have  the
      authority  to  identify   and  adopt  implementation  measures.
      Institutional arrangements also include intra-organization and inter-
      organization arrangements. Examples  include federal,  state, city,
      county,  regional,  and  interstate legislative  and administrative
      bodies.
      Residuals  Management  Strategy: A  combination  of  physical
      methods, implementation  measures, and institutional arrangements
      adopted for the  purpose of reducing or eliminating the discharge of
      residuals into the environment and/or reducing or eliminating their
      impact   if  discharged—i.e.  achieving  environmental  quality
      objectives.
      Physical methods may be viewed as the "hardware" as compared to
      the other components which may be viewed as the "software" of the
      residuals management strategy.

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2
    Siudy
THE PROBLEM
THE CAUSES
THE SOLUTION
THE PROCESS
THE PROPOSED SYSTEM
EXAMPLES

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                      2.  THE STUDY
WHAT IS THE PROBLEM?
      The problem is residuals. In response to demand, goods and services
      are produced; the production process itself creates some residuals.
      After  the  goods and  services  reach  the  consumer,  they  are
      "consumed"; this use also results in residuals.
WHAT CAUSES THE PROBLEM?
      1. We have not considered environmental resources as items to "cost
        out" when combining the production resources of labor, capital,
        and raw material to produce goods and services.
        We  have  used  environmental  resources—air,  water,
        land—relatively freely in producing and disposing of goods; that
        is, we have combined our production resources in such a way as to
        exploit  environmental   resources  as   extensively  as
        possible—because environmental  resources have cost little or
        nothing.
      2. We have built up a consume-and-discard way of life. When  goods
        like cars, appliances, clothes, or even buildings no longer provide
        the kind of utility we think we want, we "throw them away."
      3. We have assumed that "away" is in the environment, ignoring a  law
        of Nature:  the conservation  of  mass and energy  —the  same
        quantity of material that went into a product remains in existence,
        even  if the  product  itself does  not. A  product is not  really
        "consumed," it merely changes form. It usually changes into the
        form of residuals which are deposited into the environment.
      4. Until  recently, we considered the environment adequate  to the
        task of assimilating residuals as part of our use of environmental
        resources. We are now beginning to realize that the environment
        has only  a  finite capacity to  assimilate  some residuals from
        production and consumption; and we are beginning to seethatthe
        quality  of human life suffers when the environment is  taxed
        beyond that finite capacity.

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       THE ENVIRONMENT IS A FINITE SOURCE OF MATERIALS WITH A
              FINITE CAPACITY TO ASSIMILATE RESIDUALS
FINITE ENVIRONMENTAL
RESOURCES (AIR, WATER,
LAND) USED AT LITTLE
OR NO COST
TO PRODUCER
              DEMAND FOR
              GOODS AND
              SERVICES
                                ENVIRONMENTAL
                                RESOURCES
PRODUCTION
OF GOODS AND
SERVICES
CONSUMPTION
OF GOODS
AND SERVICES
                                         NON-ASSIMILATED
                                         RESIDUALS
                                         DUMPED INTO A
                                         FINITE ENVIRON-
                                         MENT AT NO COST
                                         TO THE DUMPER

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        THE SOLUTION TO THE PROBLEM . .  . MANAGING RESIDUALS
             Through their  government officials,  people  make a  number of
             decisions regarding  environmental improvement.  Such decisions
             consider

                    1. Factors Influencing  Plans for the Environment

                          •  level of environmental quality desired
                          •  costs of achieving that quality
                          •  who bears those costs
                          •  benefits of enhancing environmental quality
                          •  strategies for achieving that quality

                    2. And Constraints on  Environmental Management

                             economic
                             legal
                             political
                             technological
                             social

             These basic decisions are used to establish  long-range goals for
             levels of environmental quality to  be achieved and interim goals, or
             objectives, to be reached.
             Goals and objectives are set up during the planning process, which
             also includes identifying and selecting strategies for achieving goals.
             Planning and strategy selection are essential to effective residuals
             management.
8

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       A SYSTEMATIC PLANNING PROCESS CONSIDERS THE PROBLEM
           AND THE FACTORS INSTRUMENTAL TO ITS SOLUTION.
1
ENVIRONMENTAL
   PROBLEM
            LEADS TO
            ESTABLISHING
         THAT ARE
         TRANSLATED
         INTO
                                  WHICH
                                  PROVIDE
                                  BASIS TO
                                                         WHICH PROMPTS
                                                         DEVELOPMENT
                                                         OF
                                                      STRATEGIES
     SPECIFIED LEVELS
     OF ENVIRONMENTAL
     QUALITY (SPECIFIC OBJECTIVES)
                                                TO ACHIEVE
  Constraints such as political, economic, legal,
  scientific,  technological,  and  social
  considerations affect this process, principally in
  Steps 3, 4, and 5.

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       THE PROCESS
             Through the systematic identification, selection, and evaluation of
             strategies for residuals management, administrators can determine
             the most effective ways to attack an environmental quality problem.
             The process is outlined in the following pages.
       THE PROPOSED SYSTEM FOR RESIDUALS MANAGEMENT
             1. UNDERSTAND THE RESIDUALS GENERATION  AND
               DISCHARGE PROCESS
                  Within the  framework of  an  overall environmental quality
                  management  system,  the proposed system for managing
                  residuals  begins  with a consideration of the  residuals
                  generation  and discharge process as depicted  in a simple
                  model.

                  WHAT IS  THE  RESIDUALS GENERATION AND  DISCHARGE
                  MODEL?
                        In  response to producer and consumer demands for
                        goods  and  services, the production process brings
                        together raw materials, labor, and energy to produce a
                        product or service. The production process also results
                        in  non-product  outputs (outputs which are not the
                        primary  or intended product). Non-product outputs
                        may be  utilized or discarded, depending on  their
                        economic value. If utilized,  they are  intermediate
                        products; if  discarded, they are residuals. In other
                        words, residuals are non-product outputs which would
                        not be recycled, reused or recovered unless some type
                        of environmental or pollution control were imposed on
                        the producer.
                        Residuals can be handled by different methods:
                        1.  Modified or treated pn-site;
                        2.  Collected, and modified or treated, off-site;
                        3.  Discharged into the environment without modi-
                           fication or treatment.
10

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         THE RESIDUALS GENERATION AND DISCHARGE MODEL
1
DEMAND
FOR GOODS
PRODUCTION
PROCESSES
                      RESIDENTIAL
                      MANUFACTURING
                      TRANSPORTATION
                      UTILITIES
                      AGRICULTURAL
                      MINING
                      RECREATION
                                  ON-SITE
                                  MODIFICATION
                                  OF RESIDUALS
               GASEOUS
               LIQUID
               SOLID
               ENERGY
                                  OFF-SITE
                                  MODIFICATION
                                  OF RESIDUALS
                                                    ENVIRONMENT

                                                    LAND
                                                    AIR
                                                    WATER
                              ENVIRONMENTAL
                              PROCESSES

                              TRANSFORMATION
                              DILUTION
                              DEGRADATION
                              STORAGE


                              AMBIENT
                              ENVIRONMENTAL
                              QUALITY
                                                    LAND
                                                    AIR
                                                    WATER
                                                   RECEPTORS
                                                   HUMANS
                                                   ANIMAL
                                                   PLANTS
                                                   MATERIALS
                                                   OTHER
                                                                      11

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             2.  IDENTIFYING THE RESIDUALS MANAGEMENT
                STRATEGY

                  • WHAT IS A STRATEGY?

                         A  residuals  management strategy combines  three
                         components—physical    methods,   implementation
                         measures, and institutional arrangements—to reduce or
                         eliminate  the  discharge  of  residuals  into the
                         environment,  and/or  to  lessen  their  impact  on
                         environmental quality ii they are discharged.

                  • HOW TO FORMULATE ALTERNATIVE STRATEGIES

                         After determining goals and objectives, and identifying
                        "problem  sources,  alternative  residuals  management
                         strategies can be formulated in three steps:
                         First:    Identify  physical  methods  which can   be
                                 introduced at each point along  the residuals
                                 generation and discharge model.
                         Second: Identify implementation measures which will
                                 induce   implementation   of  the  identified
                                 physical methods.

                         Third:    Identify the institutional arrangements  which
                                  have the capacity to- adopt,  implement and
                                  enforce the implementation measures.
       NOTE:
       Since the residuals generation and discharge process take place in a certain area, external
       factors particular to that area may well determine whether a leftover has some economic
       value or none, thus  determining the degree of  its usefulness to  the producer as an
       intermediate product or its uselessness as a residual.

       External factors such as prices and supplies influence the production/consumption process
       and therefore the residuals generation and discharge process. Other factors such as import
       taxes, unemployment compensation, or minimum wages may affect  materials, capital, or
       labor. The administrator should consider these factors, which may heavJly influence the
       generation and discharge process, when planning strategies for residuals management.
12

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                    DETERMINE
                    GOALS AND
                    OBJECTIVE
                                                           IDENTIFY
                                                           PROBLEM
                                                           SOURCES
     IDENTIFY
     PHYSICAL  1
     METHODS     /
IDENTIFY
IMPLEMENTATION
MEASURES
                IDENTfFY
                INSTITUTIONAL
                ARRANGEMENTS

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1
RESIDUALS MANAGEMENT STRATEGIES ARE COMPRISED OF
THREE COMPONENTS
COMPONENTS DEFINITIONS EXAMPLES



1









3



PHYSICAL
METHODS





IMPLEMENTA-
TION
MEASURES



INSTITUTION-
AL ARRANGE-
MENTS





• Specific physical action,
technologically based,
that result in
• changingthequantity,
type, timing, orspatial
location of discharged
residuals; or
•improving the
assimilative capacity
of the environment.
• Measures such as
regulations, laws, or
ordinances that induce
residuals generators to
use appropriate phy-
sical methods for con-
trolling residuals.
• Governmental and
administrative agencies
that can
• select, initiate,
operate, and enforce
physical methods,
and
• identify and adopt
implementation
measures.
• Changing production process
technologies
• Changing the operating rate of
the production process
• Treating residuals
• Changing the environment to
increase its assimilative
capacity



• Limiting residuals emissions
• Passing zoning regulations
• Authorizing federal funding for
treatment plants
• Depreciating pollution control
devices at an accelerated rate.

• Federal, state, local, regional,
and interstate legislative and
administrative bodies.
• Inter-agency and intra-agency
planning and cooperation.





















14

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   ADMINISTRATORS CAN CONSIDER A NUMBER OF METHODS FOR
                            EACH ALTERNATIVE:
     Alternatives
                 Methods
  REDUCTION   IN  GEN-
  ERATION      OF
  RESIDUALS   CAN   BE
  ACCOMPLISHED BY:
Changing final demand for the mix and/or characteristics
of goods and services—e.g., switching from disposable to
returnable containers.
Changing production processes—e.g. if sulfurfumesfrom
an open-hearth furnace create air pollution, a different
method of manufacturing steel, such as the basic oxygen
furnace, may be introduced.
Changing raw material inputs—e.g., changing from high
sulfur content coal to low sulfur content coal would help
reduce the residual S02.
  MODIFICATION  OF
  RESIDUALS  AFTER
  GENERATION CAN BE
  ACCOMPLISHED BY:
Residuals modification and/or recovery on-site.
Residuals  modification and/or  recovery  off-site in a
collective facility.
Residuals modification to a less harmful form of residual
in order to eliminate or reduce its adverse effect on  the
environment.
  IF  RESIDUALS  ARE
  DISCHARGED INTO THE
  ENVIRONMENT,   THE
  ASSIMILATIVE CAPA-
  CITY  OF  THE  ENVI-
  RONMENT CAN BE IM-
  PROVED  BY:
Changing the spatial distribution of production activities
Changing the timing of production activities
Changing the spatial distribution of the discharge of
residuals.
NOTE:
There are many points in the residuals generation and discharge model that can be
identified and used as "valves" to control the process; before turning those valves,
however, administrators should define specific environmental problems andtheirsources,
establishing a relationship between those problems and possible strategiesforeliminating
or reducing them.
                                                                                15

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MODIFICATIONS IN THERESIDUALGENERATION AND DISCHARGE MODEL
PROCESS

MODIFICA-
TION

METHODS

















1
DEMAND
MODIFICATION
OF
DEMAND

1. REDUCE OR
ELIMINATE
DEMAND
2. CHANGE TIME
AND/OR PLACE
OF DEMAND













2
PRODUCTION
MODIFICATION
OF
PRODUCTION

1. CHANGE
LOCATION OF
ACTIVITIES
2. CHANGE TIME
OF ACTIVITIES
3. CHANGE RAW
MATERIAL
INPUT
4. CHANGE
ENERGY INPUT
5. CHANGE MIX OF
PRODUCT
OUTPUTS
6. CHANGE
PRODUCT
SPECIFICATIONS
7. CHANGE
PRODUCTION
PROCESS
3
RESIDUALS
PROCESSING
OF
RESIDUALS

1. ON-SITE
MODIFICATION
AND/OR
RECOVERY
2. OFF-SITE
MODIFICATION
AND/OR
RECOVERY











4
ENVIRONMENT
MODIFICATION
OF
ASSIMILATIVE
CAPACITY
1. MAKE BETTER
USE OF
2. INCREASE
CAPACITY OF















5
RECEPTORS
FINAL
PROTECTIVE
MEASURES

1. INDIVIDUAL
2. COLLECTIVE


















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3.  CLASSIFYING AND IDENTIFYING STRATEGIES

     •  THREE WAYS OF CLASSIFYING COMPONENTS OF THE STRATEGY:

           1. Classify  physical methods  according to their points  of
              introduction in the  residuals generation and  discharge
              model. Relate these  methods to the source activities that
              cause the pollution problem.
           2. Classify implementation measures according to their effect
              or  purpose—regulatory,  economic,  administrative,
              informative. Relate  physical  methods to implementation
              instruments necessary to ensure their use.
           3. Classify institutional arrangements according to different
              levels and  types of government. Relate implementation
              measures to institutional arrangements  which  can enact
              such  measures.


4.  RELATE COMPONENTS TO THE MODEL

     Starting at each point of introduction along the residuals generation
     and   discharge  model—e.g.,  final   demand,   production
     process—identify applicable  physical methods,  implementation
     measures and institutional arrangements that will accomplish the
     desired environmental objectives.


5.  ENFORCING THE STRATEGY

     After  choosing appropriate strategies, administrators  must, of
     course, apply and enforce them. The study does not deal in depth with
     implementing and enforcing residuals management strategies, but
     rather concentrates on steps for developing and evaluating strategy
     alternatives.
                                                                    17

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       6.  DEVELOPING AND EVALUATING A RESIDUALS MANAGEMENT
          STRATEGY INCLUDES THE FOLLOWING SEVEN STEPS:
             -|  DEFINE THE
                	.
                PROBLEM
                        SPECIFY ALTERNATIVE
                        PHYSICAL METHODS
                                          ANALYZE ALTERNATIVE
                                          PHYSICAL METHODS
                           IDENTIFY ALTERNATIVE
                           IMPLEMENTATION
                           MEASURES AND
                           INSTITUTIONAL
                           ARRANGEMENTS
                 FORMULATE ALTERNATIVE
                 RESIDUALS MANAGEMENT
                 STRATEGIES
                                    EVALUATE ALTERNATIVE
                                    RESIDUALS MANAGEMENT
                                    STRATEGIES
                         7
CHOOSE STRATEGY
FOR IMPLEMENTATION
18

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             STEP1
             DEFINE THE PROBLEM

             1. Define the problem in terms of

                  •  Residual characteristics: gaseous, liquid, solid, energy
                  •  Sources:  residential,   manufacturing,   transportation,,
                     utilities, agriculture, mining, and recreation.

                  •  Media: air, water, land.

             2. Classify residuals in terms of their intermedia effects—the way
               they interact with  two or more media.
            STEP 2

            SPECIFY ALTERNATIVE PHYSICAL METHODS

             1. Specify physical methods in relation to sources of the problem.
             2. Differentiate among sources  in terms  of  possible points  of
               introduction in the residuals generation and  discharge process.
NOTE:

These two steps provide a "baseline" inventory and analysis of problems.
                                                                           19

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                 STEP 3

                 ANALYZE ALTERNATIVE PHYSICAL METHODS

                 1. Analyze methods in terms of

                     • Physical effects
                     • Economic effects.

                 2. Utilize models if resources are adequate; if resources are limited,
                   call upon a panel of advisors or experts.
                 STEP 4

                 IDENTIFY  ALTERNATIVE IMPLEMENTATION  MEASURES
                 AND INSTITUTIONAL ARRANGEMENTS.

                 1. Consider actions prescribed  by  regulations or ordinances, or
                   actions  offering incentives  for changes in the production
                   processes used by residuals generators.
                 2. Consider agencies at various levels that can oversee and enforce
                   implementation measures chosen..
                 STEPS

                 FORMULATE  ALTERNATIVE  RESIDUALS  MANAGEMENT
                 STRATEGIES

                 1. Consider the results that can be expected from each strategy in
                   terms of
                     • the environment
                     • the economy

                 2. Utilize'information developed  in Step 3 for  each  residuals
                   management  strategy. This  information  would  indicate  the
                   reductions to  be achieved for each residual as well as costs for
                   each strategy.
20

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STEP 6

EVALUATE  ALTERNATIVE   RESIDUALS  MANAGEMENT
STRATEGIES. SUGGESTED CRITERIA:

1. Physical effects:

     • Reduction of residuals (quantity)
     • Improvement in environmental quality

2. Economic effects:

     • Direct  costs: expenditures  required to respond  to a
        particular strategy. These  costs include  investment and
        operating costs for control equipment, incremental costs of
        fuel  switching,  costs  of  production process  changes,
        emission monitoring  costs,  administrative costs  for
        accounting and reporting, costs of supervising personnel,
        and  costs  required for  implementing and  enforcing a
        strategy.
     • Other economic effects to society: employment, income to
        other firms,  change in  income tax and  property taxes,
        increased cost of user goods, and dislocation of  people.

3. Legal considerations:

     • Enabling legislation
     • Legal precedents
     • Susceptibility of implementation measure to legal challenge
     • New legislation required

4. Administrative considerations:  flexibility of the strategy in terms
   of

     • Seasonal variations
     • Changes in prices, technology over time
     • Ability of the strategy to  incorporate new  information
     • Effects  of new goals and  priorities

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                   5.  Time considerations:
                         • Time required to implement strategy
                         • Time needed to  obtain first results and/or benefits
                   6.  Political considerations:
                         • Feasibility of adoption
                   7.  Public Responsiveness:
                         • Public response survey
                   STEP?
                   CHOOSE STRATEGY FOR IMPLEMENTATION
                    1. Use the materials generated in the evaluation process in Step 6 to
                      choose the most practical strategy.
                    2. Obtain advice from other sources as necessary.
      NOTE:
      If those who participate in the development of the residuals management strategy are also
      those  responsible  for its implementation  and enforcement,  they will have a better
      understanding of the obligations they are assuming. They will also have a more realistic
      view of the results they can expect in terms of  reduced residuals discharge into the
      environment, the  economic and social effects of that reduction, and the outlook for
      improvement in environmental quality.
22

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3 Appli
CATIONS
    WHAT TO LOOK FOR
    WHERE TO LOOK
                            23

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                     3.  THE  APPLICATIONS
       WHAT TO LOOK FOR
            The  study  contains  an  extensive bibliography of  practical
            publications covering  many  aspects of environmental  pollution
            control. These publications range from Alternatives to the Internal
            Combustion Engine through  The Zoning Dilemma. A  number of
            theoretical references are noted at the end of each chapter in the
            study.
       WHERE TO GET THEM
            Information on availability of copies of "Development of Residuals
            Management Strategies" can be obtained from:

                             Mr. Charles N. Ehler
                              Program Manager
                      Regional Environmental Management
                       Office of Research and Development
                      U.S. Environmental Protection Agency
                              401 M Street, S.W.
                            Washington, D.C. 20460

                            Professor Richard Howe
                             School of Public and
                             Environmental Affairs
                              Indiana University
                            400 East Seventh Street
                          Bloomington, Indiana 47401
                          Professor Nicholas L. White
                                School of Law
                              Indiana University
                          Bloomington, Indiana 47401
24

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4 CoNclusioNS
    CONCLUSIONS
    RECOMMENDATIONS
    PROJECT IDENTIFICATION
                               25

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      4.  CONCLUSIONS & RECOMMENDATIONS
       CONCLUSIONS
       1.   H uman activity results in residuals that are generated and discharged
         into the environment, affecting its quality. To the extent that human
         activity can be changed, environmental quality can be enhanced.
       2. A planning process to identify,  evaluate, and select strategies  for
         overcoming or alleviating environmental problems caused by residuals
         discharge can be based on the framework of a residuals generation and
         discharge model.
       3. This model identifies different methods for complying with recentfederal
         legislation that requires a specified level of environmental quality.
       4. This model provides a method for identifying and evaluating residuals
         management strategies. These strategies are helpful in the formulation of
         environmental  assessments and impact statements.
       5. The residuals  management  strategy  identifies many points  in the
         residuals generation and discharge model at which physical methods can
         be introduced, or changes made, to reduce or alleviate the effect of
         discharging residuals into  the environment.
       6. A planning process that uses the residuals management model can prove
         beneficial to  elected   officials and administrators  at  all levels of
         government. It is particularly useful to local and regional officials who
         must deal with problems first-hand.
26

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RECOMMENDATIONS


1.  A planning process for residuals management (pollution control)  could
   use the residuals generation and discharge model as a framework.
2.  The planning process  for identifying residuals management strategies
   should start without considering legal, political, technological, or social
   constraints so that officials can examine the broadest possible range of
   alternatives.
3.  Decision makers should consider all reasonable alternatives; they should
   not  limit  themselves to  conventional,  end-of-the-pipe solutions  to
   residuals problems.
4.  A planning process that  uses the residuals generation and discharge
   model  should  be  followed  by  consumers,  labor, business, and
   government—by all decision makers concerned about environmental
   quality—so  that they share  a common base  for their residuals
   management decisions.
                                                                           27

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       PROJECT IDENTIFICATION
               AUTHORS:  Richard S. Howe, Professor,
                         School of Public and Environmental Affairs
                         Nicholas L. White, Professor,
                         School of Law
                         Indiana University
                         Bloomington, Indiana
               GRANT:    R-803313-01-1
                         Regional Environmental Management
                          Program
                         Washington Environmental Research Center
                         U.S. Environmental Protection Agency
                         Washington, D.C. 20460
               PROJECT OFFICER AND MANAGER: Charles N. Ehler
               PREPARED  FOR:  Office of Research and Development
                          U.S. Environmental Protection Agency
                         Washington, D.C. 20460

               EXECUTIVE SUMMARY DESIGNED BY: Gary Simmons
28
GPO 898-997

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