TRANSCRIPT
Public Meeting
of the Resource Conservation Committee
on Solid Waste Product Charge Issue
November 18, 1977, Cincinnati, Ohio
This meeting was sponsored by the Resource Conservation Committee,
the Interagency Committee established under the Resource Conservation
and Recovery Act of 1976, and these proceedings (SW-31p) are reproduced
entirely as transcribed by the official reporter, with handwritten
corrections by the Office of Solid Waste.
U.S. Environmental Protection Agency
1978
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An environmental protection publication (SW-31p) in the solid waste management series.
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PUBLIC MEETING
(2D/^S£~/^ yfi-~T>PN
RESOURCE eOHVBRDIOH COMMITTEE
SOLID WASTK PRODUCT CHARGE ISSUE
NETHERLAND HILTON HOTEL
33 WEST 5th STREET
CINCINNATI, OHIO
NOVEMBER 18, 1977
PROFESSIONAL SECRETARIAL / COURT REPORTING SERVICE
416 First National Bank Building
Cincinnati, Ohio 45202 — (513) 421-3383
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SENIOR ADVISORY GROUP
Richard Herpst -
Steffen Plehn
Lynn Brown
David Arella
John Robinson
Dr. Edwin Clark -
Commerce
E.P.A.
E.P.A.
Resource Conservation Staff
Moderator
C.E.Q.
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JOHN ROBINSON: Good morning. I'd like
to welcome you all to the second meeting of the Resource
Conservation Committee. My name\ is John Robinson. I'll be
moderating this meeting today.
Just a couple announcements
before we get started. I trust all of you are registered
outside. If you haven't, please do, so we can keep a good
record of who's attending and so we can get your name on our
mailing list. I'd also like to call your attention to the
publication on the registration table outside. They're
basically there for your information so you can pet some
additional information about both the committee and what
we're doing about resource conversation. Thirdly, the restroonis
are straight through the back, across the lobby. Also public
telephones are out there.
As we said in our
presentation, the purpose of this meeting is to find out as
much as we can about your thoughts on this solid waste prodxict
charge issue. We're basically here to listen. And I'd like
to reiterate, as we said in our presentation, that we will
be giving full consideration to both oral and any written
comments you might submit. The record will remain open for
two weeks from yesterday, which would be the 1st of December,
for the submission of any written comments to be included in
the record.
JThe Resource Conservation
Commit!feg is an inter-agency committee, which is established
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by Congress for a two year period. It was established about a
gaar_ ago 1" October of 1976. We have about a year left to go.
The purpose of the committee is to study 3 wide variety of
public policies refiar^fnp; n>an,,rr-a f^noqf-opfirn and to rnake
recommendations to both the Congress and the President
regarding measures we think are advisable. This is the third
in a series of public meetings in which we expect to address
conservation issues. We plan to hold additional meetings
throughout next year. Information on those meetings will be
sent to all of you here today. If you didn't get an invitation
to the -meeting, again, please be sure to register so we have
your name.
I'd like to very briefly introduce
the people we have here from the .Resource Conservation
Committee, Senior A^irtflfflry frniifi At the far left is Dr.
Edwin Clark, C.E.Q. Next to him Dick Herpst, Department of
Commerce. Sext to hit" is Mr. Steffen Plehn, Environmental
Protection Agency. Lynn Brown is sitting next to Steffen,
also from the Environmental Protection Agency. And David Arella,
from the Resource Conservation Staff.
As I said before, the entire
proceedings of this meeting, both oral and written, will be
published so that the other members of the Committee can
review them and have their staff review them at a later date.
Since we don't have a tremendous
number of people here who would like to give formal statements,
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I would like to suggest a slightly different procedure. We'll
take the formal statements to start off with, then we'll move
into a. general discussion open ufr- to anyone on the floor and
see how long that lasts.
Without too much else, I think
I^robably better stop talkinp, and start listening to what
you have to say. Once again, I welcome you and look forward
to your comments.
The first speaker we have today,
who has asked to be placed on the program, is Mr. John Tracey
from the American Paper Institute. Mr. Tracey.
JOHN T. TRACEY: Good morning. I am
John Tracey, Senior Vice President of the
CrvrpnT-ai-|on of America in Evana^on^ ITHnM « My company is
a member of the American Paper Institute, which is the
national trade association for the pulp, paper and paperboard
industry. Tho twf hnnrirpfi f*rjps of API produce mn-re t-han
ninety percent of all P'^P. • .P"!""" an^ paperboard manufactured
domestically.
As Chairman of the Recycled
Paperboard Division of the API, I am speaking today for
the entire recycling segment of the paper industry. Many ^
of the recyclers are small companies . Our mill
about fifteen million tons of recycled paper.
I appreciate the opportunity
to present to you, as a recycler, our views on the proposed
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*\*
.solid waste disposal tax — or product^ charge, as you call it.
The paper industry jppnnoja
this tax for a number of reasons -- It is inflationary. it
is j-acroagive, Htapr-fnytnat-nry and will cause market dislocations.
These points were made yesterday at the Washington hearings
by Mr. Louis F. Laun, President of the American Paper
Institute, and the recyclers support the API position.
When we review Senator Kart's
bill, S 1281, and Appendix B of the EPA 4th Report to
Congress, we are concerned about the concept and also the
magnitude of this tax. In the first full year of implementation
after the phase-in and adjustments for inflation -- J_£_Kill
cost paper pr^^n^^^n whn tin nnf iiflf pnnf-piTHi"r?r
paper $2.6 billion per year and we would p^ftrmifo
would add 54 to ^ ^< i n "n tr rhn fruym nf fnrrr prm-lnrfc,
because of the effect of the markups. This tax is just
so massive that it is going to cut into the growth rate
of the paper industry. Anything that danpens this overall
growth rate will have impact on the recycling segment.
The paper industry, and particularly
the recycling segment.has supported the concept flf r<"!r"rr''0
For the paper industry, resource
recovery means Tf^yfUnp vnnrr fnf"T Currently, we are
recycling on a national basis more than thirty percent nf tihf
.old ne^ftppppTfi nnrf unrH p-rriirntrirl hn-rfn rHnpnr'f"'* n^-r nf°
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In fact, iiX-gome areas of th
fifty percent of these grades.
ofcl --
separgt-o^ at- f-fra girnrnn nnri T-rpf clrrm frrrm i — ntinm-'n -art"? .
Not all waste paper can be
recycled and that portion in solid vraste that cannot be
recycled should be incinerated t^n "rpcoveir its fuel v.aJ-iifi—
to ^ene•ra^p afoam fln^ p^oflfr-i.'-ifY The paper industry has
for many years stated that we
of waste paper when it can be done on a sound economic
In 1977, the paper industry
will be taking 17.5 million tons of waste paper and other
waste fibers from the solid waste stream. The breakdown on
this is as follows:
'"tlmnry rnmiimrrton nt U.I: pjpn-' Trill IT
T.H1 1 atn/Mint- «-r. H, ^ tlli llton tOTIK .
U.S. exp_or£g pjf waste paper - one and
a half million tons.
\
Consumption to make other products -
a half million tons.
Consumption of other waste fibers -
one million tons. •
Totaling 17.5 million tons.
This total, we estimate, will
Increase by one million tons each year over the next three
years.
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EPA officials, when discussing
increased recycling, have fflld we ngprf t-c- j,fir.rpagfi rfiTiYf'1'l"S
. faster. If the paper industry says that the economics
are not sufficiently favorable to «ymao a fflfHtiftT •trirr«»
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average.
There is an "available supply"
of all grades of waste paper out there, Jhiifc tt t:akes time
to Ingreage supply You have t£ alero the over f1fteen hundred
paper stock dealers that additional tonnage is needed, you
have to get organizations -InfrpreRfrrl in i-rrndnr'Mnc vnntn
paper drivgs-> you have to >*fgr£-^-hf-j^rihljic to s^w nld
newspapers. Contract waste haulers who dump recyclable
waste paper in landfills or burn waste paper in incinerators
must be informed when the time is right to deliver more
waste paper to the mills.
It can tak^three to sixmongje,
and in some cases as long as a year, for a substantial increase
in supply to develop,and meanwhile, all recyclers are
bidding up the price of the existing paper being collected.
After the collection programs turn on new supplies, waste paper
prices tend to stabilize at the lower historic levels.
In 1977, we are in a situation
that is a replay of 1974. For over twenty years, there has
been an insulation material on the market made from old
newspapers. I do not think I have to tell you what the
demand is today for home insulation due to the cost of energy
and the possibility of tax credits. Well, we again have to
increase collection to meet the demand for recycled waste
paper from paper mills and insulators, too.
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Now, I know we will get the paper.
We always have and we are not going to shut down our mills.
We may shut down a day or a week, but we will eventually get
the paper and recycling will increase, and we will decrease
the amount of old newspapers in' solid waste.
But the time factor is what
worries me. How long will it take and the greater worry is
what will it cost?
My company operates four
recycling mills and they are rather small mills. They are
unable to raise the price for paperboard to offset dramatic
increases in the prices for waste paper. If they become
unprofitable for a long period, we will be forced to shut
them down. We have shut down one mill in Michigan which
operated two paper machines, one machine in Indiana, and one
machine in our mill in Ohio because they are unprofitable.
We simply do not think this
tax will increase recycling to any significant extent --
rather we think there will be a shift of waste paper utilization
from the smaller recycling trills to the large mills who will
want to avoid the tax or a percentage of it.
To increase recycling and reduce
solid waste, we think there is a real opportunity to work
with EPA to develop new waste paper collection systems that
will generate waste paper supply on a steady flow basis, at
stable prices and clean from contaminating materials.
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We need a strong resource recovery
section in EPA that is adequately funded and staffed. My
company, as well as others, have worVfi'l vrH-'h T?PA'R
to start up n,f«
Over two hundred cities in the United States have such
programs, but few of them are large cities. We need more
cities and, specifically, more large cities co] Tpr*"*^ v?^
jicoopapei*B. As new solid waste processing plants are built,
we need to set up a.priority
waste prior to its being comingled with other waste.
We need to jfrm-l rnrrrnrah on
particularly, technology to
in waste paper such as adhesives, inks, coatings and
laminates. We think EPA can fund such research, and we can
work with you to select the consultants and to write the
objectives of this program.
We need to develop a copnnunica-
t-Qs^alert the American people_jrr "B1^ that
effort" ff) fiftpqratS Waste fflpP^ frnm nf'hor or>T i H
jeejfeWng. In 1977, the API members who recycle waste paper
will spend $500,000 to ask the American people to recycle
waste paper and also, to buy products made from recycled waste
paper. We are on television, radio, in newspapers and
magazines to get our message across, but if it is to be
effective, ™_ -poo^ a Yflfifly fypandFfl pr~prnn- t-n •fncrrm fbr
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American public On the impor^f"™ nf rprypl ing pore
paper.
"r. vnnt f
but we need help on the supply side. We do not need the
tax. We want to work with EPA. We have done so in the
past and want to continue to do so. I would like to suggest
that we schedule a meeting at your offices at Waterside Mall
in Washington where we can start to work in a positive way,
rather than being here opposing a tax which we believe is a
negative approach to solving the solid waste problem.
Mr. Chairman, this completes
my testimony and I think you very much.
JOHN ROBINSON: Any questions? During
the questions and answers, if I can ask everyone to please
identify themselves.
Dr. Edward Clark from the
Council on Environmental Quality.
EDWARD CLARK: As the product charge
proposal is usually considered recycled material, recycled
j-iaper w^il A ho oiroinpt- from. it. So it would increase thtL.
prtcp of purchasing paper . and as a result one would expect
to see the price of recycled paper also increased for the
recycled paper manufacturers. So we would expect to see your
product being bought at a higher price. And I was interested
in your comments that after the supply of waste paper increases
the cost of paper, the cost of raw material tends to fall off.
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This combination of things would seem to me to put you in a
pretty good situation.
JOHN TRACEY: On the surface one might
certainly think so. However, tiTie fr^tal capfffy ff *'K°
jgfyf 1-tnp pm-tion of the industry is so small comoarpfj tq the
poT-«--(/-.r. ^f fh," j_nt]1Ta«-ry <-hnt- if ai-vino nf t-frftse lajPgT
n nnr hnnlnrn mnl r ,T , onrmn-T-ai-gH Pffnri-_«-n n«-«T-f
ann/i t,i3ofo we don't think that the price is going
to fall off at all. We think that it will be driven to new
highs, and although it may stabilize once the supply is
available, the distortion here is something that is, in our
opinion, very difficult to track or to forecast.
We also are concerned about the
price elasticity of our product. At what point, for example,
does a purchaser of a folding carton elect not to use a folding
carton? At what point, if you're packing a razor or an appliance,
do you say paper is not going to be the nedium which I use
to put that product in the consumer 's hands? 1'Iov, this would
involve all kinds of foreign packaging materials, it would
involve glass and plastics. And the impact on all of these,
we don't feel will be necessarily equal. But we are concerned
with the fact that there is such an overwhelming capacity of the
virgin portion of our industry to draw upon the available,
or hopefully available supply of (inaudible) -- it could very
well distort the price schedule for some time to come.
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EDWIN CLARK: It is my impression that
most of your large virgin mills are located close to the
supply of virgin materials in the northwest, and places
like that. Are most of your plants located near urban
areas?
JOHN TRACEY: Yes.
EDWIN CLAPK: Would you not have a
comparative advantage over the virgin mills where they would
have to ship to the markets and you would have lower trans-
portation costs?
JOHN TRACEY: Well, there's no question
that JUT"" "*• <"'"° Tpvflc mi Tin jn i^rln rniintry nrr Inrntrfl
pppr HIP iflj-gp iflf.t-1-npr.ni-im or-?-.e TIT?I"^P thp waste paper is
available• But as we have seen, for example right now on
newspaper collections, we're pulling newspaper in to
Hutchinson, Kansas from as far away as Houston, Texas, because
that's where we have to go to get it.
And we have to believe that with
the product tax that a virgin craft mill in the southeast --
there's a number of then; in the State of Georgia -- we have
a virgin craft mill in Tennessee. We are currently shipping
from Cleveland, Ohio down there and also from Detroit and some
cities in Hew Jersey. You go where you have to go to get it.
And it's true we will have an advantage on the basis of freight,
but we don't have the necessary economies of scale that they
might have.
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EDWIN CLARK: The ability of the recycling
industry to be -- to recycle paper to expand and the extent
to which (inaudible) with respect to larger v^gin material.
Is that a problem in your industry?
JOHN TRACEY: It has been a problem.
Addressing myself to the first part of your question on the
ability to expand. We have been attempting to get some
recognition within the tax laws for additional investment
tax credit for the recycle industry. We're hopeful that
some of the legislation that has been recommended and is
pending will be passed. " "~
There is an opportunity to
expand if there is a recognition of the need and also the
future potential growth of the recycling industry. I think
we can.
EDWIN CLARK: How about pollution control
laws?
JOHN TRACEY: The pollution control laws
are applying &ft all of us in the industry, whether you're
virgin or recyclers. It is a very difficult financial time
for the whole industry in this respect. Some thirty percent
of the capital dollars in the whole industry have gone in
this direction over the past ten years or so. We are, for
the most part, in compliance. The mills that have shut down
from the recycling segment of our business, which number over
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a hundred in the past seventeen years, have shut down primarily
because they felt they could not afford the expenditure
for compliance with the pollution control.
I would say that for the most
part in the recycling portion of the industry the pollution
control bill is behind us. They are in compliance with the
July '78 requirements. They will certainly be in compliance
with the water regulations in '83, whatever they will finally
turn out to be. All of the major recycle mills that I know
of are well on the way to closing up there (inaudible)
discharge systems. I think it is a very viable industry
today, and I think it will be in the future.
EDVJIH CLARK: Is air pollution a problem?
JOHN TRACEY: Not as serious, but it is
a problem. We have a particular S 02 problem.
My mill in (inaudible), Ohio,
for example, we have four boilers operating three paper
machines there, and we're operating on coal. We are going
through a three and a half million dollar expenditure presently
to clean up our/discharge into the air.
RICHARD HERPST: Richard Herpst, Department
of Commerce. Would you tell me whether API has done any
work with respect to what the product charge issue might
have on trade implications. For example, yesterday we learned
that we have what is known as (inaudible). And specifically
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this treaty does not permit imported educational printed
material to be taxed.
JOHN TRACEY: I can't really answer that,
sir. I have with me today, Rod Edwards, who is the Vice
President of API, and I will defer that question to him.
UOD EDWARDS: We haven't really made a
thorough study that you might get all the details. But in
_™IT- f-raHo -r-oi at-'ir.y^ip with Canada, for instance, their pulp
and newsprint romps tnt-o n^r country duty free_. And with the
solid waste tax and the proposal that
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IS
reporter and another copy at the registration desk.
Our second speaker today is
Professor Haynes Goddard of the University of Cincinnati.
HAYNES GODDARD: Good morning. My name
is Haynes Goddard. I'm an Associate Professor of Economics
at the University of Cincinnati. I'm here, really, to speak
for myself, but perhaps I should give a little background.
My teaching areas at the
University of Cincinnati include Public Econonics, mainly
Environmental Economics. My research interest, principal
research interest, is the economics of solid waste management,
and I've written a book on the subject entitled, "Solid Waste
Matter, Economics and Technology, in Institutions". It was
published by (inaudible) Publishers in 1975. I'ffi also an
editor for a journal, "Resource (inaudible) and Conservation".
First, I'd like to say I'ir
happy to see there's a serious interest on the part of the
government towards economic incentives for environmental
control.
I heard of this meeting only
three days ago, so I haven't had nuch tiffe to prepare my
corments. I have tried to keep somewhat abreast of the
analysis on the product charpe and I have thought somewhat
about it. My cotrnents will be general and perhaps I can
clarify sorre of their that may not be too clear.
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I'll begin by asking a question.
The question is, what is the solid waste problem which the
product charge is designed to correct? Essentially, it's
designed to correct t-hp unepnnnmlp use <^f Tn^^gr-* -*1 " f*-™ *->"•-
point of view of the impact pffl t-ho. ppviromngnt:. In particular,
it's designed i-n-i-oHirt. rV r"~ "J ' ' ' r " ' ' ' "' '
"flVif filnr1" «"^
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to a number of communities around the country, would be
essentially a function of the quantity of waste discharge
in the surface level.
The second element of this
framework would be a litter control mechanism. This might
include various deposits for returnable and non-returnable
beverage containers, fines for littering with a clear
enforcement mechanise:.
The third element would be
a viable smvrpp sppara<--ifvn p-moi-flf) vrlri r-+i would be made more
viable by the presence of an economic incentive of the user
charge.
And lastly, of course, the
resource recovery program. And all of these are designed
to be put together.
I'll discuss some of the
potential merits of this shortly, but I would first lil
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particular it doesn't tell us very much about how to choose
overall national policy objectives. Usually, these questions
are much too large for the scope of benefit cost analysis
and much too important.
The adoption of national
objectives and the methods of achieving them, even for
fairly straight forward economic questions, is very much
conditioned, or conditioned very heavily, by our values,
and the institutions that we choose to give life and
substance to our values.
Two values which are fundamental
to our economic and political system are the followinp: Each
individual is the best judge of his own welfare, and
individual preferences should count. I'll repeat these.
East individual is the best judge of his own velfare, and
individual preferences should count.
Now the institutions which we
have adopted in this society to guide our economic and
political life by these values are essentially the followinp:
We have a political democracy that permits choice by
individuals, and we have an economic counterpart which can
be suranied up as the market system where choices can be
exercised, and those who want to consume particular resources
are required to pay the cost incurred for producing those
resources.
You should note that I did not
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say free enterprise system or capitalism. How the meaning of
this is that we have, in fact, in this society adopted
decentralized decision-making institutions. And that every-
thing else being equal, these are to be preferred. Decentralized
decisionmiaking institutions imply that incentive systems
or mechanisms should reflect, in the case of solid waste
management, local solid waste management for its conditions
and local preferences, and not incentive mechanises that
reflect a national average in no particular place in particular.
Such a situation has much potential, I think, for reducing
consumer and social welfare, or economic welfare, unnecessarily.
How, the implications of this
solid waste management, I think, are the following: We should
begin first to examine decentralized decision-ciakinp
institutions rather than centralized ones for solving the
solid waste problem. We should first look at instruments
that permit incentives to reflect local cost conditions,
local income, local preferences. And such a decentralized
mechanism can be found within the framework that I mentioned
earlier, that is an integrated solid waste management system
operated essentially at the state and local levels.
The principal elements of this
system include the economic incentive provided through a user
charge for collection and disposal, effective litter control
mechanisms, such as garbage container deposits, anti-litter
laws, source separation programs and resource recovery programs.
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All of which are designed to be integrated together. And as
well, an on-going program which maintains the discard informa-
tion to the discarding public in each of these areas about
the cost implications of their behavior. Both in terms of
budgetary feed-backs and the external costs. Thus
decentralization can be preserved, and the local conditions
can be factored into these consumer mechanisms. Something
that is very difficult to do or impf- ^ble to do in the case
of a national product charge.
Now, this proposal is similar
to the product charge in that I believe that the federal
government would have to insist that the local communities
adopt a mechanism to induce waste disposal behavior that
is consistant with the social flaws it creats. But it differs
in that the magnitude or the level of the incentive, the
price, would vary according to the local cost conditions
and local preferences.
There are some problems with
the proposal, however, or with both proposals. The user
charge aspect of incentive mechanisms for solid waste
management is very much unresearched in comparison to the
product charge. These two incentive mechanisms are very
likely a substitute for one another in some aspects of solid
waste control, and compliments in others. I do think that
the product charge should not be made into lav; in isolation.
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The user charge merits more consideration, and the two
concepts should be developed together, but they haven't
been to date. Otherwise I think the potential growth rate
for getting locked into environmental control mechanisms
and instruments would make the attainment of environmental
quality more expensive, more costly, than is necessary.
And the result of this is that if environmental quality
is made more expensive than the need to be, the public will
inevitably demand less environmental quality than it could
have in terms of the underlying benefits. And thus the
public will be worse off. And, in particular^ I think we will
pass on to our own children a heritage of less environmental
quality than they should have.
These conclude my prepared
comments, and I recognize that they've been kind of general
which have been put together under the press of time. If
you have any questions, I'll be glad to answer them.
JOHN ROBINSON: Any questions?
EDWIN CLARK: I'm puzzled about one
element, llaybe you can enlighten tne about it with regard
to consumer choice. You recommend a (inaudible) council,
or something like that, as part of your program. And yet
when you look at how consumers have reacted to the choice
between throw-away cans and returnable bottles, they have
chosen the throw-away cans.
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HAYNES GODDARD: In the presence of
deposit revisions?
EDWIN CLARK: Well, in returnable bottles
the beverage is cheaper, and they have preferred to pay
more for the opportunity to use the convenience of cans.
And this would appear to be a strong demonstration of
consumer preference and consumer decision making.
On the >ther hand, when you
do an opinion survey, you find that something like seventy-
three percent of the people prefer beverage container
deposit legislation.
I would be interested if you
could explain this discrepancy.
HAYNES GODDARD: Well I suspect -- You
made the comment that -- something about correct consumer
prices on beverages sold in returnable and non-returnable
containers in the absence of a deposit mechanism. I wouldn't
5 n.k>* TT^-^/Vf
say they're correct. There are oubotqtivc costs and litter
costs that are not being made explicit to the people who
are purchasing the containers.
It is true, typically, that
beverages are slightly cheaper in returnable containers,
but it could simply be, I think, that the price differential
between the two is insufficent to outweigh the convenience
of having a non-returnable container.
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As you know,there will always
be a large -- Well there will be a number of people who are
really on the margin of their decision-iraking, and a slight
jiggling 6f the price one way or the other won't make a
change in their behavior. It may not cause a mass shift
from non-returnable to returnables.
So I would say that on the
surface there really isn't an inconsistency between the
two, but rather you have to take a look at the magnitude
of the price differential.
I would think, based on the
experiences (inaudible) that I'm not all together up-to-date
on, does suggest that once the price differential is made
somewhat greater, you will have a much greater response,
and you create a much greater demand for the returnable
containers.
JOHN ROBINSON: Any questions?
STEFFEN PLEHN: It's really come to an
informational question. In those communities in this
country where a user charge system is in place, do you know
what the experience has been in terms of the person with
solid waste, in an effort to avoid the charge, littering
or dumping, or otherwise discarding his waste so as to
avoid it?
HAYNES GODDARD: In other words, to what
extent does the presence of a user charge give incentive to
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dump Illegally?''
STEFFEN PLEHN: Yes.
HAYHES GODDARD: No-, I don't know, nor
does anyone else, to the best of my knowledge. There have been
some relatively superficial studies done on the question,
really, of indirect measures, and are a very poor data
basis, but they do suggest that there would be a slight
increase. And theoretically you indeed would expect that
there will be some individuals who would say, "I'm going
Co dump it someplace else."
But we don't really know, and
it has not been carefully studied, and my own feeling is
that we're probably -- it would be very difficult to find
out on the base of a historical study.
Probably you would have to have an experiment someplace
to see what would happen.
But the answer to the question
should be posed in these terms. Even though one would
expect theoretically that the presence of a local user
charge would give an incentive to some to litter, the
question is, once alternative mechanisms were in place
to both control that litter, that is,a clear enforcement
mechanism based on fines and perhaps beverage container
deposits, and information and picking up whatever does
get littered, which system represents the lower total
cost system? It's conceivable that the total cost of local
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28
solid waste management could indeed be lower under a system
which allows user charges and also expects some increased
littering cost. But all things considered, the total cost
would be lower.
Now this is also within the
context of source separation programs and resource recovery
programs.
It's also possible that the
total cost would be higher. And if that were the case, then
the evidence, I think -- one would have to conclude from
the evidence that the user charge system is not the best
system to do. But we don't know this, and I'm reasonably
confident that no one does. There are some formed opinions,
though.
STEFFEN PLEHN: From the institutional
point of view, would it be your feeling that serious
consideration be given to a federal requirement that states f
more local governments be required to institute the user
charge system? I'm asking that in the context of your
earlier statements about the free market choices and the
decentralization of decisionrinaking within our society.
HAYNES GODDARD: Well, my major thrust
is to preserve local choice and to have incentive mechanisms
that make solid waste management cost explicit. And so, in
general, I would say that probably is warranted in major
metropolitan areas, but there has to be room for exceptions.
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29
I don't doubt that there are
many local rural communities where the cost of solid waste
management is sufficiently low, or the external costs are
virtually nonexistant, that the benefits and costs of the
situation would warrant no user charge system. That is,
they would go on either disposing of it themselves or have
it financed out of the property tax. The situation is that
local cost conditions may be such that zero price would be
the proper price. Whereas in many other areas, some
positive price that would reflect the cost of collection
and disposal, would be the proper price.
So, if you were to legislate
that all communities were required to have it, you would
be forcing on some communities, I think,*a mechanism which
is really not warranted in terms of benefits and costs.
So the legislation would have to be in such a way to allow
that flexibility, otherwise you're running counter to my
whole thrust. You're imposing unnecessary requirements
c/e/77£/s*NS
upon communities. And that's exactly one of my crittalma—
of the product charge in requiring local communities,
such as Missoula, Montana, which is in the middle of
nowhere, which may not have to be subject to a product charge.
There is likely no opportunity that the material they use
would be recycled,because of the (inaudible) involved. It's
much cheaper for them to landfill it locally. So you're
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30
Imposing an unnecessary cost upon them, a cost that reflects
New York City, or Philadelphia, or Boston where waste
management problems are getting serious. Therefore, you
reduce their wealth unnecessarily.
EDWIN CLARK: Should one presume that
one should write a law that says that the user charge should
reflect actual costs? But from a political standpoint,
is it appropriate for the federal government to pass a law
dictating how communities should charge?
HAYNES GODDARD: Well, we do it already.
One part of the water pollution control act requires cost
sharing.
EDWIN CLARK: I don't think that's an
appropriate role.
HAYNES GODDARD: Well, I really couldn't
address that. I suspect I would quarrSl with the way it's
implemented. I usually do when it's done through legislation.
But it is a mechanism designed to make at least some of
the costs explicit to local dischargers in that case. So
the general thrust is appropriate.
EDWIN CLARK: The justification of the
Water Pollution Control Act involves about seventy-five
percent of the facilities, and, therefore, they have an interest
in trying to reduce the discharge. And in this case, there
is no such justification. So it seems there would be less
of a justification here.
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31
HAYNES GODDARR: Well, that's possible.
I really haven't thought, from a political point of view,
what kind of justification might be required. Certainly
in areas in which a solid waste management problem
u~j?
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32
that the user charge should be referred to the product
charge. As a matter of fact, I think that the user
charge would also stimulate the resource recovery
program, and it would do more, I think, although I
don't really know, to insure a consistent supply of
separated raw materials. Particularly if you allow the
household to have its separated waste picked up for nothing,
and the waste that it does not separate be subject to the
user charge. Or if not (inaudible) sufficient to give an
incentive and also to reflect any underlying cost.
One of the problems with the
self-separation programs is that the household has no
incentive to measure against the implicit cost of having
to separate and store separated waste. Whereas, if he has
an incentive by saving some money, through collection,
having the material picked up for nothing, then he would
be more likely to engage in it. Kow widely, of course,
depends on the level that is charged. Some households,
again, will always be in the margin and separate nothing.
Some do it for nothing already. Others will never do it.
That way you can insure, I think, a steadier supply of
materials.
Now, that's essentially the
supply side,and that doesn't create a demand. So in this
case a product charge might be appropriate to insure there
is a demand for the materials as well. Although resource
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33
scarcity, by itself, will also do that. If one projects ahead
that the scarcity situation may be for variously long
periods and may not require (inaudible).
RICHARD HERPST: You may well know that
the Resource Conservation Committee is addressing the
question of (inaudible). And in view of your comments
about taking an integrated approach, could you reflect
on whether this committee should be making a decision
with respect to mandatory deposits.
HAYNES GODDAM): Well, they certainly
are related. And on the surface I haven't thought about
that question very much. But if things are related I think
you certainly ought to be thinking about them in a
related framework. That would include a product charge
and mandatory deposits on containers. Because they are
substitute mechanisms for dealing with the solid waste
management program along some dimensions, and along other
dimensions they would be compliments. We really need to
determine which is which. Otherwise, I think the potential
is very great, as I think has happened with the water
pollution control, that we get ourselves locked into
mechanisms that in the long run prove to be frightfully
expensive, and uneconomic, and frequently don't work in
some cases or they overlook the fact that the communities
don't operate the mechanism, and so on. By looking at them
all together and sorting out what follows what and what
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34
relates to what seems to be a better approach £n~5n considering
them in isolation. But it does make the problem trore
complex.
JOHN ROBINSON-. Are there any other
questions? Thank you. Are there any others from the
audience that wish to rake a formal statement at this
time?
I notice from looking through
the registration cards there are a number of representatives
from state and local governments. We haven't really
heard much of anything from the state and local governments,
and if any of you have any thoughts on this issue we would
certainly be glad to hear them. No volunteers?
ROD EDWARDS: Could I make one
addition to Mr. Herpst's question on the international
trade? I neglected to mention that in addition to the
situation with Canada, we are in GATT negotiations now
with the objective of lowering tariffs world-wide.
And the product disposal charge on imports of paper could
be construed as an attempt by the United States to add
import duties. And that might upset those international
trade agreements and the objectives of the CATT
negotiations. Thank you. For the record, I'm Rod Edwards
of the American Paper Institute.
EDWIN CLARK: I'm not so sure about
your GATT argument. It seems to me that under the general
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35
GATT agreements that a product charge would not be
treated like a tariff or income tax. I think that it
could be adjusted under the GATT agreements.
The question I had is,
bot-h the head of the American Paper Institute and the
person speaking this irorning talked about the distribution
of income tax. Has the American Paper Institute done any
analysis on how this charge, in fact, would be distributed
across income levels?
ROD EDWARDS: No, I guess we really
haven't done anything that looks at the various income
levels and their consumption of paper. We do know that
the lower income groups are larger purchasers of packaged
food items, such as rice, pastas and cereals. That is
the largest part of the percentage of their disposable
income. So they are the larger buyers of packaging with
regard to their total disposable income. Therefore, we
say it's regressive because the impact on that wage level
would be greater from a percentage interpretation than it
would be on the higher income people who do not spend that
great percentage on packaged food products.
JOHN ROBINSON: Thank you. Is there
anyone else that would like to say anything on the subject?
EDWIM CLARK: Regarding the representatives
from state and local governments, if a product charge were
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Introduced it would be generated from a fair amount of
revenues, and there's the question of what to do with the
revenues. One of the proposals is to pass them back to
the state and local governments. And there are various
ways this could f,o. It could he a block prant to the
states. It could be a block prant directly back to
municipalities on the basis of solving waste costs.
Or it could be a (inaudible) grant proprar where it is
passed back to the local level for better solid waste
disposal facilities. Or it could be a state prant prop.ram.
I would be very interested
in getting peoples observations on the relative presence
of these alternatives. If there are representatives from
state and local governments, they must have some thought
on it.
JOHN ROBINSON: Does anyone care
to respond?
ROD TOWARDS: I've always wondered
how the return of revenues frotri the product charge is
going to impact upon individuals of those communities
that have private collections where governrents are not
involved. Are these individuals poinp, to have to pay
twice. That is, once when they have their material ilcVod
up, and once in the products they buy?
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EDWIN CLARK: That question -- there's
been no answer to any of these questions. That question
can be answered, like 1 say, in three ways. One is, some
attempt is v.ade to pass it back in such a way that it would
compensate the private -- these people who have their
waste privately collected, to the extent of passing
it back directly in solid waste collection costs.
The second is if it went
back to the coiranunities it would lower property taxes,
which would in some way compensate for not lowering the
solid waste collection costs.
WIDENTIFIED SPEAKER: It could
lower property taxes, it doesn't mean it would.
EDWI7T CLARK: That's a judgment
I think you have to be fairly careful of. You have to
be careful of making that judgment.
JOHi: ROEIT7SOK- Would anyone else care
to address that question? Does anyone on the Cor.miittee
have anything further to say?
DAVID ARELLA- I have a follow-up
question for Mr. Goddard. I think your point is well
taken about the need and value of local decision—waking,
and also about the cor.plitner.tary aspects of a user charge.
And I fully appreciate the incentive that this puts on
the consumer to be conscious of his waste.
-------
My follow-up question is,
do you feel there is any role or justification for an
incentive at the manufacturing l€'.vel both to increase
demands and also to produce waste?
KAYNF.S GODDARD: Well, since I'l? not
really intiirate with the lay studies and I haven't been
able to follow the concept as carefully as I would like ,
I would say there likelv are coirplerpentar ies to the two
approaches. And wy nain concern is, one is being pursued
(inaudible). I can envision that the rarket tvechanisir
I W§.fr~/v'., T'f -
nay not be sufficentiy int.euLitfe or sensitive to changes
in local waste management costs or changes in the incentive
structure on the local level, narticularlv the user charge,
making it explicit to the householder. It ray have little
impact on packaging configurations that the manufacturer
Now, on the other hand, it
doesn't have to be. I think we view the cot'isviraer as
tyoicallv knowing what he is doing, and yet retrospective
analysis indicate that consuirers make bad choices. In this
case, I think we can po far in that direction by sirr>ply
raintnininp a reasonably accurate and continual flow of
information to consumers , say, once a rx?nth when the bill
comes out, or however billing is effectuated. Txplain to
householders what the cost implications are if they continue
to buy non-returnable containers, if they buy packages that
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39
have four or five levels of packap;in;?, if they buy
containers that are four or five times larger than the
contents.
By this sort of mechanism
I suspect that the sensitivity of the market mechanism
can be improved a great deal. And the advantage of it
is it does still permit choice.
Now, if one does a complete
accounting of the benefits and see what we can do, the
benefits and costs of an alternative mechanism, I'm sure
there would be a liir.it to that kind of activity. And there
still may be a complimentary relationship for which it's
difficult to get consumer preferences translated effectively
back to the manufacturer or the packaging fabricator, and
maybe there would be some reason to have a product charge.
They would have to be phased in together. Maybe that
makes life more complex, but ny preference is, and, I think,
based on the values that I think characterize this society,
that's where we should begin. And then if we find that we
still have a problem, then we look for alternative rechanisms
that are more centralized.
Of course, they still go
through the political mechanism, but I think it's better
to start on the decentralized mechanism first, and then if
it doesn't work move towards more centralization.
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JO'-"I T>.Or.ItT?0*'- If there are no further
CMCStions, I'd lil'e to retrir.d everyone that vritten comnents
vill he accepted through the first of December and will
be distributed tc all the rorrittee jref-bers. T.'e vould
erco-'.rafe you to ploace subrit your written thoughts
or. tMs Issue.
I'e'll retrain around for
a while after we turn off the riicrofhor.es. So if anyone
vould liVe to talk s little bit rore inforrally atout it,
we'11 be here.
Thank you very much for
coirirp.
FEARINC COMCLUDEP
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STATEMENT
DY
JOHN T. TRACEY
SENIOR VICH PRESIDENT
PACKAGING CORPORATION OF AMERICA
TOR
TUB AMERICAN PATER INSTITUTE
BEFORE
RESOURCE CONSERVATION COMMITTEE
CincinnaLj, Ohio
Novomhor 1R, 1177
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- 4 -
We went longer distances for nrw supplies thus increasing
transportation costs, we financed m-w paper stock plants, we
advertised for new collection programs and our cost for waste
paper doubled, and in some cases, tripled in that year compared
to the historical average.
There is' an "available supply" of all grades of waste paper
out there, but it takes time to increase supply. You have to
alert the over 1500 paper stock dealers that additional tonnage
is needed, you have to get organizations interested in conducting
waste paper drives, you have to alert the public to save old news-
papers. Contract waste haulers who dump recyclable waste paper in
landfills or'burn waste paper in incinerators must be informed when
the time is right to deliver more waste paper to the mills.
It can take three to six months and in some cases as long as
a year for a substantial increase in supply to develop and mean-
while, all recyclers are bidding up the price of the existing paper
being collected. After the collection programs turn on new supply,
waste paper prices tend to stabilize at the lower historic levels.
In 1977, we are in a situation that is a replay of 1974. For
over 20 years, there has been an insulation material on the market
made from old newspapers. I do not think I have to tell you what
the demand is today for home insulation due to the cost of energy
and the possibility of tax credits. Well, we afjain have to in-
crease collection to meet the demand for recycled waste paper from
paper mills and insulators, too.
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I am John T. Tracey. I am Senior Vice President of the Packaging
Corporation of America (PCA) . My company is a member of the
American Paper Institute, the national trade association for the
pulp, paper and paperboard industry. The 200 member firms of API
produce more than 90S of all puJp, paper and papcrboard mania factnred
domestically.
As Chairman of the Recycled Paperboard Division of the API,
I am speaking today for the entire rccyclinq seqmcnt of the paper
industry. Many of the recyclers are small companies. Our mills
produce about 15 million tons of recycled paper.
I appreciate the opportunity to present to you, as a recyclor,
our views on the proposed solid waste disposal tax — or product
charge, as you call it.
The paper industry opposes thi'3 tax for a number of reasons --
it is inflationary, it is regressive, discriminatory and will cause-
market dislocations. These points were made yesterday at the
Washington hearings by Mr. Louis r. Lauri, President of the American
Paper Institute, and the recyclers support the API position.
When we review Senator Hart's hill, S 1781, and Appendix Ii of
the CPA 4th Report to Congress, we are concerned about the concept
and ajso the magnitude of Lhis tax. In the first full year of imple-
mentation — after the phase-in and rid ) us t moti ts for inflation — it
will cont paper produoi-rn who do no* use post-
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consumer waste paper $ 2. (> bi II ion por year and we would estimate
that this would add $4 to $5 billioi to the buyers of paper pro-
ducts because of the effect of the markups. This tax \s just so
mass i vc that it is go i ng to cut into the qrowt h rate of the paper
industry. Anything that dampens this overall growth rate will
have i mpnc t on the recycling segment,.
The paper industry and particularly the recycling segment
has supported the concept of resource recovery as the best solu-
tion to the solid waste problem.
For the paper industry, rosource recovery means recycling
waste paper. Currently, we are roeyd ing on a national basis
more than 3urfc of the old newspapers and used corrugated boxes
discarded after use. In fact, in some areas of the country we arc-
recovering over 50?, of these grades. Rccycl ing of waste paper,
separated at the source arid kept clean from contaminants, is
using waste paper at J ts highest economic value.
Not all waste paper can be recycled and that portion in
solid waste than cannot be roeye led should bo incinerated to
recover A t s fuel val vie to ijonoratc steam and o lect r i c i hy, The
paper i ruinst ry has for many years nt atod that we encouraged
increased recycling of waste-paper when it can be done on a sound
economic banis.
In 1977, the paper industry will be taking 17.S million tons
of wa1^t^ paper and other was t-c fihois from the solid waste stream:
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U,S. 1977 Waste Paper Col lection
Consumption at U. S. paper mills 14.5 million tons
U.S. exports of waste paper 1.5 million tons
Consumption lo make other products .5 million tons
Consumption of other waste fibers 1.0 million tons
Total 17.5 million tons
This total will increase by 1 million tons each year over the
next three years.
EPA officials when discussing increased recycling have? said
we need to increase recycling faster. If the paper industry says
that the economics are not sufficiontly favorable to cause a
faster increase EPA says it will force the economics. This is
one of our primary concerns with the tax.
As recyclers of waste paper, we are extremely apprehensive
about the impact of this tax on the economics of recycling, and,
therefore, we oppose this tax.
Solid waste tax proponents expoct increased recycling to take
place at the same time they expect waste paper prices will remain
constant. We anticipate that large paper companies, now not usinq
waste paper, will enter the waste p.iper markets causing dramatic
dislocations in the paper industry which will impact on the many
small recycling companies. In 1974, there was an all time high
in the world demand for waste pnper. To meet this demand, my
company, as well as al] companies uiinq waste paper, worked
feverishly to start-up new collection programs and to increase the
tonnage collected in existing programs.
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Now, I know wo will qot the paper. We always have and we
arc not going to shut down our mills. Wo may shut clown a day or
a week, but we will eventually qet the paper and recycling will
increase, and we will decrease the amount of old newspapers in
solid waste.
But the time factor is what worries me. How long will it
take and the greater worry is what will it cost?
My company operates four recycling mills and they are rather
small mills. They are unable to raise the price for paperboard
to offset dramatic increases in the prices for waste paper. If
they become unprofitable for a long period, we will be forced to
shut them down. We have shut down one mill in Michigan which
operated two paper machines, one machine in Indiana, and one machine
in our mill in Ohio because they were unprofitable.
We simply do not think this tax will increase recycling to
any significant extent — rather we think there will be a shift of
waste paper utilization from the snaller recycling mills to the
large mills who will want to avoid the tax or a percentage of it.
To increase recycling and reduce solid waste, we think there
is a real opportunity to work with FM A to develop new waste paper
collection systems that will generate waste paper supply on a
steady flow basis, at stable price', and cle n from contaminating
materi als.
We need a strong resource recovrry section in EPA that is
adequately funded and staffed. My crmpany, ap well as others,
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have worked with EPA's Office of Solid Waste to statt up new
municipal collection programs. Over 200 cities in Ihe U.S. have
such programs but few of them are large cities. We need more
cities and, specifically, more large cities collecting old news-
papers. As new solid waste processing plants are built, we need
to set up a priority for presorting recyclable waste prior to its
being comingled with other waste.
We need to fund research on developing new technology for
repulping waste paper and, particularly, technology to remove or
disperse the contaminants in waste paper such as adhesives, inks,
coatings and laminates. We think EPA can fund such research, and
we can work with you to select the consultants and to write the
objectives of this program.
We need to develop a communications program to alert the
American people to make that extra effort to separate waste paper
from other solid waste for recycling. In 1977, the API members
who recycle waste paper will spend $500,000 to ask the American
people to recycle waste paper and also, to buy products made from
recycled waste paper. We are on television, radio, in newspapers
and magazines to get our message across, but if it is to be effec-
tive, we need a vastly expanded program to inform the American public
on the importance of recycling more waste paper.
We want to increase recycling, but we need help on the supply
side. We do not need the tax. We want to work with EPA. We
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have done so in the past and wnnt to continue to do so. J would
like to suggest that we schedule a mooting at your ofliccr. at
Waterside Mall in Washington where we can start to work in a
positive way, rather than being here opposinq n tax which we
believe is a negative approach to solving the solid waste problem
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DuBOIS TOWER • CINCINNATI, OHIO 45202 • PHONE: (513) 762-6000
November 23, 1977
Ms . Susan B. Mann
Public Participation Liaison
Resource Conservation Committee (WH-563)
401 M Street SW
Washington, D. C. 20460
Dear MS. Mann;
I attended your November 18, 19/7, public meeting on the Solid Waste
Product Charge and was shocked that there was such poor attendance
and participation. That spurred me to write the following.
I have read your handouts in an effort to better understand the
questions, but I still have difficulty in addressing your specific
questions because they are probably too general for a short concise
answer. Instead I will reflect on the proposed Product Charge and
how it would affect DuBois Chemicals, our products and possibly our
customers, the Motels, Hotels and Industrial plants across the
United States. I have assumed that our packaging material would be
subject to a charge even though your emphasis is directed toward
consumer products.
DuBois Chemicals manufactures cleaners and detergents to clean dishes,
glasses and kitchen utensils in the Institutional trade and steel,
aluminum and finished appliances in the Industrial trade. Well over
600 products are marketed nationally with a sales volume of over
$130 million annually.
ror powaerea ana iiquia inauscriai products, me pac Ka£
from 1.7 cents per pound of product for the paper and st
to 4.20 per pound of product for the plastic containers.
The choice of packaging and amount of overpack given each product is
dictated by the market served and the characteristics of the product
be ing packaged. Institutional dishwashers want small packages of 2
to 10 pounds not 55 gallon drums, while industrial plants want 55 gallon
drums not two pound paper pouches. Corrosive liquids require plastic
or plastic coated steel containers.
; VISION OF CH9M6D CORPORATION
CABLE MISTERDU
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We package with the most economical material we can use consistent
with corrosion resistance, container failure rates, and container
availability. As prices change, formulas are modified, and the
used 55 gallon drum market fluctuates, we shift our packaging.
Our packaging is all in one way -- no return containers. The cost
of return, accounting and cleanout are too high to justify any kind
of a return program even with our truckload volume customers.
Doubling or tripling the cost of packaging would still not justify
a return program for most of our packaging. Some drums are re-used
by recycling through a drum reconditioner, not directly by DuBois.
The best disposal for our used paper and plastic packaging is through
incineration and heat recovery. Metal drums should be recycled
through steel scrap programs or drum reconditioners, as they are
presently.
A Product Charge on our various packaging would only increase its
price to us and to our customers. Disposal cost factored in the new
container cost would not be great enough to matter when compared with
the other cost factors that trust be considered. The cost of packaging,
currently much higher than the projected Product Charges, is not
sufficient to make a difference to our customers. Therefore, I conclude
that the addition of a Product Charge would make no difference either.
I see the solid waste problem as a local problem that must be handled
on the local basis. The cost of collection and disposal varies more
widely than the cost of packaging material, from a high in New York
to zero in rural areas. Recovery has proven economical in some cities
but not in others because of local conditions and institutions. I do
not think that a Product Charge will effectively attack or change the
local conditions that determine waste recovery or disposal methods.
Federal efforts should address the question of making known to the
public the institutional inhibitions we have built into our culture
that act to inhibit salvage, reuse or heat recovery of waste.
The Congress is debating tax incentives or laws to push more utilities
to coal, perhaps the same type incentives should be extended to burning
mixed waste by utilities.
In conclusion, we are opposed to the concept of a Product Charge. The
complications of equitably applying Product Charges and administering
the program far outweigh the benefits. The Product Charge will be
inflationary for most consumers. The Product Charge will probably not
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have the desired effect on the critical factors that determine
packaging on a national scale, just as it will have no effect
on us or our customers choice of packaging material.
Thank you.
NEW/lc
CC: E.
D.
J.
R. Loder
B. Harper
E. Donovan
Very truly yours,
DUBOIS CHEMICALS
Div. of Chained Corporation
Nelson E. Wittman
Ass't. Vice President
Government Relations
C. White
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Attendees—November IB, 1977
Albrecht, Oscar
Environmental Protection Agency
Research Center
26 West St. Clair
Cincinnati, Ohio 43950
Belewian, R . E.
Proctor * Gamble
Ivorydale Tech. Center
Cincinnati, Ohio 45217
Boehm, Richard W.
Contiental Can Co. USA
Sharonville, Ohio 45241
Bramble, Gary M.
Mead Corp.
Courthouse Plaza N.E.
Dayton, Ohio 45402
Brown, Alex C.
Solid Waste Comm. of
Environmental Advisory
Council of Cincinnati
2355 Fairview Ave.
Cincinnati, Ohio 45219
Castillo, Leonard
Dow Chemical
2030 Dow Center
Midland, Mich. 48640
Culkin, G. W.
Goodyear Tire & Rubber Co.
1144 E. Market St.
Akron, Ohio 44316
Donovan, James E.
DuBois Chemicals
DuBo i s Towe r
Cincinnati, Ohio 45202
Edwards, J. Rodney
American Paper Institute
260 Madison Avenue
New York, New York 10016
Fatkin, Harry
Polaroid Corp.
Technology Square
Cambridge, Mass. 02139
Hearring, Samuel M.
City of Evansville
Environmental Protection
Agency; Rm. 207; Adm. Bldg.
Civic Center Complex
Evansville, Ind. 47708
Goddard, Haynes C. Prof.
Dept of Economics
University of Cincinnati
Cincinnati, Ohio 45221
Hildebrandt, Jeff
WLWAAM-Radio
901 Elm Street
Cincinnati, Ohio 45202
Hill, Gregory J.
NEFCO
137 S. Main Street
Akron, Onio 44308
Lapp, W. L.
Mead Cor p.
P. 0. Box 2500
Chillicothe, Ohio 45601
Lucke, William E.
Cincinnati Milacron Inc.
P . 0. Box 9013
Cincinnati, Ohio 45209
Macke, Bobby
League of Women Voters
7305 Drake Road
Cincinnati, Ohio 45243
Myers, R. D.
YMCA of Northern K\.
624 Madison Avenue
Covington, Ky. 40512
Nelson, Helaine Q.
Beverage Management Inc.
1001 Kingsmill Pkwy.
Columbus, Ohio 43216
Reed, Allen M.
General Electric-
Cincinnati Chamber of Commerc e
Mail Drop A-79
Cincinnati, Ohio 45215
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Schuck, Arthur H.
Superintendent; Div.
of Waste Collection
City of Cincinnati
Cincinnati, Ohio 45268
Smith, C. Arden
Proctor & Gamble Co.
301 E. Sixth Street
Cincinnati, Ohio 45201
Staff, William A.
Evansville E. P. A.
207 Adm. Bldg., Civic Center
Evansville, In. 47708
Sterling, Gary D.
U. S. Brewers Assoc.
P. O. Box 29009
Columbus, Ohio 43229
Taggart, Robert
General Motors
G.M. Tech. Center (EAS)
Warren, MI. 48084
Theohorous, Lew
Proctor & Gamble
301 E. Sixth Street
Cincinnati, Ohio 45201
Tracey , J. T.
Packaging Corp, of America
1603 Orrington Avenue
Evanston, Illinois 60201
whiting, w. D.
Container Corp. of Amer.
1 First Nat'l Plaza
Cincinnati, Ohio 45202
Wittman, Melson
DuBois Chemical Co.
511 Walnut
Cincinnati, Ohio 45202
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