SW-72-4-4
ANALYSIS OF
FEDERAL PROGRAMS AFFECTING
SOLID WASTE
GENERATION AND RECYCLING
^\. ^
BWa
SOLID WASTE RESEARCH LABORATORY
OFFICE OF RESEARCH AND MONITORING
NATIONAL ENVIRONMENTAL RESEARCH CENTER
CINCINNATI, OHIO
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SW-72-4-4
ANALYSIS OF
FEDERAL PROGRAMS AFFECTING
SOLID WASTE
GENERATION AND RECYCLING
SCS ENGINEERS
performed the investigation and prepared
this report for the
Solid Waste Research Laboratory of the
National Environmental Research Center, Cincinnati,
under Contract No. EHS-C-71-O1O6
U.S. Environmental Protection Agency
Office of Research and Monitoring
National Environmental Research Center, Cincinnati
1972
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REVIEW NOTICE
The Solid Waste Research Laboratory of the National
Environmental Research Center, Cincinnati, U.S. Environmental
Protection Agency, has reviewed this report and approved its
publication. Approval does not signify that the contents
necessarily reflect the views and policies of this laboratory
or of the U.S. Environmental Protection Agency, nor does
mention of trade names or commercial products constitute
endorsement or recommendation for use.
The text of this report is reproduced by the National
Environmental Research Center, Cincinnati, in the form
received from the Contractor; new preliminary pages and cover
have been supplied.
ii
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ABSTRACT
Agencies of the Federal government have been assigned the
responsibility of carrying out many programs, some of which
affect either the generation or recycling of solid wastes
throughout the country. The effects on solid waste generation
and recycling of most of the approximately 1,000 Federal agencies
are minimal or nonexistent; however, some of the Agencies'
programs have a very direct effect. The 12 agencies identified
as having the most influence are the subject of this study.
Specifically, they are:
Office of Tax Analysis, Treasury Department
Federal Highway Administration
Federal Trade Commission
Forest Service, Department of Agriculture
General Accounting Office
Interstate Commerce Commission
National Bureau of Standards, Department of Commerce
Office of Community Development, Department of Housing
and Urban Development
Department of Defense, Defense Supply Agency
United States Postal Service
Property Management and Disposal Service, General
Services Administration
Public Building Service, General Service Administration
In addition to determining the extent of the respective agency
influences, the report contains several specific recommendations for
improving the Federal role in national solid waste management.
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FOREWORD
To find, through research, the means to protect, preserve, and
improve our environment, we need a focus that accents the interplay
among the components of our physical environment - the air, water,
and land. The missions of the National Environmental Research
Centers - in Cincinnati, Research Triangle Park, N. C., and
Con/all is, Ore., - provide this focus. The research and monitoring
activities at these centers reflect multidisciplinary approaches to
environmental problems; they provide for the study of the effects
of environmental contamination on man and the ecological cycle and
the search for systems that prevent contamination and recover valu-
able resources.
Man and his supporting envelope of air, water, and land must
be protected from the multiple adverse effects of pesticides, radia-
tion, noise, and other forms of pollution as well as poor management
of solid waste. These separate pollution problems can receive inter-
related solutions through the framework of our research programs -
programs directed to one goal, a clean livable environment.
This document, published by the National Environmental Research
Center, Cincinnati, reports on a study of the activities of 12
Federal agencies whose programs and policies might influence solid
waste generation and recovery. Having the Federal government
consistently identified with sound solid waste practices is
important, and this report and its recommendations will be of
especial interest to workers concerned with environmental pollution
and to the agencies involved.
ANDREW W. BREIDENBACH, Ph.D.
Director, National Environmental
Research Center, Cincinnati
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ACKNOWLEDGEMENTS
This work effort, initially involving a review of all Federal agencies and
later 12 specific agencies, would have been an impossible task without the
assistance of many government and private industry representatives. We have
included as Appendix I a tabulation of those persons who collaborated with
the study team in this research work. Their assistance and support is
gratefully acknowledged.
We are pleased to acknowledge those persons providing continuing
assistance throughout the execution of the project. Mr. Harry Freeman,
Project Officer, Environmental Protection Agency (EPA), not only provided
direction and guidance, but gave invaluable support during the preparation
and review of the final report. His assistant, Mr. Richard Ongerth, also aided
the study team. Mr. John Hill, EPA, provided necessary interagency liaison
assistance while gathering information in the Washington, D.C. area. Mr. Eric
Zausner, of the Council on Environmental Quality also assisted the study
team.
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CONTENTS
I Introduction 1
II Off ice of Tax Analysis 3
III Federal Highway Administration 17
IV Federal Trade Commission 33
V Forest Service 41
VI General Accounting Office 53
VII Interstate Commerce Commission 59
VIII National Bureau of Standards 75
IX Office of Community Development 83
X Department of Defense 95
XI United States Postal Service Ill
XII Property Management and Disposal Service and Public Building Service 119
References 129
Glossary 141
Appendix IOfficials Interviewed 145
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SUMMARY AND RECOMMENDATIONS
National interest in environmental matters in general and in resource recovery in
particular has increased in recent years. The Environmental Protection Agency (EPA)
recognized that Federal efforts aimed at controlling solid waste generation and encouraging
waste recovery and refuse would be enhanced if all Federal agencies operated under policies
and regulations that were in concert with national environmental goals. Consequently, this
study was militated to determine those Federal Government programs and policies that
might influence solid waste generation and recovery and to identify the policies that are
counter to resource conservation and recovery goals. The study was a relatively brief review
of Federal practices.
Summary
This report presents the results of a 9-month investigation during which the effects of
Federal activity on solid waste generation and resource recovery were studied. A preliminary
survey was made of all Federal agencies and their possible influences on solid waste
generation and recycling. The vast majority of the approximately 1,000 Federal agencies
had little or no influence on solid waste generation and resource recovery. Forty-nine
agencies with policies or regulations that had or could have an effect on the generation or
recovery of solid wastes were identified.
Based on results of the initial study, the following 12 agencies were selected by EPA for
further study.
Office of Tax Analysis, Treasury Department
Federal Trade Commission
Forest Service, Department of Agriculture
General Accounting Office
Interstate Commerce Commission
National Bureau of Standards, Department of Commerce
Office of Community Development, Department of Housing and Urban
Development
Department of Defense, Defense Supply Agency and selected aspects of the
Department of the Air Force and Department of the Army.
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United States Postal Service
Property Management and Disposal Service, General Sendees Administration
Public Building Service, General Services Administration
Agency policies and programs do influence solid waste generation or resource recovery, or
both. However, surprisingly few agency policies were found that had a major effect on the
generation of solid waste or inhibited recovery. Conversely, most agencies had policies and
practices in effect to encourage resource conservation and waste reclamation. The more
significant influences are discussed in the report.
Recommendations
Many Federal policies and regulations affect solid waste generation and recycling to
varying degrees. Certain policy changes could enhance the possibilities for recycling and/or
could discourage waste generation. In some cases the basic laws administered must be
altered to more positively influence resource recovery efforts. Some agency influences on
solid waste recycling and generation are too complex to judiciously develop recommended
policy changes based on this brief study. Additional work is required for these agencies in
order to make specific recommendations. The following recommendations are consolidated
from the body of the report. Other recommendations for each agency studied are included
within the report.
Federal tax provisions allowing special treatment of income derived from virgin
resource development should be altered so that secondary material recovery and
processing receives equivalent tax treatment. The marketability of secondary
materials should be enhanced by this action.
The Tax Reform Act of 1969 should be clarified and/or revised to include solid
waste as well as air and water pollution control facilities and to allow accelerated
depreciation on facilities intended to reclaim resources from solid wastes.
The Interstate Commerce Commission should determine the influence of freight
rates on secondary material movement, sales, and corresponding degree of resource
recovery. Insufficient evidence exists to indicate whether present freight rate
differentials actually impede the recovery of solid waste materials.
In those Federal activities requiring the preparation of an environmental impact
statement, consideration should be given to anticipated solid waste generation, and
alternatives for waste reduction, reuse and recovery.
The Forest Service should periodically revise its tree-cutting specifications and
regulations to reflect technological advances so as to increase yield from the
harvested logs, use other parts of the felled or down timber, and otherwise reduce
the quantity of waste residue.
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The Office of Community Development should more actively cooperate with the
Federal Highway Administration so that demolition rubble generated in the course
of urban renewal work can be incorporated whenever practical into highway
embankments.
More study is required to establish the following:
The type and advisability of special income tax incentives to encourage resource
recovery.
The effectiveness of the property management systems in the civilian and military
sectors. Indications are that possibly solid waste generation may be reduced and
additional materials recovered if improved controls were instituted and/or existing
provisions more closely controlled.
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CHAPTER I
INTRODUCTION
Background and Purpose
The decade of the seventies has brought increased public and governmental concern for
the quality of the environment and conservation of resources. In the Declaration of National
Environmental Policy (National Environmental Policy Act of 1969, Public Law 91-190),
Congress stated that the Federal Government should use all practical means to enhance the
quality of renewable recycling of depletable resources.1 President Nixon, in his message on
the environment in 1970, stated, "One way to meet the problem of solid waste is to simply
surrender to it .... Our goal must be broader: To reduce the volume of wastes and the
difficulty of their disposal and to encourage their constructive reuse instead."2
However, some existing Federal policies and regulations may have a counterproductive
influence, thereby impeding progress toward the commendable goals expressed by the
President. Existing policy often exemplifies the "unlimited resources" thinking of our
country's earlier "frontier" years. Federal agencies, in carrying out their respective
responsibilities, establish regulations, policies, and controls, that in addition to their
expressed purpose, may have a secondary effect on the generation or reclamation of solid
wastes.
Accordingly, the Environmental Protection Agency (EPA) authorized this brief study to
identify laws, rules, regulations, and practices that were instituted without consideration of
the effect on solid waste generation and recovery. The priorities of the seventies, including a
clean environment and the rational use of limited natural resources, should not be prevented
from realization because of antiquated Federal laws and policies.
This report presents the results of a 9-month study undertaken to determine and analyze
the effect of ongoing Federal activities on solid waste generation and recycling. Time
constraints limited this study to a brief coverage of Federal programs. This is especially true
of the larger and more complex agencies, particularly the Department of Defense.
Approach
All major Federal Government agencies were surveyed to determine those policies, laws,
and regulations that in some way may add to the generation of solid waste and/or
discourage the recovery of usable solid waste constituents. Forty-nine agencies administering
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such policies and regulations were identified. A brief description of how their activities
affected solid waste generation and reclamation was provided in an earlier unpublished
report to the EPA, together with a complete bibliography of all documents, periodicals, and
other references used.
Based on results of the initial work, the EPA selected the following 12 agencies for
further study.
Office of Tax Analysis, Treasury Department
Federal Highway Administration, Department of Transportation
Federal Trade Commission
Forest Service, Department of Agriculture
General Accounting Office
Interstate Commerce Commission
National Bureau of Standards, Department of Commerce
Office of Community Development, Department of Housing and Urban
Development
Department of Defense, Defense Supply Agency, and selected aspects of the
Departments of the Air Force and Army.
United States Postal Service
Property Management and Disposal Service, General Services Administration
Public Building Service, General Services Administration.
During an ensuing 3-month period, project staff met with agency representatives in the
Washington, D. C. area. Representatives of numerous industrial associations and other
pertinent organizations were also interviewed to further explore agency influences or
impacts on solid waste generation and recycling. Quantitative data indicating the extent of
agency influence were gathered when available.
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CHAPTER II
OFFICE OF TAX ANALYSIS
TREASURY DEPARTMENT
Abstract
Income tax treatment varies between industries just as between individuals. Certain tax
provisions give special treatment to those businesses mining virgin resources from the land.
An entrepreneur who "mines" resources from solid waste, however, is not entitled to similar
tax treatment. Since the resources, regardless of origin, must ultimately compete for buyers,
these tax laws discourage resource recovery efforts by inhibiting their potential profitability.
Other aspects of the tax law also influence resource recovery efforts. For example,
municipal solid waste disposal operations are tax exempt. A business engaged in recovering
materials from solid wastes is taxed on any profits. In an evaluation of relative economics,
this factor favors a decision to discard solid wastes rather than attempting to recover
reusable portions.
Accordingly, the Federal tax structure, as delineated in the Internal Revenue Code, was
studied. The Office of Tax Analysis furnishes technical support in development of proposed
changes in the tax law.
Background
Taxes are the major source of operating revenue for the Federal Government. Annual
income tax revenues from corporate and individual sources currently approximate $130.4
billion. Excise tax revenues currently approximate $17.5 billion annually.3
Taxes have pronounced effects on economic activity, since many businesses and
individuals base important decisions upon tax code provisions. The original intent of
taxation was the generation of revenue. Today, however, the tax structure is also used to
change national economic policies and to encourage activities that appear beneficial to the
Nation. For example, natural resource development and industrial modernization are
encouraged by favorable tax policies. Thus, the Federal tax structure can be used to attain
apparently beneficial social and economic goals that are not directly related to revenue
needs.
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Role of the Office of Tax Analysis. The Office of Tax Analysis was chosen for study
because of its role of advising and assisting the Secretary of the Treasury on tax policy
issues. Among other functions, the Office investigates the probable effects of proposed tax
measures and the actual effects of existing tax legislation. Therefore, this Office was in an
excellent position to advise on the role of Federal taxes in relation to the national solid
waste problem.
The role of the Office of Tax Analysis is only investigatory and advisory. Changes in tax
laws can be made only by Congress, and by the courts through interpretive decisions. As an
arm of the Executive Branch, the Treasury Department develops tax proposals and policies
that are sent to Congress for approval. The Internal Revenue Service (IRS), Treasury
Department, is charged with implementing tax laws, assessing taxes, and collecting monies.
There are two aspects of tax law discussed herein: (1) the effect of present tax laws on
solid waste generation and reclamation and (2) the possible changes that could be made to
reverse undesirable conditions.
A source for major portions of the information in this chapter was a paper prepared for
the Council on Environmental Quality by Mr. Richard E. Slitor of the Office of Tax
Analysis.4
Encouragement of Use of Virgin Resources
The Internal Revenue Code affords tax advantages to developers of virgin raw materials.
Similar advantages or incentives are not now available to those who are engaged in
recovering secondary materials. Three main provisions in the Code are detrimental to
resource recovery: (1) Depletion allowances; (2) development expense exemptions; and (3)
capital gain treatments. These are discussed below.
Depletion Allowances. From the inception of the income tax, Congress has indicated its
desire not to tax capital gains as highly as ordinary income. Thus, the individual capital gains
tax rate does not exceed 25 percent (increasing up to 35 percent for amounts over $50,000)
regardless of the individual's bracket for normal income nax. In addition, owners of
extractive businesses, such as ore mines, oil wells, and timber stands, are allowed a tax credit
for a portion of their income derived solely from their properties. This credit is in
recognition that part of what apparently was ordinary income is a return on invested capital
or a capital gain. For example, when a ton of coal is sold, the excess of what was received
from the cost of mining that ton "is by no means all income; part of that excess must be
treated as a repayment of what was invested in the mine from which the coal was
taken . . . "s The special tax credit allowed to extractive industries for this type of income is
known as a depletion allowance.
There are two types of depletion allowances used by industry in reducing its income
taxes: cost depletion and percentage depletion allowances. The cost depletion allowance is
computed by dividing the estimated total number of recoverable units in the deposit (i.e.,
tons of ore, barrels of oil, etc.) into the original cost of the property less all previous
depletion allowances (called the adjusted basis) and multiplying the resulting rate per unit
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(depending on the accounting system used) by either the number of units for which
payment is received during the tax year, or by the number of units sold.6 Cost depletion
deductions cease when the adjusted basis of the property reaches zero. An example of a cost
depletion allowance calculation is given below.
If the owner of a timber stand paid $10,000 for the timber and $8,000 for the land, his
tax basis for the timber would be $10,000 (cost of the timber). If there was 1 million
board-feet on the land, the depletion unit would be $10 per thousand board-feet. If he
felled 500,000 board-feet of timber in 1 tax year, his depletion allowance would be
$5,000.7 This $5,000 can be deducted from net income before taxes.
To determine the percentage depletion allowance, a percentage (ranging from 5 to 22
percent, depending on material mined or otherwise extracted) is multiplied by the gross
income from the property for the tax year. The only restriction is that the deduction
calculated under this method cannot exceed 50 percent of the taxable income without
depletion allowances.8 A sampling of applicable materials and their corresponding
percentages is given below.
Depletion
Material (percent)
Sulphur, uranium, lead, nickel 22.0
Oil and gas 22.0
Gold, silver, copper, iron ore 15.0
Coal, sodium, chloride 10.0
Clay (for sewer pipe or brick) 7.5
Clay (for pots, roofing tile), gravel, sand 5.0
Most other minerals and metallic ores 14.0
Percentage depletion allowances are not applicable to timber harvesting; only cost
depletion allowance is permitted for timber. Mineral extraction operations may apply either
percentage or cost depletion allowances, whichever provides the greater deduction.
Percentage depletion can be applied as long as the mineral deposit produces, even after the
original cost has been completely recovered. In addition to the income derived from the sale
of the mineral itself, certain transportation charges and processing steps applied by the mine
owner or operator to add value to the mineral for marketing purposes can also be included
as part of the gross income to which the percentage depletion rate is applicable. In ferrous
metals mining, for example, the costs for sorting, concentrating, sintering, and loading for
shipment are all processing steps for which the percentage depletion rate applies. The
following is an example of a percentage depletion allowance:
The owner of an iron mine complex had annual gross sales of $20 million. Prior to selling
the iron ore, it was transported from the mine to the mill at a cost of $1 million and
processed at the mill at a cost of $2 million. The percentage depletion allowance was
computed at $3 million ($20 million x 0.15). If the total expenses of the complex, including
the owner's transportation and processing costs, were $13 million, the taxable income
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would be $7 million. Since 50 percent of $7 million is greater than the percentage
depletion allowance, the taxable income limitation does not decrease the deduction.
On the other hand, those who reclaim and process secondary materials that compete with
virgin materials are subject to normal income tax treatment under the Internal Revenue
Code. Income derived from the collection of secondary materials (similar to mining),
processing it into an acceptable form (analogous to virgin material treatment and
processing), and sale is fully taxable. Herein lies the main alleged tax discrimination favoring
new materials. Conversely, it can be argued that the tax advantage afforded new materials
reduces the cost of the new material, and this reduced cost carries down to a lower cost for
scrap.
Development Expense Exemptions. Costs incurred in developing mineral deposits can be
capitalized and subsequently depreciated over several years or taken as current deductions,
whichever tax treatment results in a lower tax burden. Qualified development costs include
those for mine shafts, tunnels, and stripping when incurred after the presence of minerals
has been ascertained. Expenses incurred during an unsuccessful exploration for new domestic
resource deposits are completely deductible and not subject to recapture.
Through this mechanism the tax structure encourages exploration for new sources of
virgin materials and development of such sources. There is no similar encouragement given
to businessmen who develop a source of raw materials from residuals.
Capital Gain Treatments. Owners of timber, coal mines, and iron ore deposits are
afforded additional tax benefits. Using timber as an example, a taxpayer who has owned a
timber stand for more than 6 months and cuts the timber either for sale or use in his
business may treat such a cutting as a sale or exchange. Under this provision, the difference
between the original cost of the standing timber and the market value on the first day of the
taxable year is treated as a long-term capital gain or loss rather than as straight income. Also,
income derived from disposal of standing timber under a cutting contract may be treated as
a sale under certain conditions and can also qualify for capital gains treatment. Even though
the owner may be a dealer in standing timber, he is permitted capital gains treatment.
The overall impact of this provision on timber, coal and iron ore resource owners is a
reduced tax rate since capital gains are taxed at a lower rate than normal income.
Impact on Resource Recovery. The economic effect of tax advantages afforded owners
and producers of virgin natural resources is significant. A sizeable tax savings is afforded
those industries engaged in extracting new materials from the earth while industries engaged
in collecting and processing competing materials from the waste stream must pay normal
taxes.
Minerals. Table 1 illustrates the effect of depletion allowances on income for certain
extractive industries in 1966.9 The portion of total revenue generated in the mining
industry that was not taxed because of depletion allowances ($1.02 billion) represented 109
percent of the net income after taxes ($0.94 billion). Considering the metal mining
industries only, tax-exempt receipts in the form of depletion addled about 60 percent to this
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industry's after-tax income. The corresponding figure for the nonmetallic mineral mining
industry was 127 percent. Businesses engaged in resource recovery activities have no
corresponding tax deductions that favorably affect their profitability in this manner.
TABLE 1
1966 CORPORATE INCOME TAX ANALYSIS
FOR SELECTED MINING INDUSTRIES9
(Dollar amounts in millions)
Total number of returns
Number of returns with net income
Total receipts
Total deductions
Depletion*
Net income (less deficit)
Income tax
Investment credit*
Net income (after taxes)
Total
mining
14,831
7,284
$14,609
12,884
1,021
1,740
832
32
940
Metal
mining
886
267
$2,990
2,420
209
576
226
10
360
Nonmetallic
minerals
mining
3,685
2,323
$2,681
2,546
109
134
56
8
86
* Included within total deductions.
tIncludes adjustment for constructive taxable income from related foreign corporations.
Table 2, the 1967 income tax analysis for the iron ore mining industry, indicates more
specifically the tax advantages provided virgin material suppliers.10 Overall, the 140 iron
ore mining companies submitting income tax returns lost approximately $95 million in
1967, which included $19 million paid in income taxes and $37 million in depletion
allowances. The $37 million in depletion allowances claimed by the iron ore industry
represented 5.6 percent of the $657 million receipts for the industry. If passed on to
customers, this savings could have reduced prices by $0.61 per ton, using the average price
for iron ore at the mine of $10.21 per ton in 1967.11 The average depletion allowance is
only about one-third of the maximum percentage depletion allowance, due in part to the
above-described limitations. For individual plants that can apply the maximum percentage
depletion allowance of 15 percent, and a $10.21 per ton price at the mine, the depletion
allowance can reduce the price of iron ore by $1.80 per ton. Thus, although the depletion
allowance has the potential to reduce the price of iron ore by as much as $1.80 per ton, the
nationwide average would have been $0.61 per ton in 1967.
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TABLE 2
1967 INCOME TAX ANALYSIS FOR THE
IRON ORE MINING INDUSTRY10
(Dollar amounts in millions)*
Total number of returns 140
Number of returns with net income 29
Total assets $1,309
Total receipts 657
Total deductions 735
Depletion1" 37
Net income (less deficit) 77
Other special deductions 23
Taxable income 45^
Income tax 19
Investment credits 1
Net income (less deficit) after taxes 95
* Figures are rounded to the nearest million dollars and therefore do not add in all cases.
t Depletion included within total deductions.
$ Although the overall industry lost money, companies within the industry had a taxable
income of $45 million.
The percentage depletion allowance can either enhance the after-tax profitability of the
iron ore mining industry or reduce the selling price of the product. Either course serves to
encourage iron ore production and use. Since ferrous scrap is the only other domestic source
of ferrous resources, secondary materials dealers in these commodities are competing for
sales with iron ore at a disadvantage of about $0.61 per ton of ore.
Paper, Capital gains treatment afforded to the timber industry, including producers of
pulpwood, encourages use of virgin wood fibers in papermaking instead of fibers reclaimed
from wastepaper. Due in part to the effect of capital gains treatment, the effective rate of
tax on the timber industry's taxable income was 35 percent in 1966, compared with a
maximum statutory rate of 48 percent and an effective tax rate of 44 or 45 percent for all
industries as a whole.
The effect of these favorable tax treatments on the ultimate sales price of virgin pulp can
be estimated. In 1970, 70.3 million cords of pulpwood were produced and sold for an
average price of $19 per cord.12 This corresponds to approximately $24 per ton. Assuming
a gross profit margin of 8 percent of sales, or $1.92 per ton, the approximate 10 percent tax
savings can amount up to $0.19 per ton due to capital gains treatment alone.
Assuming all of this savings had been reflected in lower prices, the sales price would have
to be increased by $0.35 per ton in order for the seller to realize the same after-taxes profit
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without the capital gains treatment. This simplified example assumes that the market would
allow an increase in profit margin from 8 to 9.4 percent of sales.
In addition, IRS figures indicate that in 1967, the 25 largest paper and allied products
manufacturers had total receipts of $7.5 billion and used cost depletion allowances of $67
million.1 3 As previously indicated, timber harvesting is eligible for cost depletion allowance
but percentage depletion does not apply. Thus, depletion accounted for approximately 0.9
percent of receipts, representing an additional potential price reduction of $0.22 per ton
(0.9 percent x $24 per ton). Accordingly, suppliers of virgin paper fiber may have passed a
$0.57 per ton ($0.35 + $0.22) savings on to consumers.
Many paper manufacturers are large integrated corporations. They not only produce and
market paper, but also own and operate the tree farms and forests for needed raw materials.
These manufacturing processes are designed to use virgin wood fiber. Tax savings attainable
by owners of timber stands were cited by paper manufacturers as one reason for becoming
integrated. Hence, the income tax structure further encourages the use of virgin fibers at the
expense of secondary wood fibers recovered from solid waste.
Encouragements for Solid Waste Generation
Depreciation Allowances. It has been generally recognized that income tax deductions for
depreciated property and investment credits can have the effect of shortening equipment
and building lives, although no quantitative estimate was made within the scope of this
project. Depreciation schedules are generally developed by the IRS based on the expected
useful life for equipment and machinery. Industry often replaces equipment before or soon
after its original purchase price has been recovered through depreciation deductions, even
though useful life may remain. This practice tends to increase material consumption and
also solid waste generation because earlier sale or scrapping of equipment is encouraged. In
July 1971 new tax depreciation rules were put into effect to allow businesses to shorten by
20 percent the number of years over which new machinery and equipment may be
depreciated. The effect of the new rules is to reduce income taxes on business by 5.8
percent, a reduction of $2.8 billion in 1971 and an average reduction of $3.9 billion over 10
years.
Depreciation allowances and investment credits are not the only factors causing early
equipment replacement. Businesses must continually update their operations and replace
equipment and machinery as technological advances occur in the industry. Income tax
provisions such as depreciation allowances do encourage industrial modernization and
equipment replacement to some degree. Some equipment having useful life remaining may
be discarded as a result, thus contributing to solid waste generation. The subject of
depreciation allowances and their effects is quite complex and cannot be fully discussed
within the scope of this study.
Tax Exemption for Municipalities. Resource recovery is presently practiced to a very
limited extent in this country, partially because of Federal tax provisions. Most solid wastes
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are not reclaimed but are discarded at disposal sites. This is particularly true of most
municipal solid wastes.
The Internal Revenue Code, in effect, provides incentives to municipalities to establish
and operate solid waste collection and disposal activities. These: include the following:
Municipal activities are tax exempt.
Municipalities can usually borrow funds at relatively low interest rates through
tax-exempt securities.
Local sales, excise, and property taxes, and other sources of operating funds for
municipal activities are deductible from individual income taxes.14
Municipalities could conceivably operate resource recovery sytems using funds derived
from tax-exempt sources. However, the mission of municipal solid waste management
system has generally been restricted to protecting environmental health. There has been a
hesitancy on the part of local governmental agencies to spend taxpayer money on untried or
experimental methods.
Therefore, it has been left to private enterprise to attempt the development and
implementation of a system to recover resources from municipal wastes. However, the
recovery system must be competitive with municipal or private disposal operations now
serving the municipality. The entrepreneur cannot charge a municipality more to reclaim its
waste than the city presently pays for disposal, or else the city would wisely choose to
continue the present method. But a private entrepreneur competes with the city on unequal
footing. He must pay federal income taxes on corporate earnings while the city is under no
tax liability. Business must pay the prevailing interest rate on borrowed funds (currently
about 7V4 percent) while the city is entitled to preferred treatment (municipal bond interest
rates are currently about 5Vt percent).15 Resources recovered by the entrepreneur must be
marketed without tax assistance, whereas the municipality may raise operating funds
through sources that are deductible for contributors.
Possible Tax Incentives to Achieve Resource Recovery Goals
The use of the Internal Revenue Code to stimulate activity in specific sectors of the
economy has long been practiced. Natural resource mining has been encouraged through the
depletion allowance. Investment in housing has been more attractive because of beneficial
depreciation considerations. In recent years, Congress has indicated its willingness to use the
tax laws to stimulate investment in facilities that are designed to protect the environment
(see the following section). Therefore, it was beneficial to explore examples of possible tax
incentives that would promote action toward solid waste recovery and reduced generation.
It should be noted that these incentives are conjecture only; no quantitative measure of
their potential impact was possible without an in-depth economic and technological study.
Analysis of potential incentives is also complicated because of multiple ramifications in the
economy, both predictable and unforseen, which should be expected.
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There are two main avenues by which tax incentives can be implemented: through the
excise tax mechanism or through income taxes. Potential incentives will be discussed under
each heading.
Excise Taxes. From the standpoint of administration, the imposition of excise taxes to
attain environmental ends is preferred, rather than the alteration of the income tax
structure. Revenues can be predicted more accurately under the excise tax system,
facilitating fiscal planning. Examples of excise taxes that could be imposed to encourage
attainment of resource recovery goals are briefly discussed below.
Excise Tax on Use of New Material. Under this plan, an excise tax would be imposed on
the production of material, e.g., paper, aluminum, or steel, manufactured wholly from virgin
resources. This would increase the price of such materials while competing products made
with at least a minimum specified percentage of reclaimed materials would not be taxed.
The latter materials would presumably become more competitive in the open marketplace.
There could be many problems associated with the imposition of such a tax, including the
following:
Identification and certification of manufacturers using recycled materials in their
products would be difficult to monitor.
Virgin material producers and users would likely lobby against such a tax.
The costs for reclaiming enough secondary materials to replace virgin materials in
manufacturing may be excessive, thus canceling the price advantage desired.
Excise Tax on Disposable Goods. In order to reduce the total quantity of solid wastes
generated, use of consumer goods having a short use life could be discouraged. After an
extensive study to establish the expected useful lives of all classes of commodities, or to
establish the relative environmental impacts associated with their disposal, appropriate
excise taxes could be levied on short-lived and/or problem commodities. This tax would
raise the price to consumers of such goods and discourage purchase and use. Of course, the
value of the product must also be considered in assessing the proper tax. Theoretical
examples of applications of such a tax are as follows:
Commodity Excise tax (%)
Newsprint and candy wrappers 10
Steel, aluminum, and glass beverage containers 8
Boxboard 7
Auto tires 5
Automobiles 3
Roofing, tile, and wall board 1
These excise taxes could be reduced to lower the product's selling price if the
manufacturer indicated that materials reclaimed from solid waste were used in his goods.
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Problems associated with such a tax would be similar to those described above for an
excise tax on new material. In order to achieve a substantial benefit, in addition raising the
revenues, a substitute should be available to replace the short-lived and/or problem
commodity. Additionally, recent court decisions tend to discourage attempts to impose
such taxes.
Income Taxes. Alteration of the income tax laws to effect a reduction in solid waste
generation and an increase in reuse may also be possible. Because of the complex nature of
the tax structure, the use of income taxes to change marketplace activity would be a
complicated and multifaceted problem. Examples of changes and associated problems are
discussed below.
Tax Credits. Those businesses that install processing equipment used in the reclamation of
solid waste materials could reduce their tax burden if an income tax credit were allowed for
such investments. Tax credits (also called investment credits;) allowed in the past for new
equipment installation have encouraged industries to expand and modernize their
operations. According to a secondary materials industry spokesman, previous tax credits
were not in effect long enough to influence widespread expansion in the secondary materials
industry. Generally secondary material processors are relatively small and have only one
processing facility; consequently, they require a longer period of time to accumulate enough
capital to expand and/or modernize. Conversely, companies processing virgin materials are
often larger and may have additional capital available for large capital investments during a
limited period when investment credits are available.
An investment tax credit specific to or favoring installation of the secondary material
processing equipment and/or facilities would be a positive move toward solid waste
recovery. Alternatively, the tax law could be amended to allow accelerated depreciation of
equipment used in resource recovery efforts. Although accelerated depreciation or tax
credits may encourage more rapid discarding of equipment, the net effect of an investment
tax credit or accelerated depreciation schedule is expected to benefit expansion of the
secondary materials industry and produce positive effects on recycling and reclamation
efforts.
Other Incentives to Recycle. If the goals of resource recovery are deemed to be of
sufficiently high priority, a tax holiday could be granted to those businesses engaged in solid
waste reclamation efforts. A provision to equalize the effects of the depletion allowance
afforded to virgin material producers could also prove helpful. This may be achieved by
allowing corresponding deductions to waste material processors or by reducing and/or
eliminating existing depletion allowances. As another possible tax incentive, extended loss
carryovers applicable to those who reclaim and use materials from solid wastes could be
instituted.
A graduated income tax reduction could be allowed producers who use varying amounts
of secondary material as raw material input to encourage usage of materials recovered and
thereby provide a market for reclaimed wastes. This mechanism could be administered
through the income tax structure and be similar to an excise tax on virgin material
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consumption, except a rebate would be given for secondary material usage. However,
administration and planning of such a system could be difficult.
The purpose of all these tax incentives is to improve the profitability of the recycling
industry and thereby encourage such activity by private enterprise. However, the adoption
of such incentives would not necessarily guarantee the achievement of the desired goals.
There is the possibility that the costs involved in effectively recovering a significant portion
of municipal solid waste are so excessive that even a tax incentive that essentially reduces
the cost of equipment to zero would not cause the operation to be profitable. More detailed
analyses must be undertaken to determine whether any given tax incentive would actually
accomplish increased resource recovery. Impacts of tax policy changes on international
trade balances and other indirect effects must also be considered.
As previously stated, consideration of these tax incentives to encourage solid waste
recovery is only at the prelimimary stages. There has been some action on related proposals,
however, which will be covered in the following section.
Recent and Pending Action
Tax Reform Act of 1969. Three provisions of this most recent amendment to the Internal
Revenue Code relate to solid waste generation and recovery.
Industrial Development Bonds. Under the tax statutes, state and local bonds may not be
granted tax-exempt status if a major portion of the bond proceeds will be used by a taxable
business and/or if repayment of the bonds is secured by payments derived from property
used by a taxable business. An exception has been allowed, however, if the bond proceeds
are to be used in sewage, air and water pollution, or solid waste disposal facilities. On April
3, 1972, the Internal Revenue Service issued rules that extend this exception to bonds used
to finance resource recovery. Thus, an indirect subsidy in the form of lower financing costs
is available to persons engaged in waste disposal and resource recovery operations.
Pollution Control Facilities. In order to encourage abatement of pollution, the Tax
Reform Act allows a taxpayer to amortize pollution control equipment over a 60-month
period rather than the normal 16 years. This accelerated depreciation is applicable only to
facilities installed in an existing plant after January 1, 1969, and placed in service before
1975. Only facilities that control air and water pollution are covered by this provision. Sales
of material reclaimed as a result of pollution control processing reduce the basis that can be
rapidly deducted. This limitation is included to ensure that the accelerated depreciation
incentive causes pollution control facilities to be constructed that would not otherwise be
profitable or economically feasible. Thus, not only are solid waste recovery operations
excluded from this favorable tax treatment, but recovery of salable solids from air and water
pollution control facilities has been discouraged.
Building Rehabilitation. Capital expenditures for existing buildings can be written off
over a 5-year period under the Tax Reform Act. The original purpose of this tax incentive
was to encourage the rehabilitation of slum-type structures and thereby improve housing
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quality. As a side effect, this incentive also tends to lengthen the useful life of buildings and
in this manner reduces, or at least defers, the quantity of demolition waste generated.
H. R. 9906. Introduced in the House of Representatives on July 20, 1971, H.R. 9906
proposes to amend the Internal Revenue Code such that recycled materials are included in
the list of materials for which percentage depletion is allowed. Specifically, this bill would
provide for a 14 percent depletion allowance for reclaimed materials including recycled
minerals, paper, lumber, glass, plastic, and oil, except if a higher rate is provided for the
same mineral when produced from natural deposits. This bill presently awaits action in
committee.
Such a "depletion allowance" for recycled materials would be difficult to administer
since depletion allowance is based on natural resource depletion. There is no known
comparable basis on which to calculate a similar deduction for secondary materials. Office
of Tax Analysis personnel feel that more investigation and research will be required to
ascertain effects of recycling incentives before any Code change can be effected.
H.R. 9906 and other proposed legislation with similar intent serve to bring the issues to
public light and are helpful in this respect.
Recommendations
Tax treatment that favors virgin resource development should be amended.
In response to the recognized need to conserve limited natural resources and to
recover the resource value presently wasted, the Internal Revenue Code should be
altered to encourage the utilization of recovered resources. The stimulative effects of
depletion allowances and special capital gains treatmem: that are preferential towards
natural resource development are discriminatory toward reclaimed material.
Corresponding tax advantages should be provided to encourage secondary material
recovery, processing, and use, if the advantages afforded virgin resource development
are continued in effect.
An in-depth study should be undertaken under the joint sponsorship of EPA and the
Office of Tax Analysis to determine what additional tax incentives or disincentives
would be most beneficial in encouraging resource recovery.
Accelerated depreciation should be available to those who install facilities intended
to reclaim resources from solid wastes.
Presently, only air and water pollution control facilities qualify for favorable
depreciation treatment under the provisions of the Tax Reform Act of 1969. This
amendment to the Internal Revenue Code fails to consider solid waste generation as
a serious pollution and resource depletion problem. The Act's coverage should be
extended.
Furthermore, the Tax Reform Act presently stipulates that the portion of the
cost of a pollution control facility offset by the sale c>f materials recovered from its
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operation cannot be subject to accelerated amortization. However, to provide the
most effective incentive to recover low value solid wastes that would not otherwise
be reclaimed, gross sales of such materials should not reduce the basis upon which
rapid depreciation is calculated, but profits should reduce the basis.
It is beyond the scope of this study to determine what specific new tax measures should
be adopted. The tax law and its possible effects on resources recovery goals is an extremely
complex issue, requiring an extensive investigation. Both direct and indirect effects of new
tax provisions must be considered. An in-depth analysis of such factors as recycling
technology, secondary material marketing, and economic impact on existing industry, and
the balance of payments problem is required before definite income and excise tax
incentives are formulated so that the desired resource recovery goals are attained without
adverse side effects. EPA and the Office of Tax Analysis personnel are knowledgeable in the
specific areas necessary and should jointly support and lead such an investigation.
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CHAPTER III
FEDERAL HIGHWAY ADMINISTRATION
DEPARTMENT OF TRANSPORTATION
Abstract
The Department of Transportation (DOT) has responsibility for the development of
national transportation policies and programs to provide fast, safe, efficient and convenient
transportation at the lowest possible cost. The Federal Highway Administration (FHWA)
has responsibility for carrying out the highway transportation program of DOT.16 Large
quantities of solid wastes are generated during highway construction work. The potential
magnitude of this impact may be best illustrated by the fiscal year 1970 expenditures for
Federal and Federal-aid interstate, and secondary highway construction of about $11.2
billion.17 Over 50 percent was Federal funds with the balance provided by the States.18
The FHWA has conducted research into use of processed solid waste material for highway
construction.
Background
Federal aid has been provided for highway construction since 1917. However, the
establishment of FHWA in 1966 marked a broadening of the Federal interest in total
highway transportation. Federal and Federal-aid highway construction, highway safety, and
motor carrier safety are the major program elements of FHWA. Other activities seek to
coordinate modes of transportation so that an effective balance of transportation systems
and facilities can be achieved.19
The Federal-aid highway program includes construction of the 42,500 mile National
System of Interstate and Defense Highways and improvement of 872,000 miles or primary
and secondary roads and their urban extensions.20 On the former, Federal aid normally
provides 90 percent or less of the total funds, and generally less than 50 percent on the
latter. FHWA administers the highway beautification program and is responsible for
construction of Federal highways.
The FHWA coordinates a wide-ranging research and development program involved with
such topics as traffic congestion, street and highway safety, effective design, materials usage,
highway costs, and social, economic, and environmental impact of highway transportation.
Aspects of the research activities related to solid waste usage were studied as a part of this
project.
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The FHWA develops and administers programs in cooperation with States to identify
causes of motor vehicle-related accidents on streets and highways. It develops and
administers safety standards relating to highway design, construction and maintenance,
traffic control, and pedestrian safety. The FHWA has jurisdiction over the safety
performance of commercial motor carriers engaged in interstate and/or foreign commerce,
and the movement of explosives, flammables.and other dangerous cargoes over highways.
The relationship of these activities to solid waste generation and recycling were judged to be
nominal, and were therefore not studied further.
Organization. The overall organizational structure of FHWA provides for three levels of
responsibility: Washington headquarters, regional, and divisional offices. There are nine
regions; each has a regional office and several division offices. There is one division office in
each State, the District of Columbia, and Puerto Rico. The headquarters office has been
organized by function: Right-of-way and environment, engineering and traffic operations,
research and development, motor carriers and highway safety, planning, and administration.
The first three functional departments were of primary interest to this study effort.
Environmental Impact Statements
In accordance with the National Environmental Policy Act of 1969 (NEPA), the FHWA
requires each state highway department to evaluate the environmental consequences of all
highway construction projects, research and demonstration projects, and other major
actions supported by FHWA. Those actions not having a significant impact on the
environment require a declaration to that effect. Action likely to be highly controversial on
environmental grounds was considered by FHWA to be significant and thus required
preparation of an environmental impact statement in its NEPA guidelines.21 Twelve effects
of highway construction projects likely to be significant are set forth by FHWA. Other
significant effects are referred to elsewhere in FHWA publications. Solid waste generation
was not one of the effects identified.
Personnel in the FHWA's Office of Environmental Policy estimated that, of about 9,000
projects for which there is Federal involvement each year, 10 to 20 percent are of sufficient
magnitude to require preparation of a detailed environmental statement. FHWA's interim
guidelines for preparation of these statements specify that the contents should include the
following:22-23
Description of the proposed project, its purpose, and a location map.
Discussion of the probable impact of the proposed project on the environment, both
negative and positive.
Discussion of probable adverse environmental effects that cannot be avoided. Also,
alternatives to the proposed project should be described along with their probable
adverse environmental effects.
Discussion of the relationship between local short-term uses of the environment and
the maintenance and enhancement of long-term productivity.
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Description of the irreversible and irretrievable commitments of resources required
for the project.
Coverage of objections raised by other Federal agencies, State and local
governmental parties and private citizens including the disposition of these issues.
Steps to be taken to minimize adverse environmental affects that cannot be avoided.
After the draft of the statement has been prepared by the state highway department,
copies are distributed to the three levels of FHWA, the Council on Environmental Quality,
other Federal, State, and local governmental agencies, and interested citizens. Wide
circulation is given these documents. Public hearings are held to discuss the more
controversial projects.
Five draft environmental impact statements were reviewed as a part of this study. The
statements had been prepared for the following projects:
Replacement of an existing bridge24
Construction of 20 miles of interstate highway25
Construction of 30 miles of interstate highway26
Construction of 24 miles of interstate highway27
Construction of the Chicago Crosstown Expressway28
Each statement differed in approach, items considered, and detail. It was noteworthy,
however, that possible environmental effects of solid waste generation expected during
demolition and clearing were not covered in any of the statements. Obviously, large
quantities of solid wastes are generated during the demolition of buildings and clearing of
trees from the planned roadways. These wastes will likely cause some degree of
environmental impact. Solid waste generation was not considered in the statements, because
it was not one of the criteria listed in FHWA's guidelines. Several FHWA officials stated that
consideration is generally not given to solid waste in any environmental statements.
Included within Reference 27 was a letter from an EPA regional office with comments on
the impact statement and the proposed project. The letter commented on effects of the
project on water quality in a nearby lake, but not of solid wastes.
Plans and Specifications
The primary mission of the FHWA is to develop transportation policies and programs for
the lowest cost consistent with the highest standards for providing safe, fast, efficient, and
convenient transportation. Emphasis is placed on effective design, and consideration is given
to social, economic, and environmental factors related to highway systems. A philosophy
expressed by FHWA officials interviewed during the study was that, by allowing the
contractor to decide the use and/or disposal of materials on the job, lower construction
costs would be obtained and the mission of FHWA would be realized. Consequently, plans
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and specifications are often prepared to reduce construction costs without regard for total
resource utilization, indirect impact on the environment, or costs to local solid waste
disposal authorities.
Federal Specifications. The basic specifications used by FHWA, Standard Specifications
for Construction of Roads and Bridges on Federal Highway Projects, (FP-69), has been
patterned after the American Association of State Highway Officials (AASHO) Guide
Specifications for Highway Construction, to establish nationwide uniformity and a
consistency in specifications for highway construction.29 The specification covers items of
work, materials, and construction methods generally applicable to direct Federal highway
contracts, but are adaptable for use by other highway agencies as well. They are designed to
be sufficiently general to prevent early obsolescence and subsequent controversy in the
administration of contracts.
On Federal highway construction projects under the direct supervision of FHWA, FP-69
is normally specifically referred to and thereby made a part of the contract documents. For
each specific project, job specifications are prepared to amplify, clarify, and modify FP-69
to comply with job conditions. On Federal highway construction not under the jurisdiction
of FHWA, FP-69 may or may not be included by reference in each construction contract. If
not included by reference, FP-69 may be the basis for that agency's specification. More
importantly, the indirect impact of FP-69 provisions can be substantial since they and the
AASHO Guide Specification provide guidelines and formats for use by many highway
agencies in preparing standard specifications and job specifications.
On the other hand, the direct impact of the Federal specifications, and possible
alterations thereof, on solid waste generation and recycling may not be great. Table 3
indicates that only $258 million was expended in fiscal year 1970 for construction of
Federal highways, compared with a total of $11.2 billion expended during the period for all
interstate primary and secondary highway construction.30 Of these Federal highway
construction funds, only 25 percent were under FHWA jurisdiction. However, the Federal
specifications can have an effect on the $10.9 billion expended by States (including the
Federal share) and on additional expenditures for other highway construction financed
solely by States, local government agencies, private developers, and foreign governments.
Because of the potential impact of FP-69 provisions, and revisions thereto, on solid waste
generation and reuse on highway construction, the Federal specifications were studied in
detail. Also studied were specific job specifications and contract documents for several
Federal highway projects. Following are descriptions of provisions within FP-69 and from
an example Proposal and Contract (the Washington Forest Highway Project in Oregon31 )
that relate to solid waste generation, disposal, and potential reuse. The numbers following
each subject refer to the section number in FP-69.
Clearing and Grubbing (201). This work consists of removing and disposing of all
vegetation and debris within the projected roadway path except those objects designated in
the plans to remain.32 The quantity of waste material removed depends upon the terrain
and the existing vegetative growth. Data indicating the total quantities of materials cleared
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TABLE 3
ESTIMATED FISCAL YEAR 1970 CAPITAL EXPENDITURES
FOR HIGHWAY CONSTRUCTION17
(Dollar amounts in millions)
Highway system
Interstate
Rural
Federal aid
Non-Federal aid
Urban
Federal aid
Non-Federal aid
Total Federal aid
Total interstate
Primary
Rural
Federal aid
Non-Federal aid
Urban
Federal aid
Non-Federal aid
Total Federal aid
Total primary
Secondary
Rural
Federal aid
100% Federal
Non-Federal aid
Urban
Federal aid
Non-Federal aid
Total Federal aid
Total secondary
Total Federal aid
Grand Total
Right-of-way
acquisition
181
295
10
476
486
103
177
112
185
215
577
50
83
-
38
50
171
741
1,234
Engin-
eering
214
2
164
10
378
390
106
196
54
96
160
452
62
10
77
33
72
182
610
1,024
Construc-
tion
1,642
35
1,250
145
2,892
3,072
704
1,579
409
1,203
1,113
3,895
475
248
869
377
723
1,969
4,728
8,936
Total
2,037
37
1,709
165
3,746
3,948
913
1,952
575
1,484
1,488
4,924
587
258
1,029
448
845
2,322
6,079
11,194
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and grubbed per year was not available from FHWA. Similarly, data indicating quantities of
solid waste generated, reused, and disposed of from other highway construction tasks were
not compiled.
Burning was the most commonly used method of disposing of combustible solid waste
from clearing and grubbing. FP-69 requires that burning be completed in accordance with
applicable local ordinances and State law. As prohibitions against open burning become
more prevalent, disposal of cleared materials will become more costly and larger quantities
of waste material will be generated. It may become necessary to specify the method of
residual disposal.
Noncombustible and perishable materials are to be removed and disposed of at off-site
locations,33 but FP-69 did contain a specific provision that its disposal comply with local
ordinance and State law. In the Special Provisions of Reference 31 it was specified that
noncombustible debris and silt-laden materials were to be placed in areas where high water
or heavy rain would not wash them into streams.
FP-69 provides that all timber in the right-of-way at the beginning of construction
becomes the property of the contractor unless otherwise provided.34 The contractor may
either sell the timber or dispose of it as waste material. Increased utilization of the timber
would probably result if a provision was added to FP-69 requiring that merchantable
portions of either felled or downed timber in the highway right-of-way be sawed into
standard lengths and used in the course of construction, sold, and/or stockpiled in a
designated area.
On the Washington Forest Highway Project the contractor was required to salvage any
merchantable standing or downed timber within the area to be cleared.35 In conjunction
with FHWA, the Forest Service has sometimes negotiated timber sales to remove salable
timber from the area to be cleared prior to start of construction. Also timber sales are
conducted by FHWA when the estimated costs of cruising and staking the limits of timber
removal do not exceed the estimated timber market value.
Removal of Structures and Obstructions (202). This work consists of the removal of
buildings, fences, structures, pavements, pipelines, and other obstructions from the area to
be cleared. It may include salvage of certain materials.36 Salvable materials may include
steel and wood bridges, concrete suitable for riprap, pipe, ballast, gravel, and other surfacing
materials. The materials can often be used on the job. However, addition of provisions to
FP-69 to more clearly define suitable uses, necessary processing, handling, and storage could
increase its utilization. Asphalt may be reused in the roadway base or buried within the
embankment, and concrete may be sized and used for fill material or stockpiled for future
use. If the materials cannot be used on the job, the contractor is normally required to
arrange for disposal as with nonsalvable materials. The government representative (hereafter
referred to as the engineer) has broad authority in directing the contractor to use or
stockpile materials for future use, or to discard the material as waste. He can also specify the
method of disposal.
Excavation and Embankment (203). Excavation includes removal and disposal of soil and
organic materials not suitable for use as foundation material.37 The engineer designates the
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soils to be excavated and directs the method for disposal.38 The waste materials are often
placed adjacent to the roadway within the right-of-way and blended into the terrain to the
extent possible.
On the Washington Forest Highway Project, FP-69 was modified to allow undisturbed
stumps and roots and nonperishable objects to be left in place if they did not interfere with
roadway construction. This special provision reduced solid waste disposal problems and
costs. Another provision in FP-69 allows the construction of a roadway over sod and other
similar vegetative matter if the roadway embankment is more than 4 ft high.39
Whenever a compacted road surface containing granular materials such as gravel, asphalt,
or concrete, lies within 3 ft of the new subgrade, this surfacing must be scarified and
recompacted. Thus, the old surfacing becomes a part of the new embankment.40
FP-69 provisions relating to embankment construction are standard for the roadway
construction industry. The use of broken concrete and other demolition debris are not
specifically mentioned. The provisions can be interpreted to allow placement of such
material within the embankment.41
Obliteration of Old Roadways (209). When roadways are no longer needed for traffic,
they are removed and the terrain restored to the original contour or to produce a pleasing
appearance. Structures such as bridges and buildings must be demolished and removed.
When included on the plans or directed by the engineer, materials for the new roadway can
be supplied from the old roadway. Similarly, materials not suitable for the new roadway
may be used in restoring the terrain of the old roadway.42 Thus, there would be little or no
solid waste from the old roadway except organic material that would be disposed of in
accordance with clearing and grubbing requirements.
Roadside Cleanup (210). Upon completion of roadway construction, the contractor is
required to clean the area lying within the right-of-way line. Cleaning includes clearing
downed timber, dead brush, logs, debris, and the burning or otherwise disposing of the
material as ordered by the engineer.43 Salvage, reuse, and disposal provisions are similar to
those for clearing and grubbing.
Temporary Erosion and Water Pollution Control (213). Soil erosion and possible water
pollution are controlled during the construction phase. Control procedures include
placement of mulches, such as hay, straw, fiber mats, netting, wood cellulose, bark, corn
cobs, wood chips, or other suitable material acceptable to the engineer.44 Conceivably trees,
slash, and brush removed from the right-of-way could be chipped for use in erosion control,
utilizing materials that would otherwise require disposal. However, Section 713.05 of FP-69
could be interpreted to disallow use of such wood chips, and require that a commercial
grade of wood chips be used.
On the Washington Forest Highway Project, a preconstruction conference was held, as is
usual for FHWA projects. At this time, the contractor was required to submit a schedule and
plan for temporary and permanent erosion control work.45 From the standpoint of solid
waste utilization and disposal, the preconstruction conferences offer an excellent
opportunity for the contractor to present and discuss his plans for use of on-site materials
and for disposal of solid waste materials.
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Portland Cement Treated Base (308) In the traveling plant method of highway
construction, aggregate for the base can be obtained by scarifying the existing roadway or
from other sources. The aggregate is placed and the specified quantity of portland cement
applied and mixed. Water is applied during mixing and the material is then spread and
compacted.46 This section of the specification is applicable for both upgrading an existing
roadway or for constructing a new roadway. Furthermore, it provides a use for used
asphaltic concrete, thus providing a secondary use for this material that would otherwise be
disposed as solid waste.
Loose Riprap (619). Stone riprap is used for stream bank protection. No reference was
made in the specification to use of broken concrete for riprap*.47 Discussions with FHWA
personnel indicated, however, that concrete has often been used for riprap.
Mulch (713.05). Mulch may include wood chips, straw, hay, wood fiber, sawdust, peat
moss, and peat humus. The specification generally precludes use of secondary materials. For
example, wood chips must be obtained from disease-free green hardwood and meet specific
dimensional requirements. All wood chip mulch must also be free of leaves, twigs, shavings,
bark, or other materials injurious to plant growth. To comply with these requirements it
would be necessary to have commercial wood chips supplied. The high production chippers
currently being demonstrated produce chips larger than specified.
A second example is sawdust. It can be used, but must be at least 5 years old. This
requirement generally precludes use of sawdust not sold commercially.
General Provisions. Included in the proposal and contract documents for Federal highway
projects and for most Federal construction of all types are General Provisions prepared by
the General Services Administration, based on the Federal Procurement Regulations (41
CFR) 1-16.401. Section 9 of the General Provisions requires that "unless otherwise
specifically provided in this contract, all equipment, material, and articles incorporated in
the work covered by this contract are to be new and of the' most suitable grade for the
purpose intended."48 Obviously this requirement discourages the use of secondary
materials.
State Highway Departments. State highway agencies control the design, construction, and
maintenance of highway systems in their respective states. Many states prepare their own
standard specifications, which are normally patterned after the AASHO Guide
Specifications for Highway Construction, but modified to comply with local conditions
and practices. FHWA requirements are also considered, since 3. major portion of the funds
used for highway construction are provided by the Federal government. Design criteria for
Federal aid interstate, primary and secondary highways are also generally patterned after the
AASHO guidelines.
The plans and specifications prepared by State highway departments for each project
receiving Federal aid are approved by the responsible FHWA district office. It appears that
FHWA does not strictly regulate State practices concerning design work or specifications.
FHWA headquarters personnel believe that more economical construction results if the
State personnel are allowed a relatively freehand in design and specification preparation, as
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long as the State generally complied with FHWA and AASHO specifications. There are
certain exceptions to this generalization; e.g., environmental impact statements are required.
As the approving agency, FHWA can influence the reuse of materials currently disposed as
wastes by the States during highway construction. Secondary materials are now used in
some construction, but not to the extent possible, even though they may be classified as
standard items in some specifications.
Construction
Highway construction can be defined as a moving manufacturing plant with a stationary
product while most other manufacturing consists of stationary plants to which raw material
is shipped and from which finished goods are transported. A significant portion of highway
construction costs are associated with transporting materials to the construction site. The
haul distance may range from a few hundred feet for earth materials onsite to several miles
for concrete, bituminous, and other road construction materials, and hundreds of miles for
fabricated steel. Transportation costs are also incurred in removing solid waste materials
from the site.
Major Solid Waste Problems. Major solid waste problems on highway construction in the
order of importance are removal and disposal of unstable material, slash, and tree stumps
and roots.
Unstable Material. Unstable material, such as muck or peat, must be excavated and
removed from the job site. The material may be excavated, stockpiled and placed on the
sides of the embankment, outside the structural prism. Where this practice is not possible,
the material must be hauled away and disposed of off-site.
Slash and Timber. In most rural areas, slash and unmarketed timber (vegetative material)
are burned for disposal. This practice is unlawful in many urban areas, and there is an
increasing tendency to prohibit burning in rural areas as well. FHWA personnel indicate that
all open burning in rural areas may cease within 5 years. When this occurs, more cleared
timber will probably be marketed and disposal of slash will become an even greater solid
waste problem. Under such conditions, utilization of unmarketable timber and slash would
be more attractive.
In some locales, disposal methods other than open burning are practiced. Pit burning is
one such method. It provides more complete incineration, and air pollution is reduced,
compared with open burning. However, the cost for this method is much higher than for
open burning because a pit must be constructed, debris must be pushed into the pit, and
supervision is needed.
Where restrictions prohibiting burning exist, slash and timber have been buried adjacent
to fill slopes within the road right-of-way. In effect, this is a landfill operation. The Federal
specifications allow the contractor to dispose of waste materials on adjoining property with
written permission of the property owner. Large chippers that can process logs up to 12 in.
and 24 in. in diameter are being developed and demonstrated with considerable success.
Chips from these machines help provide slope stability, since they are largely unaffected by
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winds and storm runoff. Problems associated with use of wood chips on the highway
construction site include pest harborage, fire hazards, and acid runoff.
Tree Stumps and Roots. This problem is similar to that described for slash. In many cases
the tree stumps can be cut off at the ground surface. Left in place, some additional slope
stability can be achieved by the roots and the waste disposal problem can be reduced.
Demolition Debris and Clearing and Grubbing. FHWA personnel indicated that a major
problem in incorporating solid waste materials in highway construction was the lack of
quantity. Highway construction often requires embankments requiring large volumes of fill.
The relatively small quantities of inert demolition debris suitable for use in embankments
were not considered significant. From strictly a highway construction standpoint, the cost
to haul demolition debris for an embankment may exceed the cost to use locally available or
imported earth. In many urban areas the cost to place demolition debris into highway
embankments would be less than to dispose of the material via landfill.
The District of Columbia Redevelopment Land Agency has discussed with FHWA the
possibility of using demolition debris from urban renewal projects for highway construction.
FHWA indicated that such a plan would be acceptable on an experimental basis. This plan
could substantially reduce the cost of demolition debris disposal from the renewal project.
It could even reduce highway construction costs if the debris reduced the quantity of
material imported for embankments. The District of Columbia also discussed with DOT the
feasibility of reclaiming aggregate from asphaltic concrete. The concept has excellent
potential, especially in locations where there is a shortage of good aggregate for use in
asphaltic concrete construction. Neither project was initiated, however, for indeterminable
reasons.
DOT and HUD are required by law to consult and exchange information regarding their
respective transportation policies and activities and to carry on joint planning, research, and
other activities. Authority for cooperating in mutually beneficial activities such as debris
disposal now exists.49
Demolition debris from urban renewal projects sponsored by HUD was estimated to be
more than 3 million tons annually (See Chapter IX). Assuming one-quarter of the debris can
be economically reclaimed, and one-half requires landfill and/or incinerator disposal because
it is organic material or is a mix of organic and inert material, nearly 1 million tons of solid
waste would be available for disposal within highway construction projects. This estimated
quantity is about equivalent to the annual solid waste generation of a city of 1 million, or
about 0.5 percent of the Nation's municipal solid waste generation.
The quantity of demolition debris from clearing of structures from urban highways was
not documented. However, based on Table 4, expenditures for interstate, primary, and
secondary highway right-of-way acquisition and construction, the quantity is significant.
Although the extent of current demolition debris utilization was not documented, it is
anticipated that a larger percentage could be used in roadway construction if advanced plans
were formulated for its utilization and disposal, especially if this planning function were
done on a regional basis rather than a job-by-job basis.
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TABLE 4
CAPITAL EXPENDITURES FOR HIGHWAY CONSTRUCTION*
(Dollar amounts in millions)
Fiscal year
1968
1969
1970
1971
Rural
highways
6,347
6,197
6,813
7,380
Urban
highways
3,991
4,118
4,381
4,831
Total
10,388
10,315
11,194
12,211
* From U.S. Department of Transportation, Federal Highway Administration.
Unpublished data, April 12, 1972.
Research and Development
The FHWA has been interested in results of research into reuse possibilities of industrial
and domestic waste materials, particularly those relating to highways. Following is a
summary of several secondary materials that show promise for use in highway
construction.50
Fly Ash. Fly ash is a finely divided mineral product produced by the burning of
pulverized coal. It is high in silicate, aluminum, and iron. Fly ash is classified as a pozzolan
since it has the property of combining with lime in the presence of moisture to form a
cementing material. For this reason, it is useful in construction.
A considerable amount of research has been performed on fly ash. Specifications for Fly
Ash and Raw or Calcined Natural Pozzolans for Use in Portland Cement Concrete, ASTM C
618, describes the quality of fly ash added to concrete mixes. Alternatively, fly ash can be
added to cements as described in Specifications for Blended Hydraulic Cements, ASTM C
595.
Fly ash has been used as a partial replacement for cement in concrete dams. This
application was justified on the basis of cost savings, reduced heat liberation, and control of
adverse chemical reactions with certain aggregates. With as much as 35 percent of the
cement replaced by fly ash, the ultimate strength of the concrete will generally be greater
than that of concrete without fly ash. However, concrete made with fly ash is slow to cure
and does not attain early strength needed for some applications. Many highway engineers
are reluctant to compound the problem of controlling the quality of concrete on the job by
adding fly ash as an additional ingredient, since fly ash can vary in quality from lot to lot.
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Fly ash has been used for stabilization of roadway bases. A strength increase and better
resistance to freeze-thaw and wet-dry cycling results. Fly ash use on state highway work has
been limited because of its increased cost over that for standard base course construction.
Fly ash is also acceptable for use as the finely divided material in asphaltic paving
mixtures as evidenced by Specifications for Mineral Filter for Bituminous Paving Mixtures,
ASTM D 242. Its use for this purpose has occurred in areas located near metropolitan
centers where fly ash was produced.
Blast Furnace Slag. Blast furnace slag is the nonmetallic product developed
simultaneously with iron in a blast furnace. It has been used extensively in highway
construction and is acceptable as aggregate for concrete under Specifications for Concrete
Aggregate, ASTM C 33, and for bituminous mixtures under Specifications for Coarse
Aggregate for Bituminous Paving Mixtures, ASTM D 692.
All available supplies of blast furnace slag are generally consumed in a useful manner.
Other types of slag, such as those from the open hearth process or from the production of
nonferrous metals, have not been as acceptable because of chemical instability.
Glass. Crushed glass has been used as aggregate in bituminous paving mixtures on an
experimental scale. Test strips have been placed at five locations in the United States and at
two locations in Canada. Experience on the test installations indicates that it is possible to
use glass as a replacement for major portions of the aggregate in bituminous mixtures and
still obtain satisfactory levels of stability, density, and resistance to water. Further
evaluation is needed to determine such factors as long-term durability, resistance to severe
traffic conditions, skid resistance, and effects on tire wear.
Rubber. Waste rubber has been used in conjunction with asphalt for several highway
applications. Attempts have been made to improve the performance of asphalt paving by the
addition of rubber, the ultimate objective being to enhance the elasticity of asphaltic
concrete over a wide range of temperatures. The rubber is introduced into the asphalt or the
asphaltic concrete mixture in the form of small particles and is then mixed with the
application of heat.
In one application, rubber tires were devulcanized in order for the rubber to regain
plasticity, and added in powdered form to asphaltic mixtures. About 200 miles of this type
of pavement are reportedly in existence.
Rubberized asphalt has been considered for use as a strain-relieving inner layer to prevent
reflection cracking in asphaltic concrete surfaces. An experimental project of this type was
installed by the city of College Station, Texas. A mixture of rubber aggregate, soil or sand,
and asphalt was placed in a layer of V4 in. thickness or less between the roadway base surface
and foundation course.
Another application of rubberized asphalt is for joint sealant. The joint sealant must be
flexible to accommodate movements of adjoining pavement slabs and still adhere to slab
materials. Federal specifications for rubberized asphalt joint sealants reportedly exist.
One tire-manufacturing company has been conducting tests of discarded tires for use as
safety barriers.51
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Coal Refuse. A laboratory study of the properties of carbonated bonded coal refuse
found potential for utilization of the material in road building.52 Using up to 12 percent
lime hydrate and 9 to 15 percent water, high compressive strengths were obtained. The
study recommended additional work to demonstrate the carbonate bonding process on a
larger scale prior to use for road construction.
Wood Chips from Mulching. As discussed previously, trees and other slash cleared from
highway right of ways can be processed into chips and applied as mulch during seeding
operations. Wood debris from demolition can be used in a like manner.
Wood and Paper for Seeding Operations. A current practice for seeding highway
right-of-way areas consists of applying a mixture of wood fibers, seed, fertilizer, and water
by spraying. Although longer wood fibers are superior for this purpose than the shorter
paper fibers, waste paper could be used, particularly on level areas.
Mine Tailings. Tailings resulting from mining operations can be used either as fill material
or as a base coarse for highways. In some cases the material first must be stabilized.
Metal Cans. Metal cans, particularly 55 gal. drums, can act as energy absorbers and
therefore are useful for impact attenuation near highway structures. Painted drums are
commonly used in some areas as temporary directional barriers on highway reconstruction
projects.
Sulfuric Acid Wastes. FHWA officials consider lime-treated sulfuric acid wastes as a
potential source of binder or aggregate material in highway construction work. When treated
with lime, sulfuric acid forms calcium sulfate. Further treatment with fly ash produces a
strong, stable compound.
Recommendations
Environmental impact statements should include estimates of the quantities of solid
wastes generated as a result of highway construction activities, indications of the
intended disposal or reutilization methods, and an evaluation of potential
environmental effects.
By identifying the materials to be generated from the highway construction
project, it is more likely that a use will be found for these materials. It appears that
data needed to estimate the quantity of solid waste to be generated is available.
Additional effort will be needed to assess possibilities for reuse and to estimate
possible environmental effects of alternative uses or disposal methods.
The Standard Specifications for Construction of Roads and Bridges on Federal
Highway Projects, FP-69, should be modified to encourage material reuse and to
require acceptable methods of solid waste disposal. Effort should be extended by
FHWA to encourage AASHO to similarly modify its Guide Specifications for
Highway Construction.
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Section 9a of Standard Form 23-A should be revised to allow use of secondary
materials suitable for the purpose intended.
Currently, this general provision, included in most civil construction contracts of
the Federal government, specifies the use of only new materials.
Specifications and general provisions of the State highway departments should be
reviewed to identify and eliminate provisions restricting materials used in highway
construction to new materials. Additionally, effort should be extended by the
FHWA to encourage State highway departments to modify their standard and/or job
specifications as discussed above for FP-69.
The FHWA should attempt, through coordination with HUD and State highway
departments to utilize inert demolition wastes as embankment material for urban
highways.
Significant coordination efforts would be required to implement this policy, but
it can serve two purposes: Reduce the cost for disposal of inert demolition wastes
from urban renewal or other sources and minimize the environmental impact of
disposal of large quantities of wastes.
Within plans or special provisions on Federal highway construction contracts, the
following information should be included:
An estimate of the quantity of solid waste material expected from clearing and
grubbing operations and removal of structures. (In most cases these estimates are
already at least partially made). By identifying the types and quantities of
materials to be removed, the contractor will be more likely to utilize these
materials in his construction.
Potential disposal sites for unusable material, and, where practical or necessary,
disposal methods. (If the contractor can use solid wastes generated through
highway construction activity, he should be allowed to deviate from the approved
disposal plan, with the approval of the engineer).
Additional funds should be allocated for research and demonstration of the use of
secondary materials for highway construction.
Emphasis should be on demonstrating materials that appear to be adaptable for
early full-scale use by State highway departments. Several full-scale demonstrations
are needed for each material application along with an effective evaluation of the
materials for nationwide or regional applications. State highway departments should
be encouraged to incorporate into their specifications provisions calling for the
utilization of proven secondary materials. Research on promising materials and
methods is needed, but, owing to the time required for research, demonstration,
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dissemination of results, and adoption by State highway departments, 5 years or
more is probably required for new material application to have a significant effect
on the solid waste problem.
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CHAPTER IV
FEDERAL TRADE COMMISSION
Abstract
The Federal Trade Commission (FTC) administers various laws that prohibit the use of
unfair methods of competition in commerce and unfair or deceptive acts or practices in the
market place. Most constituents of solid waste begin as a consumer product and are
discarded after use. Possibilities exist whereby the generation of solid wastes can be reduced
through control of consumer product constituents. Because FTC has existing authority in
areas related to consumer goods, this agency has the potential to indirectly influence solid
waste generation. Other possible FTC influences on solid waste recovery are also discussed.
Background
The FTC was organized in 1915 pursuant to the Federal Trade Commission Act of 1914,
to replace the Bureau of Corporations. It was given powers to investigate the conduct,
practices, and management of any enterprise engaged in commerce in the United States.
Also, certain responsibilities regarding antitrust suits were delegated to FTC under the
original Act.
During the 57 years of its existence, additional responsibilities have been assigned to FTC
through further legislative action. These are listed below, along with a brief description of
each.
Clayton Actprohibits discrimination in price, exclusive dealings and tying
arrangements, and corporate mergers when such practices or arrangements may
substantially lessen competition or tend toward monopoly; interlocking directorates
under certain circumstances; the payment or receipt of illegal brokerage; and
discrimination among competing customers in furnishing of or payment for
advertising or promotional services or facilities.
Robinson-Patman Actprohibits discriminatory pricing and other discriminatory
practices in the sale or distribution of goods.
Export Trade Actrequires FTC to supervise the registration and operation of
association of American exporters engaged solely in export trade.
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McCarren-Ferguson Actextends the applicability of antitrust legislation to
insurance companies.
Wool Products Labeling Actprohibits misbranding of wool products.
Fur Products Labeling Actprohibits misbranding of fur products.
Flammable Fabrics Actprohibits the interstate marketing of dangerously
flammable articles of wearing apparel and interior furnishing and of dangerously
flammable fabrics and related material intended for use or which may be reasonably
expected to be used in any such product.
Textile-Fiber Products Indentification Actprohibits the misbranding and false
advertising of textile products (except wool) and defines required labeling
information for textile products.
Fair Packaging and Labeling Actprohibits unfair and deceptive packaging and
labeling and specifies conditions to be met by packagers of consumer goods.
Federal Cigarette Labeling and Advertising Actrequires inscription of a health
warning on cigarette packages.
Consumer Credit Protection Actrequires credit cost disclosure by consumer
creditors (retailers, finance companies, nonfederal credit unions and other creditors
not specifically regulated by another government agency) to assure a meaningful
basis for informed credit decisions.
To administer its responsibilities, the FTC has recently reorganized into two major
operating bureaus. These are the Bureau of Competition and the Bureau of Consumer
Protection. The Bureau of Competition has primary responsibility for enforcement of the
first four statutes listed above dealing with monopolistic behavior. The Bureau of Consumer
Protection enforces these laws related to mislabeling, deceptive packaging and advertising,
and product safety.
In fiscal year 1970 the FTC budget was $20.7 million; approximately 40 percent or $8.4
million was expended on efforts to maintain free competition. Consumer protection
activities of the FTC were allocated 50 percent or $10.3 million. The remainder was
expended for management and planning efforts.53
In recent years FTC's activities related to consumer protection have increased more
rapidly than its antimonopoly and other corporation-related activities. For example,
consumer protection activities have risen from 44 percent of the budget in 1968 to 50
percent in 1970.54'55 This increase reflects rising public interest in this area.
The influences of both FTC bureaus on solid waste generation and recycling are discussed
under two main categories: Trade practices, and labeling and packaging requirements.
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Trade Practices
Antitrust Activities. The FTC can influence solid waste recycling activities through
implication of corporations involved in processing and recycling secondary materials in
antitrust violations. For example, an industrial organization may be required by FTC to
divest itself of a secondary material processing subsidiary under antitrust action. Or, a group
of secondary material processors may be required to void a mutually beneficial operating
agreement because of trade restraint. No specific cases of these types have been noted, but
the possibility of their occurrence exists. On the other hand, enforcement of antitrust laws
by the FTC can be a valuable tool in assuring that free, fair, and vigorous competition
prevails in the area of solid waste recycling.
Industry Guidance. In addition to antitrust activities, the FTC strives to protect the
consumer and businessman in other respects. Trade practices are monitored and regulations
devised and promulgated when it appears that certain practices are unfair. For example, the
FTC has devised a Trade Regulation Rule for Games of Chance in the Food and Gasoline
Industries, and another on Unsolicited Mailing of Credit Cards. Through this mechanism,
FTC interprets the original Federal Trade Commission Act to apply to contemporary
business practices that appear unfair or deceptive.
Decisions made under this industry guidance program can have direct and indirect effects
on solid waste generation and recycling. For example, the FTC has declared it to be an
unfair trade practice to ship scrap iron and steel in rail cars so that inferior quality products
will not be readily discovered upon surface inspection.56 Similarly, the willful delivery of an
inferior product by a paperstock dealer or broker under a contract for a particular grade of
wastepaper has also been declared an unfair trade practice.57 These regulations have the
effect of improving product reliability of two major secondary material industries. There is
no estimate available to indicate the potential increase or decrease in quantity of waste
materials reclaimed as a result of these regulations.
Other FTC actions may have made it more difficult to market products made from
reclaimed materials and thus these actions discourage solid waste recovery. For example, a
manufacturer requested a ruling by FTC on whether it would be necessary to label an
electrical fuse as "rebuilt" or "remanufactured" if each used fuse were disassembled and all
used parts inspected to insure they met new part standards. The Commission advised the
company that the product must be labeled, "rebuilt fuses." In doing so the FTC cited its
holding that, in the absence of disclosure to the contrary, merchandise having the
appearance of merchandise composed of new materials but which is partially or wholly
composed of reclaimed materials, will be regarded by purchasers as being entirely new. FTC
officials express the position that the consumer has the right to know the types of products
being purchased. The Commission further contends that a substantial segment of the
consuming public has a preference for merchandise that is composed of new and unused
materials. "This has been held to be so without regard to the comparative quality of the new
and rebuilt products, for in such matters the public is entitled to get what it chooses no
matter what dictates the choice."58
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This ruling implies that merchandise made wholly or in part from used materials will
generally not be considered a substitute for merchandise made from new materials. This
and similar FTC rulings limit the market for products made from secondary materials. In the
absence of quantitative information, however, it is difficult to estimate the impact of such
actions on solid waste generation or the degree to which they hinder recycling.
Product Labeling and Packaging Requirements
Textiles. FTC enforces labeling requirements for textile fabrics. It has been alleged,
mainly by those in the secondary wool materials industry, that FTC's textile labeling
requirements hinder efforts to reclaim textile materials from solid wastes.
The FTC has stipulated that the terms "virgin" or "new", when used to describe a textile
fiber product, shall not be used unless the product is composed wholly of new or virgin
fibers. These fibers cannot have been reclaimed from any spun, woven, knitted, felted,
bonded or similarly manufactured product.59
A product must be labeled as containing "reprocessed wool" if all or part of the
constituent wool has been reclaimed from material not previously used by a consumer. If
wool reclaimed from garments previously used by consumers has been utilized in a product,
the product must be labeled as containing "reused wool." At the present time, wool is the
only fabric material that must be so labeled. In the late fifties, when Congress was
preparing the Textile Fiber Products Indentification Act, the imposition of similar labeling
requirements on synthetic fiber materials was considered. However, this idea was rejected.
FTC textile experts indicate that wool is the only fiber material that is reused today in any
significant quantities.
The imposition of a labeling requirement to enable the consumer to differentiate between
previously used and new wool fiber products has been based on performance. Reprocessed
or reused wool is of inferior quality to virgin wool. Various test methods and microscopic
examinations have been devised to identify this quality difference.60
The market for reprocessed and reused wool has been limited in the apparel industry as a
result, and only low-cost, low-value wearing apparel is made from reclaimed wool.
A survey conducted by the General Accounting Office to determine the end use of over
1.2 million Ib of carpet wool wastes developed the following information:61
Description Weight (Ibs)
Mops 465,289
Baseballs 402,396
Floor pads 155,611
Clothing 75,000
Gaskets 64,267
Other 59,698
Total 1,222,261
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It can be seen that the greatest quantities of reused wool wastes are used in the manufacture
of nonapparel items.
Unfortunately, there are no data presently available indicating the total quantity of wool
reclaimed for use. Nor is there reliable information indicating the total amount of wool
waste generated in the United States. However, it was the opinion of three textile
manufacturing experts, representing the FTC, the Department of Commerce's Office of
Textiles, and the Textile Fibers and By-Products Association, that most wool wastes readily
recoverable and occurring in significant quantities are now reclaimed. Furthermore, these
experts expressed the belief that rescinding the wool labeling requirement would have no
significant impact on the quantity of wool reclaimed.
It appears that the complaints against FTC's labeling requirements by those persons
engaged in reclaiming wool wastes are primarily based on economics. If labeling
requirements were rescinded, reclaimed wool would find increased use in apparel
manufacturing. An increase in value for reclaimed wool would be expected. However, the
total quantity of wool wastes recovered for reuse would not increase significantly.
Therefore, FTC-enforced labeling requirements for wool products do not appear to
significantly hinder wool waste reclamation nor encourage its generation.
FTC's activities under the Flammable Fabrics Act have an undetermined effect on solid
waste generation. FTC determines through testing whether garments exceed the safe limits
for flammability. Products conforming to FTC's flammability standards are so labeled. If
standards are not met, the FTC issues cease and desist orders to restrain the sale of these
items. In each case the Commission records its actions in individual reports, but the quantity
of material involved is not compiled. Therefore, the total weight of material the FTC orders
recalled by distributors or manufacturers in any given year can not be readily determined.
Although the procedure varies, the distributor or manufacturer recalling condemned
flammable apparel either reprocesses the goods to conform to standards (if economically
feasible) or disposes of the lot as waste. If the merchandise is imported, the distributor may
elect to ship the condemned goods back to the manufacturer. As long as the merchandise is
out of the channels of domestic commerce, the FTC does not monitor the destination of the
condemned goods. Ultimate disposition of such goods is not recorded. According to FTC
representatives, even a rough estimate of total solid waste generation resulting from FTC
action cannot be readily ascertained.
Other Commodities. Under the Fair Packaging and Labeling Act of 1966 (FPLA), the
FTC has inititated research and studies into such topics as "economy size" representation,
coupon practices, slack-fill practices, ingredients listing, and characterization of package
sizes. (The term "slack-fill" refers to the practice of filling a package to less than its
capacity. A package is nonfunctionally slack-filled if it is so filled for reasons other than (1)
protection of the contents, or (2) to satisfy the requirements of the machines used in
enclosing the contents.) The FTC shares responsibility for implementation and
administration of the FPLA with the National Bureau of Standards (NBS) and the
Department of Health, Education and Welfare (DHEW). The DHEW has responsibility for
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consumer commodities defined under the Federal Food, Drug and Cosmetic Act, while the
FTC regulates all other consumer commodity packaging and labeling.
Because packaging materials make up a significant portion of solid wastes (reported to be
approximately 13 percent of the estimated 350 million tons of residential, commercial and
industrial solid wastes generated per year),62 certain regulations could conceivably reduce
the quantity or the type of solid waste generated. Restrictions on package size and package
material constituency could reduce solid wastes, and may possibly encourage recovery of
packaging materials for reuse. For example, if cereal boxes were required to be of cubical
configuration instead of the present oblong parallelepiped, the resultant weight and
compacted volume of solid waste from this source would be reduced by approximately 11
percent. (Assume the average cereal box of 10 ounces has dimension of 10.375 x 7.5 x
2.375 in. and a volume of 185 cu in. A cubical cereal box of the same volume would have an
edge of 5.70 in. The weight and compacted volume of the empty cereal box as waste has
been assumed to be proportional to its surface area.)
Similarly, if the FTC were to influence package material constituency, use of readily
recycleable materials could be encouraged.
However, strict adherence by the FTC to the dictates of the FPLA will only indirectly
affect solid waste generation or recovery, and that influence will be slight.
The FPLA was passed so that "packages and their labels (would) enable consumers to
obtain accurate information as to the quantity of the contents and (would) facilitate value
comparisons.63 Various labeling and packaging requiements are set forth in the Act for the
specific purpose of preventing consumer deception. Also, the FTC has been empowered to
promulgate additional regulations to prevent consumer deception or to facilitate value
comparisons between commodities. Two actions FTC may take in this regard are
"Establish and define standards for characterization of the size of a
package . . . which may be used to supplement the label statement of net quantity of
contents of packages containing such comodity ..." This statement continues with
"... this paragraph shall not be construed as authorizing any limitation on the size,
shape, weight, dimensions, or number of packages which may be used to enclose any
commodity.64
"Prevent the nonfunctional slack-fill of packages containing consumer
commodities.65
Thus under present law, FTC cannot influence the design or constituency of consumer
commodity packages. It is possible that strict enforcement of the "slack-fill' requirements,
currently under study by the FTC, will result in a reduction in solid waste generation. Those
packages that are slack-filled are, by definition, larger than necessary to contain the
packaged commodity. One reason for this practice has been to present a shelf image of a
larger container. Curtailment of this practice may result in some reduction in packaging
waste. On the other hand, a packager found in violation of a slack-fill regulation may change
package design entirely and end up using more material or less readily disposable material in
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the new containers. It was difficult, therefore, to assess the extent to which the FTC would
influence packaging waste generation through enforcement of this portion of the FPLA.
Environmental Impact Statements
Public Law 91-190, The National Environmental Policy Act of 1969, requires
environmental impact statements to be prepared for major Federal actions that would
significantly affect the quality of the human environment. However, FTC has not prepared
any statements nor was the preparation of such statements planned as of this writing. FTC
officials expressed the view that environmental impact statements should not be required
for their agency. They reasoned that FTC's sole goal is to protect the consumer from unfair
trade practices. Possible environmental side-effects should have no bearing on a decision
aimed at protecting free trade.
Although this attitude apparently exists within the FTC, there are indications that the
agency will consider environmental matters more fully in the future. Other FTC officials
point out that, through cooperation with EPA and the Council on Environmental Quality
(CEQ), procedures for handling environmental impact statements, as required by P.L.
91-190, have been developed and were published in late 1971. Also, although no formal
liaison exists, FTC periodically meets informally with high level EPA personnel to discuss
common problems.
Recommendations
The FTC should consider product performance as an additional criteria for the
public to use in judging the suitability of a given product.
Following the expressed position that the public is entitled to know what it is
buying and to purchase what it chooses, FTC has required full disclosure of product
contents, including source of materials, either new or used. This position results in a
marketing advantage for new materials. Instead of supporting the concept that used
goods or goods composed of used materials are inferior, the Government should take
the lead in establishing a product performance certification system.
Under such a system, if Product A composed of used materials has performance
characteristics inferior to Product B, composed of new materials, then Product A's
marketability would be effected as now is the case. However, if Products A and B
can be demonstrated to perform equally well for the intended use, the marketability
of Product A would no longer be hampered by FTC labeling requirements. The
producer of Product A would likely increase his use of secondary materials in his
manufacturing process. Thus, one effect of the performance certification system
would be an increase in the quantity of materials reclaimed for reuse and recycling.
An inherent problem in use of product performance certification is the time and
effort required for certification and enforcement. The logical agency within the
Federal Government to organize a certification system would be the National
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Bureau of Standards. This agency is discussed further in Chapter VIII. Alternatively,
a nationally recognized testing agency, such as the American Society for Testing
Materials, could develop the procedures required for product performance testing
and certification. The product performance tests could be conducted by the
manufacturers.
FTC officials agree that establishment of a system of product performance
standards would be beneficial and are contemplating action in this direction.
It has been recommended in Chapter VIII that the National Bureau of Standards
(NBS) seek voluntary packaging design changes by manufacturers to effect a
reduction in solid waste generation and/or to facilitate waste recovery. FTC and
NBS should work cooperatively in attempting to achieve voluntary package design
limitation.
If such an effort proves futile, FTC should seek to alter the Fair Packaging and
Labeling Act so that packaging design and constituency can be regulated by Federal
agencies.
FTC should prepare environmental impact statements as directed by Public Law
91-190, and consider the possible ramifications of its actions upon solid waste
generation and recycling, among other factors.
Regardless of whether FTC's decisions are influenced by potential environmental
side effects or not, the public should be fully informed of the expected
consequences.
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CHAPTER V
FOREST SERVICE
DEPARTMENT OF AGRICULTURE
Abstract
The Forest Service influences use of the country's forested lands. During the harvesting of
timber, solid wastes in the form of branches, tops, and low-grade trees are generated to
varying degrees. These wastes constitute a disposal problem.
Wood and wood products, particularly paper, are a major constituent of many
manufactured products. These products also eventually become solid waste disposal
problems. The agency has been active in developing and promoting the efficient utilization
of wood resources and has cooperated with other agencies in studying resource recovery
aspects of solid waste management. These and other Forest Service activities are described in
the assessment of this agency's influences on solid waste generation and recycling.
Background
The Forest Service has major responsibility within the Federal Government for promoting
the conservation and efficient use of the Nation's forested lands. Although it directly
controls only about 19 percent of the commercial forest land in the United States, the
Forest Service influences all forest resource owners.66
Administrative responsibility for the Nation's forest reserves was transferred to the
Department of Agriculture's newly formed Forest Service in 1905. Today the Forest Service
has three major functions, as described below:
Forest Research. Basic and applied research is carried out on problems associated
with all aspects of forest land management and uses of forest resources. Often
executed in cooperation with State colleges and other educational institutions, the
research projects include, but are not limited to, studies on tree genetics; wildfire
prevention, detection and supression; improved forest product processing
techniques; and nutrition.
The National Forest System. Forest Service personnel assigned to this activity are
directly responsible for the management and development of the national forests.
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Techniques of forestry are applied to the growing a.nd harvesting of timber for
manufacture of over 5,000 wood and paper products.67 The national forests are also
managed to conserve water resources, and to provide for domestic and wild animal
forage, and public recreation.
The 154 national forests and 19 national grasslands are administered on a regional
basis. Responsibility is passed to the Forest Supervisors, who manage each national
forest.
A major duty of the Forest Service administered under the National Forest
System involves timber management in national forest lands. Trees are sold to
contractors on a planned basis following set policies and regulations.
State and Private Forestry. The Forest Service assists local public and private owners
of forests and private industry by providing assistance and current technical
information on topics such as harvesting, processing, marketing, disease control, fire
prevention and flood control. Knowledge of improved forestry techniques developed
through other Forest Service activities is thus made available for use on private and
State-owned forest lands.
The Forest Service budget for fiscal year 1971 was $652 million.68 Research activities
were budgeted at $48 million, according to Forest Service officials, with the remainder
being applied to the National Forest System, cooperation with state and private forest
owners, and administration activities.
Each of the above-described Forest Service activities influence the amount of solid wastes
generated and/or recovered. Policies, regulations, and procedures affecting resource
utilization and solid waste are discussed in the following sections in relation to four distinct
phases that occur in processing trees for ultimate use: harvesting, manufacturing, pulping,
and use.
Harvesting
Millions of tons of solid forestry waste are generated naturally and as a result of logging
operations. Branches, tops, stumps, defective, and small trees are either left in the forest
after harvesting or the slash (as such residue is called) is burned in place to leave ash.
Burning has been the most economical method of volume reduction and disposal. It was
estimated that the volume of unsalvaged dead trees amounts to 5.6 billion cu ft per year or
roughly 36 percent of the net growth of sawtimber on all commercial forest lands.69 Much
of this was in the form of limbs and dead trees resulting from natural causes such as fires,
disease, and aging. On balance, Forest Service activities are oriented towards maximizing
forest resource utilization and reducing solid waste generation.
Solid Waste Volume Reduction and Recovery. Regulations promulgated by the Forest
Service specify harvesting techniques to be followed by contractors who purchase timber
from national forests. These techniques are designed to minimize damage to the forest
environment and maximize the wood resource utilization. Requirements are set for logging
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road construction, slash disposal, and tree-cutting methods, among others. Specifically, the
requirement stipulating the minimum dimensions to which a cut tree must conform affects a
greater utilization of the tree. Presently, the minimum small-end diameter allowable for a
cut tree varies from 2 in. to 10 in., depending upon geographic, economic, and timber
conditions. A contractor who cuts the tops to a greater diameter to facilitate handling is
subject to a damage payment. Thus, this requirement results in a lower volume of treetop
wood cut and left as slash. Furthermore, as handling and processing technology improves,
the Forest Service revises its standards. For example, in one region, the minimum small-end
diameter has recently been decreased to 4 in. from 8 in. for certain types of trees.
In another effort to improve forest resource utilization and reduce residues, the Forest
Service encourages recovery of dead and down timber and cull trees. For instance, in 1962,
approximately 393 million cu ft of timber in the Pacific Coast section (Alaska, California,
Hawaii, Oregon, and Washington), or 11 percent of total roundwood production, came from
dead and cull trees.70 (These trees are natural occurring and do not result from man's
harvesting activities). Only a portion of the potential salvage is represented by this figure.
There was a backlog of approximately 10 billion cu ft of salvable timber in the Pacific
Coast section alone, and this increases by about 1.4-billion cu ft each year. Increased
utilization and resultant reduced quantitities of wastes in the forests are distinct
possibilities. Methods for recovery of these resources are under investigation by the Forest
Service.
Various research activities are ongoing in which techniques for more efficient harvesting
are being studied. For example, the Forest Service was investigating a method by which a
tree is scissored off at ground level, thus reducing stump size and including a greater portion
of the tree in the harvested log. Until this practice becomes widespread, the Forest Service
now levies a penalty charge of $1.00 against contractors for each stump exceeding a
specified height.
It has been estimated that as much as 20 percent of the wood content of a tree can be in
the stump and root system. This resource at present goes largely unharvested. The Forest
Service has given preliminary consideration to possible methods for harvesting this wood,
but no research projects are now contemplated. However, the value of the wood in the root
system may be greater in place than it would be following conversion to products, since
roots are known to be beneficial in controlling soil erosion in harvested forest areas.
Another research activity was underway to develop solutions for economical disposal
and/or reuse of slash. Slash is currently left in place to decay or else disposed of by
windrowing and burning. On a trial basis, the Forest Service was experimenting with the
technique of yarding the slash in a central location for controlled burning.
Newly developed harvesting techniques that result in less slash generation have been
disseminated throughout the country for use by State and private forestry personnel
through the Forest Service's cooperative programs.
The principal problems preventing the forestry industry from extensive use of harvesting
residuals are related to collection and debarking. Slash contains usable wood fiber, but in a
loose state it cannot be economically transported to a central processing plant for recovery
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of valuable constituents. Forest Service researchers are investigating the practicability of
using portable chippers to reduce the volume of slash so that the harvesting residue can be
removed for use. Such a solution may be practical only if an effective method of debarking
chipped limbs, tops, and branches can be devised. Most uses for wood chips, such as in
particle board, wood pulp, and cattle feed, are possible only if the chips are essentially free
from bark contamination. In this regard, the Forest Service has encouraged research into
bark separation techniques. Various processes are now under study by the Forest Service, by
industry, and at the university level to develop a workable bark separation and subsequent
segregation system. The best opportunities for chipped slash utilization appear to be in pulp
manufacture. Consequently, research efforts are being concentrated in that area.
Solid Waste Generation. The efforts of the Forest Service towards encouraging maximum
forest resource recovery are not entirely successful, due to two main reasons: (1) The Forest
Service directly controls harvesting practices in only a part of the Nation's commercial
forests, and (2) Forest Service regulations are difficult to effectively enforce and can be
circumvented, oftentimes resulting in wasteful practices.
Of the 511 million acres of commercial forest land in the United States, only 97 million
acres, or 19 percent are national forest lands under Forest Service jurisdiction.71
Seventy-two percent of all commercial forest land is under private control and 9 percent is
owned by other Federal, State, and local government entities. In 1962 only 18 percent of
the growing stock cut in the United States came from national forests, while 75 percent
came from lands owned by private interests.72 Timber cut on private lands is not subject
to the minimum specifications and other measures promulgated by the Forest Service to
improve utilization and decrease harvesting wastes.
Although the Forest Service does not directly control a majority of the commercial
timber cut, the timber harvest from national forests was significant. Wastes produced in
harvesting this timber are also of significant volume. For example, it was estimated by
Forest Service officials that harvesting operations can result in from 20 to over 300 tons of
residual wastes per acre in clearcutting operations, i.e. where all timber in a given area is cut.
This generation rate varies widely depending on such factors as geography, timber density,
and tree variety.
In 1970, 1,512,000 acres of national forest land were cut by contract; 564,000 of these
were clearcut. Assuming 150 tons of harvesting residues per acre are generated by
clearcutting operations and 75 tons per acre by operations other than clearcutting, the total
amount of harvesting waste generated on national forest land in 1970 was computed to be
155 million tons. Present and future Forest Service procedures and requirements imposed
on contractors to reduce harvesting residues can have a significant effect toward reducing
solid waste generation.
However, the mere fact that tree-cutting regulations exist that are aimed at achieving
greater utilization and reducing residue generation does not assure implementation. For
example, the General Accounting Office (GAO) has reported on timber sale practices that
resulted in under-utilization of forest resources because existing regulations were not being
enforced. A brief summary of GAO findings has been provided below.
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The quantity of national forest timber sold is frequently determined by measuring the
logs following tree-cutting, a process known as scaling. According to GAO, the timber in the
Pacific Northwest Region was scaled either by Forest Service personnel or by personnel of
private scaling bureaus authorized by the Forest Service to perform this function. During a
5-year period ending December 31, 1965, scaling bureaus measured approximately 12.4
billion board-feet of timber in this region.73 Payment by the contractor to the Forest
Service was based upon the measurements reported by the private scaling bureaus.
The cut lengths of logs usually exceed the lengths of primary wood products to be
manufactured. The excess, called trim, is provided to allow for losses in the manufacturing
process because of such things as the presence of dirt and gravel imbedded in the log ends
and end-damage caused by loading hooks. Cutting logs with more than the minimum
required amount of trim is a wasteful practice because the excess trim is not used in primary
wood products production.
Just as the Forest Service sets minimum-end diameter specifications in the timber sale
contract, as discussed before, so are maximum permissible trim allowances specified. The
contracts also provide a basis for billing timber purchasers for losses in timber volume
resulting from logs being cut with trim exceeding that necessary for the efficient
manufacture of primary wood products. The charges are imposed by the Forest Service via a
penalty fee for wasteful practices.
However, GAO found evidence that scaling bureaus did not reliably record instances of
excess trim nor did responsible Forest Service personnel levy the proper penalties when
excess trim was disclosed.74 A rough estimate of the quantity of harvesting waste generated
because of this procedure in this region can be made. Assuming the density of wood at 40
Ib/cu ft, there are approximately 3.3 Ib of wood in 1 board-foot. If excess trim accounted
for 2 percent of all timber scaled, then 415,000 tons of unnecessary wood residues were
generated in the 5-year period under consideration in the Pacific Northwest Region alone.
It should be pointed out that trim waste ends are readily usable as paper pulp, and a high
proportion are chipped for this purpose. Forest Service staff estimate that more than 90
percent of softwood trim-ends go to fiber use.
Manufacturing
Residues from wood product manufacturing processes include slabs, edgings, shavings,
sawdust, and bark. In 1962 approximately 43 million tons of such residues generated by
primary manufacturing industries were used.75 Through its activities, the Forest Service
helps to reduce the quantity of manufacturing residues.
Research. Use of sawmill residues, particularly in the western United States has increased
significantly in the last 10 years. For example, 20 percent of the pulpwood supply in 1962
was derived from plant byproducts,76 compared with an estimated 30 percent in ] 970. The
increase in production of particleboard from wood chip residues has reduced the quantity of
wood chips discarded. However, substantial amounts of manufacturing residues are not
presently utilized and are consequently wasted. Research efforts to devise manufacturing
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processes that reduce waste quantities and to develop new use:; for plant residues are either
underway in the Forest Service or are comptemplated.
Bark is a major portion of presently unused plant residues. Some bark is sold for use as a
mulch, but this outlet is not large enough to divert all bark from the waste stream. Studies
have shown that various chemicals, including wax and oils, can be extracted from bark,
although the economics of full-scale operation are not yet favorable. The Forest Service is
doing research on the feasibility of composting bark, and continuing studies are underway
to characterize the chemical constituents of bark. Also, further research may lead to the
development of better construction boards containing significart quantities of bark.
It has been demonstrated that wood residues, after minimum processing to attain desired
physical form, can be effectively used as roughage in livestock feed. With more extensive
processing, wood can also be converted to a carbohydrate source. Considering that livestock
consume approximately 400 million tons of food annually, a beneficial use of large
quantities of the wood-processing plant residues is potentially available.77 Conventional
roughage sources, such as hay, silage, and cottonseed hulls, arc scarce in many regions and
expensive to transport. Roughage materials cost from $20 to $40 per ton, thus, substantial
income is possible to a processor selling wood wastes for roughage.
A wood content of 5 to 15 percent has been found to be the optimum range for this
residue's inclusion in livestock feed as roughage.78 Assuming a 5-percent wood residue
content in the 400 million tons of feed used per year yields a potential use for 20 million
tons of wood residues annually or about 40 percent of the total amount available at
processing plants. Thus, livestock roughage appears to be a residue use worth further
research and development under Forest Service sponsorship.
No serious research problems exist concerning the use of wood residues for pulp
production.79 Good quality paper can be made from most wood residues with the
exception of bark. In this respect, development of an effective chip debarking system, as
previously discussed, would increase the quantities of wood residues used in papermaking, as
well as in particleboard or flakeboard manufacture, since bark contaminates both paper and
particleboard manufacturing processes.
As technology in the forestry industry advances, greater utilization of the logs brought to
the sawmill or plant for processing can be achieved. Accompanying the increased utilization
may be decreased generation of residues. Both private industry working independently and
the Forest Service have contributed to improvements in this respect.
For example, a reduction in the thickness of the saw blade causes a corresponding
decrease in the width of the saw kerf, thus reducing the amount of wood cut from a log in
the form of wood chips and sawdust. Research into methods of log-cutting that would
reduce the saw kerf width was underway by the Forest Service.
Similarly, the Forest Service has worked on the development of a type of sawing system
called the chipping head-rig that squares logs by chipping action. The residue from this type
of processing consists mostly of wood chips rather than sawdust. Sawdust presently is the
most voluminous portion of residue trom lumber manufacturing operations. Wood chips are
readily usable in particleboard manufacture. They also contain long wood fibers that
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facilitate pulp production, whereas sawdust has limited use applications because fibers are
shorter on the average.
Forest Service research activities in manufacturing technology can influence the level of
resource utilization and the related amount of residues generated. For example, in the
Pacific Northwest, if timber utilization were improved to a point where trees of 9-in. trunk
diameter could be processed into lumber, and if the width of the saw kerf were reduced, the
yield of timber products could be increased approximately 11 percent.80 Presently,
softwood sawtimber is a minimum 9 in. in diameter, except in the Pacific Northwest, where
the minimum diameter is 11 in. Hardwoods, found mainly in the East, must have a diameter
of at least 11 in.
National Forests. Once the timber on a tract of national forest land has been sold by the
Forest Service to a contractor, the use or destination of that timber is not under Forest
Service jurisdiction. Therefore, the National Forest System activity has minimal influence
on wastes generated from processing and manufacturing operations.
However, when it becomes technically feasible to process smaller diameter trees, timber,
sale contracts can be altered with the addition of a requirement that cull trees and down
trees of previously undersized dimensions be included in the sale. In this manner,
improvements in manufacturing processes will bring about a reduction in the quantity of
solid wastes generated in forest areas.
State and Private Forestry. The Forest Service is working in conjunction with many
interested organizations on methods to improve wood product manufacturing processes and
utilize wastes. For example, the Forest Products Laboratory of the Forest Service, the
Tennessee Valley Authority, and the Universities of Wisconsin, Pennsylvania State, and
Auburn have been cooperating on research for the past 4 years to convert wood residues to
livestock feed. Each organization was researching complementary aspects of the topic.
As new wood product manufacturing techniques are devised, whether by industry,
university, or Forest Service researchers, State and Private Forestry disseminates the
information to interested parties. In addition, marketing assistance can be provided to
industry to help locate markets for plant byproducts and residues.
Pulping Effluents
Wastes generated from pulp and paper manufacturing plants occur in liquid, gaseous, and
solid forms. The largest quantities of waste effluent are in the waste liquors. In some
processes (chemical) these wastes contain about one-half of the wood processed as well as
the unused or spent chemicals. Approximately 52 million tons of wood fibers are lost
annually during papermaking operations. However, as great as this volume is, spent waste
liquors are not the most serious pollution problem. Some solids are removed and the
subsequent effluents are largely burned in recovery furnaces designed to recover heat and
chemicals.
Both gaseous emissions from recovery furnaces and liquid discharges from bleach plant
operations are serious problems in the paper industry. The liquid discharges from these
plants are too dilute for economical burning or chemical recovery. These pollution problems
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do not directly involve solid waste generation or recycling, and are therefore beyond the
scope of this study.
Solids recovered from waste liquors at paper manufacturing plants are also a problem.
The National Forest System and Cooperative Forestry activities have minimal influence on
the generation and/or use of solid waste residues from papermaking operations. The research
activity of the Forest Service, however, has the resources to study solutions and is currently
planning investigations in this area.
Fibers and additives suspended in liquid effluents are the major type of solid wastes.
These solid residuals can completely destroy the natural ecology of the receiving waters if
allowed to accumulate. (As much as 50 tons per day can be produced by a single mill.)81
The Forest Service has identified three aspects of the solid waste generation problem;
Collection of solids
Disposal of collected solids
Reduction of solid waste quantities in processing.
The Forest Products Laboratory is planning work on improved collection systems and the
development of products made from the collected solids. Pulping waste sludges are very
difficult to dewater and, if too moist, cannot be deposited on land because of putrefaction.
Although burning has been sometimes used to reduce the volume, the wet sludge is not
suitable for disposal by this method. Possible uses for recovered, dewatered pulp mill sludges
include use as a constituent in construction board, tile products, and molded fiber products,
and as livestock feed. In contrast to wood chip and sawdust residues, most pulping wastes
are digestible by livestock. Extraneous materials, such as clay fillers, frequently found in
paper manufacturing wastes, are not expected to be harmful to the digestive system of
livestock.
The process of chemically pulping wood involves removing the lignin, the material
binding one fiber to another, from the wood. The freed individual cellulose fibers can then
be matted into paper. Present delignification methods are not selective, thus the amount of
wood fibers lost during delignification is equal to or more than the amount of lignin
removed. Improvements in this operation would lead to a significant reduction in the
quantity of solid wastes generated from paper manufacturing p';ants. Forest Service research
efforts into more selective methods to dissolve lignin are in the early stages.
Another type of paper is made from mechanical pulp, or groundwood. This paper retains
most of the lignin; over 95 percent of the wood input to this process is incorporated in the
product. Thus, there is little solid waste generated from a plant manufacturing paper from
groundwood. Such paper is suitable for newsprint, magazines, and book stock. If the uses
for paper made from mechanical pulp were expanded and increased, a reduction in plant
residues would result. The Forest Service has expressed an interest in developing improved
quality groundwood paper, but little research is underway on this topic.
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Product Use and Discard
Forest Service activities relating to solid waste generated as a result of discarded
consumer products are in conflict in some aspects. On the one hand, for example, research
activities are being conducted on methods of recycling or saving wood fiber in solid wastes,
while the same activity area seeks to develop new (sometimes more efficient) uses for forest
products, in order to increase value from forests. As an additional encouragement, the
Forest Service provides marketing assistance to processors of wood products. Minimal
marketing assistance is provided to processors of paper products. Since many wood
products, particularly paper products, are short-lived goods and are disposed of after a single
use, encouragement of the manufacture of these products is tantamount to encouragement
of waste generation.
Research. Because paper comprises approximately 50 percent of municipal refuse, it is a
natural target for recovery and recycling efforts. Approximately 10 million tons of paper
per year are now being recycled. Virtually none originates from municipal refuse. The
Forest Service is cooperating with the Office of Solid Waste Management Programs, EPA;
the city of Madison, Wisconsin; and the Bureau of Mines, Department of the Interior; in the
development of a processing scheme for the reclamation of cellulosic, as well as mineral and
glass wastes from the city's municipal refuse. Except for the successful collection of
separated newspapers, the project is still in its early stages. No reliable scheme has yet been
commercially adapted to effect economical recovery of resources from municipal wastes.
The goal of the Forest Service in this program has been to develop and test a prototype
cellulose-recovery system. The project has been budgeted at approximately $230,000 for
1971, compared with the total Forest Service research budget of $48.8 million.
The goal of this program is admirable and necessary. It should be recognized that the
most beneficial result of recycling cellulosic wastes is a corresponding reduction in the
quantity of solid waste materials requiring disposal. Claims that "recycling paper will save
trees' are invalid in the sense that they are generally used. The mind envisions virgin forest
land saved from the ax because newsprint has been sent back to the plant for reuse. In
reality, much paper is made from trees grown as agricultural products on private lands, and
if a tree is planted to replace each tree cut, the overall adverse effects are temporary and
minimal. Trees will be harvested regardless of the recycle rate, because trees cannot be saved
indefinitely. They are living organisms and, if left to nature, will grow old and die. Even in
the case of virgin, "wild" forests, cutting may be deferred, but in the long run the tree will
either be harvested or fall from disease or old age. As long as the rate of growth is more than
or equal to the demand, wastepaper recovery from municipal wastes will not reduce the
number of trees cut for pulpwood.
Paper recycling to recover the wood fiber for reuse in paper and paper products will
become increasingly necessary in the future to meet the growing demand for paper
consumer goods. The demand for wood and its products continues to increase, and
projections indicate that it will more than double by the year 2000.82 Softwood and
hardwood cut is predicted to exceed growth by 1990.83 As demand exceeds supply,
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secondary sources (recycling) must be utilized to satisfy consumer demands. However, calls
by conservationists and others to increase the present 20-percent recycling rate in this
country are based on an anticipation of future requirements, rather than immediate resource
needs or economics. There is presently an abundance of virgin pulpwood supplies. Wood
pulp is cheap and so is wastepaper. When pulp becomes more scarce, and if the demand for
paper products continues to increase as predicted, wastepaper will become more valuable
and subsequently may be economically recycled to a greater degree than now.84
Until the time when paper companies demand significant quantities of wastepaper
reclaimed from municipal refuse, the wastepaper collected will be difficult, if not
impossible, to market. Forest Service research can help to encourage paper recycling by
improving the economics and technical factors related to its reuse. For example, if
newspapers contained in municipal refuse were recovered and reprocessed into newsprint, a
twofold benefit would result. Besides reducing the quantity of waste needing disposal, the
country could improve its balance-of-payments situation, since most newsprint comes from
outside the United States. In 1970 approximately 9 million tons of newsprint were used in
the United States, of which 2 million tons were recovered for reuse as paper or in other
products.85 Approximately 6.5 million tons of newsprint were imported from Canada.86
Canada also supplied this country with large quantities of pulpwood.
In 1970, pulpwood prices were approximately $20 per cord, varying with species.87
Total pulpwood imports were 1 million cords. Thus, the United States paid approximately
$120 million to foreign countries for a product which conceivably could be recovered from
municipal refuse. If the 9 million tons of newspapers alone were recovered for repulping,
de-inking, and remanufacture, 8 million tons of newsprint could be produced (assuming
about 90 percent of the fibers remain after repulping). This represents a saving of more
newsprint (the principal paper import) than was imported that year. Thus, there are
significant gains to be achieved if Forest Service researchers develop means for the use of
wood fiber presently discarded as waste.
National Forests. It has been suggested that the Forest Service, through the National
Forest System, strictly limit the sale of its timber and thereby cause an increase in the value
of wood fiber found in wastepaper.88 Unfortunately, this approach would not achieve the
desired result, at least not for the near term. As noted previously, the national forests
comprise only 19 percent of the Nation's commercial forest lands. Furthermore, most paper
produced in the United States comes from integrated manufacturers in the southern States
where national forest holdings are minimal (5 percent of commercial forest land). Of the
total domestic pulpwood production of 70.3 million cords, 42.4 million, or 60 percent,
came from the South. Another 11.6 million cords (16 percent) came from the North, where
national forest lands comprise only 6 percent of all commercial forest land. In contrast, the
West's commercial forests, 56 percent of which are operated by the Forest Service and
representing 79 percent of all national forest lands, produced only 16.3 million cords (23
percent).89 Thus, paper has been produced predominantly from pulpwood grown on private
land or land outside the control or influence of the Forest Service. Restriction of the cut of
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timber on national forest land will not significantly increase the current demand for
wastepaper.
The Forest Service was conducting an experiment which may lead to better control of
solid waste generation in national forest recreational areas. At the Boundary Water Canoe
Area, a portion of the Superior National Forest designated as a permanent wilderness area,
hikers, campers, and canoers may not bring noncombustible disposable products into the
forest. The 113,000 visitors in 1969 left many food and beverage packages along trails and
around campsites, prompting Forest Service officials to devise a means to protect the
wilderness area. All indications are that this system is working well. Visitors carry their food
in combustible packaging or in their camp gear containers that are brought out after the
visit.
It is interesting to contemplate the potential ramifications of this policy were it to be
adopted nationwide and expanded to cover day-use as well as wilderness area national forest
recreational facilities. In 1970, there were 67.6 million visitor-days recorded at developed
sites in the national forests.90 In a recent study, it was estimated that 0.92 Ib of refuse was
generated per visitor-day.91 Assuming one-half this amount was noncombustible,
approximately 15,000 tons of solid wastes annually would not be generated on National
Forest lands. The miniscule impact of such policy with respect to total solid waste
generation, the difficulty in policing, and the inconvenience to citizens would likely make
such a system unworkable in all recreational areas. However, implementation in wilderness
areas and other remote forest lands would reduce waste collection costs and scenic blight.
Environmental Impact Statements
Environmental impact statements are prepared by the Forest Service for major timber
sales, land exchanges, and other actions that could affect the environment. A sampling of
four of these statements indicates that considerable effort was expended in their
preparation. The statements fully described the ecology, appearance, history and
archeology, and socioeconomics of the national forest. The potential environmental impact
is considered as the action would affect the recreation potentialities, scenery, wildlife,
vegetation, aquatic habitat, water and air quality, noise levels, and economics. Favorable
environmental effects are weighed against adverse impacts and alternatives described, where
applicable. Generally, the statements follow the guidelines set up by the Council on
Environmental Quality.
Given this extensive coverage, the topics of solid waste generation, recycling, and disposal
are conspicuous by their absence. In only one of the four statements reviewed was solid
waste disposal mentioned and this was a one sentence assurance that refuse generated in the
national forest area would be disposed of properly.
Recommendations
The Forest Service was established to help protect the Nation's forests and is oriented
towards forest resource conservation and beneficial utilization. However, changes in existing
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Forest Service policies, programs, and regulations could result in more effective resource
utilization and less solid waste generation.
All tree-cutting specifications and regulations promulgated under timber sale
contracts should be periodically revised to reflect technological advances in industry
allowing use of more of the harvest log.
Timber sale contracts should require more extensive harvesting of marginal down
and dead salvageable trees, whenever economically feasible.
Additional research should be directed toward greater utilization of those portions
of harvested trees now wasted.
Cutting regulations should be more strictly enforced to ensure their intent is being
realized.
Environmental impact statements should specifically consider the quantity of solid
wastes expected from Forest Service actions and consider alternative methods of
reducing the amount, when possible.
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CHAPTER VI
GENERAL ACCOUNTING OFFICE
Abstract
The General Accounting Office (GAO) is empowered to audit most departments and
agencies of the Federal Government. Through its activities, GAO frequently reports on
governmental inefficiencies and wastefulness; a primary goal of GAO is to assure that
taxpayers' dollars are utilized efficiently.
Agency practices that are wasteful dollar-wise may also be wasteful of resources. In such
cases, GAO inadvertently acts as a watchdog for Federal activities that are
counterproductive to resource recovery goals. In addition, GAO has satellite staffs
permanently assigned to the EPA and the Army Corps of Engineers that can provide further
specialized assistance in identifying Federal actions inconsistent with the national
environmental policy in general, and solid waste management goals specifically.
Background
The General Accounting Office (GAO) was established in 1921 when audit authority of
the Federal Government was consolidated into a single agency. GAO was empowered to
audit all departments and agencies of the Federal Government except for various banking
and currency activities. Books, documents, papers, and other records of the departments
and agencies are available to GAO in conducting audits.
As an independent agent of Congress, GAO assists in providing control over the receipt,
disbursement, and expenditures of public monies. In addition to its primary mission of
agency performance reviews, GAO also provides the following services:
Special assistance to Congress
Legal services and decisions
Financial management improvement studies
Financial auditing of government contractors and settlement of accounts
Promulgates rules and regulations.
The relationships between GAO's duties and governmental influence on solid waste
generation and recycling are subsequently discussed in three sections:
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Agency fiscal and performance audits
GAO's Environmental Protection Agency staff activities
GAO's Army Corps of Engineers staff activities.
Agency Fiscal and Performance Audits
Acting either on its own initiative or at the specific request of a member of Congress or a
Congressional committee, GAO investigates instances where Federal agencies may be
operating inefficiently. Economy, efficiency, and effectiveness are the criteria used by GAO
in its investigations.
Initially, GAO conducts a preliminary investigation. A full-scale investigation is
conducted if results of the preliminary investigation so indicate. The alleged inefficiencies
are investigated and documented. Recommendations are prepared on methods to correct the
deficiencies. The audited agency is then provided the opportunity to respond to or act upon
the recommendations before the findings are presented to Congress.
C.AO representatives indicated that frequently those policies designed to effect maximum
utilization of government property are not enforced. Thus, beneficial usage of government
property is not realized to the level desired. The following examples of previous GAO audits
are illustrative.
Reusable ammunition covers.92 In 1965, GAO reviewed Navy use of Mark IV projectile
fuse covers. Many types of ammunition are shipped from naval ordinance plants or depots
to the fleet with covers attached for protection. These protective covers are reusable after
firing of the projectile. GAO found during its investigation that only about 20 percent of
the estimated 289,000 fuse covers were returned. The approximately 231,000 brass and
steel covers lost over the 5-year study period required replacement at an estimated cost of
$595,000. Losses of other reusable items were also identified, but not documented. To
correct this situation, GAO recommended that appropriate accounting controls be instituted
by the Navy supply system.
In this instance, GAO action to prevent unnecessary expenditures of Federal funds
resulted also in resource conservation and a reduction in solid waste generation.
Motor vehicle tires.93 The Air Force has found that under certain conditions significant
savings can be realized by using rebuilt or recapped tires. Air Force Technical Order
36Y32-1-122 directed that reuseable motor vehicle tires be rebuilt or recapped rather than
replaced with new tires. However, GAO found that Air Force personnel responsible for tire
inspection allowed excessive tread wear to occur, thus damagmg many carcasses beyond the
point where recapping could still be accomplished. Also many tires were condemned
although they could have been rebuilt. In a 1964 survey of tire usage at 80 Air Force
installations, it was found that nearly 80 percent of the installations met less than 50
percent of their new tire requirements with recapped or rebuilt tires.
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GAO sources indicated that 90 percent of all carcass damage occured during the last 2/32
in. of tread life. This damage prevents the recapping of the tire. So, even though the Air
Force had a written policy to encourage reuse of resources, implementation was inadequate.
Following GAO's recommendations, the Air Force instituted a policy to require periodic
tire inspection to help prevent carcass damage. Conclusions of this investigation were
furnished to the Army and Navy also. GAO respresentatives indicated that the Air Force
actions should result in substantial savings.
GAO also investigated the extent to which used tires were salvaged by the military
services in Europe.94 It was found that the Army and the Air Force in fiscal year 1969 had
a total requirement for 107,836 tires. About 48 percent were rebuilt. It was estimated that a
savings of $1,040,000 could have been realized if 75 percent of the requirement had been
supplied by rebuilt tires.95 This represents 28,500 more tires reclaimed. Action was taken
by the military to remedy this situation, but the results have not yet been documented. The
Department of the Army has estimated that 75 percent of all Department of Defense tire
replacement requirements can be met by utilizing retread tires at an annual savings of
approximately $20 million.96
Excess aircraft engines.97 Air Force regulations require that excess engines should be
disassembled to obtain component parts needed for other engines whenever practical and
economical. However, because of administrative deficiencies, GAO found that many parts
were not reclaimed and were condemned to scrap along with the remainder of the engine.
Thus, the full resource value of the needed parts was not realized. At the recommendation
of GAO, the Air Force took remedial action and redirected valuable resources from
condemnation to reuse.
Controls over timber cutting practices.98 As discussed in Chapter V, certain minimum
requirements are imposed on trees cut by contractors from national forests. These
requirements are intended to promote optimum use of harvested timber under the market
conditions and industry practices prevalent in the area. During an investigation of the
cutting practices of contractors in the Douglas Fir subregion of the Pacific Northwest
Region, GAO found that noncompliance with one requirement pertaining to trim
allowances was widespread. It is estimated from GAO figures that as nv.ch as 95,000 tons
per year of logging waste was created because of this noncompliance. G* O recommended
that the Forest Service establish appropriate control procedures to ensure proper
enforcement of the specific regulations studied. Thus, GAO action may lead to greater
utilization and a resultant reduction in residue quantities.
Currently under study by GAO is the potential for decreasing the volume of wood
material being left in timber sales areas administered by the Forest Service and the
Department of the Interior.
Through its normal audit and survey work GAO routinely uncovers instances where
governmental agencies generate excessive solid waste or otherwise contribute to a misuse of
resources. An important aspect of governmental activity with respect to resource recovery
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goals is also evident; that is, the existence of regulations anc1 policies directing steps to be
taken to conserve material or recover potential waste do not in themselves insure
accomplishment of the desired goals. Inaction or lax enforcement can render
well-intentioned regulations useless.
GAO-EPA Staff Activities
For many ongoing Federal programs, GAO has a separate staff permanently assigned to
facilitate audits and also to cooperate with the agency in fulfilling its mission. The
GAOEPA staff has established itself as a cooperative partner with EPA. Unlike many of
the GAO special staff assigned to other agencies, the GAOEPA staff is primarily concerned
with effectiveness of EPA administered programs. About 80 percent of GAOEPA staff
effort is placed on evaluations of EPA program effectiveness while only 20 percent is on
program economy and administrative efficiency. The reason cited by GAO for this situation
is that the bulk of EPA's budget is allocated to water pollution control construction grants
and Congress has expressed continued interest in the effectiveness of these grants.
To assure the most effective cooperation with EPA, the GAOEPA staff meets with EPA
upper management personnel at 6-month intervals to discuss priorities and receive guidance
on all investigations planned or underway. According to GAO personnel, topics including
solid waste management and resource recovery are discussed during these meetings.
Since establishment of the GAOEPA staff, GAO has studied the following aspects of
EPA's activities:
Programs related to automobile-caused pollution
Water pollution programs
Air pollution programs
Solid waste demonstration grant programs
Solid waste management practices at selected Federal facilities.
The latter investigation has two primary objectives. The first is a study of procurement
policies and practices employed by the General Services Administration (GSA) and the U.S.
Army and their effect on the generation of solid waste and recycling. Examples of specific
commodity procurements under investigation are returnable containers, recappable tires,
and paper containing recycled fibers. The second objective is to document the solid waste
management practices at representative facilities. Those agencies under study in this phase
are the U.S. Army, Forest Service, Bureau of Land Management (BLM), and the National
Park Service. The study is designed to determine present disposal practices.
In gathering information for this study, GAO interviewed pertinent agency
representatives in three different regions. The type of data amassed is indicated by the
following topics:
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Physical appearance of the disposal sites
Working conditions and personnel skill
Attitude of responsible personnel
Feasibility of eliminating disposal areas by combining nearby sites
Feasibility of practicing recycling.
Also considered, but to a lesser degree, were waste collection practices.
All field work has been completed and a draft report is in preparation. The study results
were not available since it is the policy of GAO not to release information until the affected
agencies have an opportunity for review and comment. GAO officials do indicate, however,
that they found solid waste disposal practices to vary considerably from agency to agency
and region to region. Also, GAO expects to include both specific and general
recommendations for improvement in the report. It was anticipated that an advance draft of
the report would be provided to EPA and that informal discussions between EPA and GAO
about this study would be held prior to the end of 1971.
GAOArmy Corps of Engineers Staff Activities
At the request of a Congressional committee, GAO is studying the manner in which
certain Federal agencies are implementing Section 203 of Public Law 91-190, the National
Environmental Protection Act of 1969 (NEPA). Section 203 calls for the preparation of
environmental impact statements for major Federal projects that could have adverse effects
on the environment. The Congressional request first specified that the Army Corps of
Engineers be studied by GAO to determine whether Congressional intent, expressed in P.L.
91-190, was in fact being implemented. GAO assigned its permanent GAOCorps of
Engineers satellite staff (analogous to the GAOEPA staff) to the project.
It was subsequently decided to broaden the scope of the investigation to include other
agencies and their activities with respect to NEPA. These were to include the following
seven agencies:
Department of the ArmyCorps of Engineers (civil functions only);
Department of AgricultureForest Service and Soil Conservation Service;
Department of Housing and Urban Development (new communities and urban
renewal programs);
Department of InteriorBureau of Reclamation;
Department of Transporation- Federal Aviation Administration and Federal
Highway Administration;
Council on Environmental Quality.;
Office of Management and Budget.
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The latter two agencies are being evaluated to assess their effectiveness in providing
assistance to operating agencies. Each of the other agencies is being investigated to
determine if environmental impact statements are being prepared as required.
Representative statements will be studied to see what factors were considered. GAO will
also determine the extent to which the impact statements are utilized by the agency as a
decision tool.
Investigation of field rather than headquarters level activities will be emphasized. One or
two field offices (as applicable) in each of the agencies will be studied. GAO plans to
prepare schematic drawings illustrating the decision points used in the preparation of
environmental statements. To facilitate this aspect of the study GAO will trace the
development of a select number of previously prepared statements from the project's
conception and initiation to statements preparation and distribution to necessary parties.
The .public hearing process will also be included.
The project was initiated in September 1971, and was expected to be completed by
January 1972. A final report was scheduled for release in April 1972. GAO has estimated
3,000 man-days of effort will be expended on the project.
In the opinion of a GAOCorps of Engineers staff representative, solid waste aspects
should be considered in environmental impact statements covering projects where solid
waste generation is significant. Accordingly, it is expected that this will be a
recommendation in GAO's final report.
Recommendations
The GAOEPA satellite staff should periodically review GAO audits and special
study reports to determine instances in which inefficient Federal agency actions
may, in turn, cause excessive solid waste generation.
GAO's audits and other studies are quite detailed and often identify agency
policies and regulations that are responsible for inefficient practices. Excessive
generation of solid wastes often results from these practices, as illustrated by
examples cited. EPA's Federal facilities activity could assist the agencies identified
by GAO in remedying wasteful practices and in encouraging resource recovery.
The GAOCorps of Engineers staff should specifically consider the solid waste
generation and recovery aspects of Federal projects during its present investigation
of environmental impact statements.
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CHAPTER VII
INTERSTATE COMMERCE COMMISSION
Abstract
Businessmen engaged in the recovery, processing, and sale of secondary materials have
frequently stated that existing freight rates are too high for the profitable transport of their
products. They point out that freight rates for competing materials originating from virgin
resource suppliers are lower. It is said that this alleged rate discrimination in effect causes a
reduction in the quantity of resources recovered from solid wastes and that freight rate
adjustments would stimulate recycling nationwide and correspondingly reduce waste
generation.
The Interstate Commerce Commission (ICC) exercises certain influence over the freight
rate structure in this country. In this chapter the alleged rate discrimination issue is
discussed, and the possible role of ICC in stimulating resource recovery through freight rate
manipulations is examined. Other potential ICC stimuli, in addition to rate adjustments,
such as granting special operating authority and conducting special investigations, are also
discussed.
Background
The Interstate Commerce Commission (ICC) was created under the Interstate Commerce
Act in 1887 to regulate carriers engaged in interstate surface transportation of people and
freight." Eleven Commissioners direct the various activities of the ICC, including:
Adjudication of issues related to rate and service changes and other factors
Rulings on applications for mergers, consolidations, and sales of transportation
companies
Prescription of accounting rules and railroad equipment usage
Administration of laws relating to railroad bankruptcy
Issuance of certificates granting motor carrier operating authority.
Regulatory control of transportation became necessary when, in the late 19th century,
railroads almost held a monopoly on transportation service. Cartels developed and
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undercutting, rate discrimination, and other practices detrimental to both the shipping
public and railroads themselves were prevalent. The Interstate Commerce Act, among other
things, prohibits unjust, unreasonable, and undue discrimination or preference to different
shippers for the transportation of commodities.
The ICC has regulatory control over all interstate railroads, 39 percent of motor carriers
and 19 percent of inland water traffic.100 Those carriers not regulated by ICC include
intrastate and company-owned trucks, railroads, and barges; carriers of certain agricultural
products; and barges carrying three or fewer bulk commodities. Intrastate movements are
regulated by State public utility commissions or similar agencies. Other carriers are not
regulated by ICC. The ICC budget for fiscal year 1971-72 was approximately $27
million.101
Relation of ICC to Solid Waste. The price of commodities reflects the raw material cost,
processing or manufacturing cost, and transportation charges. For some commodities, such
as secondary materials, transportation costs are a significant percentage of the secondary
material price. Thus, when freight rate increases occur, the F.O.B. prices of secondary
materials increase proportionately more than do prices of commodities for which relative
transportation costs are less significant.
The ICC follows specific procedures in its activities. Before investigating the possible
effects of this agency on movements of secondary materials, it is beneficial to outline the
rules by which ICC operates.
Rate Increase Procedures. The Interstate Commerce Act permits carriers to make rate
changes by publishing a tariff stating the new rates, filing the tariff with the ICC, and
posting the tariff in the carriers' freight stations. Ordinarily, rate changes cannot be made
effective until 30 days after the tariff is filed with the ICC.
If shippers or other interested parties feel that proposed changes in rates are unlawful,
they may file a protest with the ICC. If no protest is filed, the proposed rates may be
allowed to go into effect, although the Commission may act on its own motion to prevent
this. In the event that a rate change is protested, an investigation will be instituted whenever
there is reason to believe that the change proposed would be unlawful. If an investigation is
begun, the ICC may also suspend the proposed rate for 7 months beyond the date it is
scheduled to go into effect. Thus, when rate changes are proposed, the ICC may:
Take no action, thus allowing the rate to go into effect
Investigate, thus permitting the rate to go into effect subject to later revision by the
agency in the light of the evidence
Investigate and suspend, thus preventing the rate, or some portion thereof, from
going into effect during the course of the investigation, but the suspension may not
be longer than 7 months.
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These actions of the Commission may be appealed. If the rate change is suspended and/or
investigated, the decision after hearing, may be appealed within the Commission at least
once. When administrative remedies have been exhausted, the decision may be appealed to
the courts.
To the extent that the ICC can control rate increases, it has an effect on freight rates. It
has been alleged by shippers of secondary materials that the ICC hinders the recovery of
valuable resources by allowing the rates for shipment of virgin materials to be unreasonably
lower than the corresponding rates for secondary materials.
Since freight rates are determined through adversary proceedings, the issues involved in
such proceedings are examined herein to illustrate the influence ICC may exert on
secondary material freight rates. Iron ore and scrap iron and steel movement by rail will be
discussed as representative of secondary materials to illustrate alleged discrimination in
freight rates between virgin raw materials and corresponding secondary materials. These
materials were chosen because scrap iron and steel represent the most widely used secondary
material: 26.7 million tons were transported by rail in 1968.102 In 1969, approximately 95
million tons of iron ore moved by common carrier and industry-owned rail.103 Much of the
ore moves both by barge and rail according to railroad officials, as discussed in the section
Position of Railroads. The ICC has no authority over the rates governing the preponderance
of domestic water transportation. There is little compiled data available to indicate
transport rates of other competing virgin and secondary materials.
Motor carrier transportation was not investigated. Although most unprepared scrap is
hauled to scrap processing yards by truck, 74 percent of the processed scrap moves to steel
mills and foundaries by rail.104 Scrap industry representatives indicate that scrap iron can
sometimes be economically shipped by truck for distances up to 125 miles; however, there
is no rate discrimination reported for this mode of transport over these distances. In
addition, little iron ore and processed scrap move by motor carrier. Trucking officials
indicate that 11,800 tons of iron ore were moved by motor carrier in 1969.
Position of Scrap Iron and Steel Industry
Solid Waste and the Scrap Cycle. There are two basic sources of ferrous scrap: home and
purchased scrap. The latter includes both prompt industrial and obsolete scrap. Home scrap,
generated at the steel mills, normally does not leave the mill and is readily reused. Industrial
scrap is generally bought by the mills from fabricators for almost immediate reuse as a raw
material. However, fabricators sometimes cannot sell their scrap and have been known to
dispose of low-grade material as solid waste. Both home and purchased industrial scrap are
generated in concentrated locales and can thus be readily introduced back into the
steelmaking process.
On the other hand, obsolete scrap is generated at widely diverse locations, where
economic activity results in use and discard of steel-containing objects. Unless the price
received for obsolete scrap is sufficient to offset costs of collection, processing, and
transportation, the scrap will remain an unused resource, deposited in disposal sites and auto
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graveyards throughout the country. Obsolete scrap account;; for 23 percent of all scrap
used.105
Increasing the utilization of obsolete scrap depends on many factors. Presently,
steelmaking processes use varying amounts of scrap in manufacturing steel and cast iron.
The amount depends upon the type of process, market price and availability of materials
used in the process, and other factors. When the open hearth method of steelmaking is used,
a 30 to 50 percent charge of scrap (home, industrial and/or obsolete) is used. Molten steel
(referred to as hot metal but often mistakenly called pig iron) provides the balance. Basic
oxygen furnaces use a 10 to 30 percent scrap charge with the balance being hot metal.
Electric furnaces using up to 100 percent scrap are frequently found in the smaller mills,
especially those in the South.
Rail Transportation in Relation to Scrap Sales. Reference hereafter to scrap refers to
obsolete ferrous scrap, and the industry that handles obsolete scrap. Scrap processing
facilities are usually built with access to a rail line, as are most steel mills. Normally,
unprepared scrap is trucked to the processing yard and the prepared end-product shipped to
the steel mills by rail. Because most mills will not accept scrap delivered in trucks, scrap
processors are dependent upon railroads. The scrap industry contends that scrap and iron
ore directly compete for markets and that a basic competition factor favoring iron ore is the
dichotomy of transportation charges and services associated with each commodity.
Rates. The ICC generally supports the concept that differences in transportation rates
should not alter the competitive standing of the alternative inputs to any manufacturing
process. The scrap industry contends that rail rates are presently biased in favor of iron ore,
contrary to equity considerations. As a basis for this contention, the scrap industry
compared ICC data on the total revenue railroads received from ferrous scrap shippers and
the total weight hauled, cars used, and miles hauled in moving this commodity nationwide,
to similar data, also obtained from the ICC, for iron ore. The latest available data were for
1966. Table 5 presents the results of these comparisons made by regions.106 Table 6
amplifies the nationwide figures and shows revenues by other bases.107
Recognizing that iron ore has an iron content of approximately 60 percent, while scrap is
90 percent iron, the third column of Table 5 was computed to compare these commodities
in terms of a common parameteriron content. The iron ore revenue figures in the second
column of Table 5 were multiplied by (90/60) or 1.5 to give the tabulated figures based on
iron content, as shown in the third column. These are the revenues that the scrap industry
claims railroads should realize from scrap transportation if equitable rates were charged to
scrap shippers.
Since scrap dealers sell their product on a weight basis, the first column in Table 6 is
meaningful to the scrap dealer. It indicates that the railroads received an average of $0.206
per 100 Ibs or $4.12 per ton in revenues for hauling ferrous scrap in 1966. The
corresponding figures for virgin iron ore are $0.082 and $1.64, respectively. On an iron
content basis, the rate for scrap should be $2.46 per ton (1.5 x $1.64). The difference,
$1.66 per ton ($4.12 minus $2.46), represents the alleged discrimination against scrap iron
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shippers. In other words, on a weight basis, it costs about 68 percent more to ship the iron
content in scrap than in iron ore.
TABLE 5
RAILROAD REVENUE FOR SHIPPING IRON AND
STEEL SCRAP AND IRON ORE (1966)106
Revenue per ton ($)
Movements
National
Regions
East
South
West
Mountain
Scrap
4.12
3.78
3.76
4.40
4.02
Iron ore
1.64
2.22
1.90
0.93
2.54
Iron ore
corrected*
2.46
3.33
2.85
1.47
3.81
Discrimination
per ton
($)t
1.66
0.45
0.91
2.93
0.21
* Revenue on a per ton of iron content, computed by multiplying the revenue per ton of
iron ore by 1.5. The natural iron content of ferrous scrap averages about 90 percent and
averages about 60 percent for iron ore.
"*" Differences between 1966 revenue for iron and steel scrap and corrected iron ore rate.
Regardless of the basis of calculation, the figures in Table 6 illustrate that more income
was generated per Ib, per car, per car-mile, and per ton-mile by hauling scrap rather than
iron ore. Accounting for the differences in haul distances involved for scrap iron versus iron
ore shipments, Table 6 shows that the overall unit cost for shipping scrap was $0.02865 per
ton-mile, while the corresponding cost for iron ore (corrected for ferrous content) was
$0.01785 per ton-mile. Thus, on an average ton-mile basis, scrap iron costs about 35 percent
more than iron ore to ship. Therefore, according to the scrap industry, the rates for scrap
movement are, on the national average, too high to allow fair competition with iron ore.
Accordingly, all available obsolete scrap cannot be sold and an unknown quantity is
discarded as waste.
The preceding figures are artificial rates, calculated from revenue data to obtain an
indication of the average dollars paid for transportation by the scrap and ore industries. The
artificial rates are representative of actual movements and revenues averaged for the
country, and are more meaningful than published rates, insofar as the total freight costs
charged to all scrap processors, miners of ore, and steel mills are concerned. Published rates
may sometimes indicate that shipping charges for the two commodities are not so diverse, or
are more diverse, over specific routes using specific equipment. However, there is no
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indication that any actual movements are made over the designated routes at the published
rates.
TABLE 6
COMPARATIVE UNIT REVENUES REALIZED
BY RAILROADS IN 1966107
Average revenue per
Commodity
Iron and steel scrap
Iron ore
Iron ore based on
ferrous content
100 Ibs.
$
0.206
0.082
0.123
Car
$
218
125
NA
Car-mile
$
1.486
0.915
NA
Ton-mile
$
0.02865
0.01187
0.01785
Service. In addition to rate discrimination, scrap shippers complain that the railroads
provide inferior service to their industry. Major complaints include:
Excessive transit time
Terminal delays
Car shortages
Bad-order cars
Bunching of cars
For example, scrap moves almost exclusively by gondola cars. This class of rail car declined
in total numbers from 294,202 in 1955, to 192,238 in 1970, a 35 percent decrease.108
Also, railroads sometimes deliver cars in groups, rather than distributing delivery evenly over
a period of weeks. Scrap shippers usually require a steady supply of gondolas so that
processed material can be directly loaded into the cars. With bunching, the processed scrap
is sometimes handled twice, thereby increasing costs. Also demurrage charges are levied on
rail cars being loaded at the scrap shippers yard over a pieriod of time. Scrap shippers
contend that these problems significantly hinder the shipment of scrap.
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Position of Railroads
Railroad officials essentially agree with the data developed by the scrap industry. More
revenue is generated for each ton of scrap hauled than for iron ore. However, the carriers
believe their costs to move iron ore are less than for scrap. They can, therefore, charge less
to haul iron ore. Reasons cited for lower costs are:
Ore is frequently shipped in trainload lots on a prearranged schedule
Loading and unloading facilities for iron ore are highly mechanized, allowing cars to
be loaded more quickly than those for scrap.
Origin points for iron ore are limited, thereby allowing the railroads to readily
schedule future car use
Scrap may travel longer distances and/or over more expensive routes because scrap is
widely distributed geographically
By having more competitive charges for commodities being shipped in large
quantities, such as iron ore, the carriers will ship still larger quantities and thus
increase profits dollarwise, but with a lower profit as a percentage of sales. Price
elasticity is a major consideration in determining actual rates to charge.
Payload differences of hoppers (100 tons of iron ore) and gondolas (50 to 60 tons of
scran iron) allow more economical operation.
scrap iron) allow more economical operation.
In contrast to the scrap dealer, the rail carriers consider the unloading and loading costs,
distance hauled, payload of the rail car, and competing modes of transportation. Referring
again to Table 6, in 1966 the average revenue per car for scrap iron and for iron ore was
$218 and $125, respectively. On the basis of car-miles, the rates for scrap iron and iron ore
were $1.486 and $0.915 respectively, a 38 percent differential.
Movement of iron ore by rail competes directly with movement by water. In 1969, 95
million tons of iron ore moved by rail and about 127 million tons moved by water. Of the
water movements, 46 million tons were imported and about 81 million tons (85.6 million
tons United States and Canadian movements on the Great Lakes less 4.6 million tons
Canadian consumption in the Great Lakes region) moved on the Great Lakes.110' nl Since
the 1969 receipts of iron ore at United States iron and steel plants totaled 141 million tons,
much of the ore shipments were bi-modal.112 In fact, many movements may have entailed
two transfers, being shipped by rail from mines to the Great Lakes, barged across the Great
Lakes, and then moved by rail to the iron and steel mills.
In other cases, ore is barged directly to the mills, either after transfer from a deep-water
vessel, or from a rail siding. In some instances, rail carriers have attempted to compete with
barge carriers by setting exceptionally low rates. However, unless there are extenuating
circumstances, barge carriers with their high volume payloads and low unit costs, provide
the service. This illustrates that rail carriers serve a secondary (but vital) role to barges for
movement of iron ore, and exemplifies the competitive situation of the carriers.
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Furthermore, the railroads contend that scrap iron and steel do not directly compete with
iron ore, but with pig iron and crude metallic iron. Pig iron is a high iron content material
made by steel mills from iron ore, coke, and limestone from which steel is subsequently
manufactured. Its chemical constituents are similar to hot metal. Crude metallic iron is a
high iron content (90 to 95 percent) pre-reduced ore. It is mined and reduced in Canada and
Venezuela. Small quantities are being shipped to two new steel manufacturing mills. The
mills can process the ore without use of a blast furnace, making crude metallic iron highly
desirable as a commodity.
The railroads presented the following computation to show the total transportation
charges on the materials required to produce one ton of pig iron. These are prices for 1970
for the Eastern Region.113
Commodity
Iron ore
Coke
Limestone
Scrap iron
Total
Quantity
(tons)
1.800
0.730
0.220
0.056
Rate
(per ton)
$3.00
5.00
3.00
5.12
Amount
($)
$5.40
3.65
0.66
0.29
$10.00
The freight rate for scrap iron alone in the Eastern Region was $5.12 per ton, while the total
rate to transport all commodities needed in the production of one ton of pig iron was
$10.00. Therefore, the railroads felt that there was no rate discrimination against shippers of
scrap. Scrap industry representatives claim these computations are erroneous. Alternate
computations show that estimated freight rates in 1971 were about $6.13 per gross ton for
scrap compared to $4.47 per gross ton for iron ore (adjusted for iron content).114
Position of ICC
In its position as judge and jury, the ICC hears the contentions of both shipper and carrier
in regard to rate and service cases. Decisions by the Commission are based primarily on the
evidence presented at the hearings.
Section ISA of the Interstate Commerce Act specifies that carriers' rates be established to
generate sufficient revenue to allow the carriers to provide adequate and efficient service to
the public. If rates to ship certain commodities over given routes are not adequate to cover
the cost of service, rates for other commodities will have to be high enough to cover those
losses and still provide a reasonable profit.
According to officials representing the ICC, a rail carrier, and the scrap industry, there is a
trend toward establishing rates on the basis of cost of sendee. In judging rate reduction
requests, cost of service is normally the principal criterion considered by ICC. For rate
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increases, cost of service, including value of the commodity and other factors are
considered.
In requesting approval for rate changes, rail carriers and/or their freight bureaus normally
complete "Out-of-Pocket Rail Form A," either when the issue is introduced or during
adversary proceedings. This form is sometimes also used by protestants to show why rate
increases should not be allowed. Carriers other than rail carriers, or their rate bureaus, use
other standard forms for the same purpose. This provides a standardized format for
justifying costs, and facilitates review by ICC cost analysts. The ICC is not staffed to
perform audits of carriers' costs; their review is limited to analyses of carrier-supplied
figures.
Although the scrap shippers contend that the basic rate structure is discriminatory and
should be changed, this complaint has not been brought before the Commission for two
main reasons.
A complaint before the ICC to change a basic rate is a costly and lengthy procedure,
lasting possibly 2 years or more.
The burden of proof is on the challenger, making the case very difficult to prepare.
On the other hand, the railroads have proposed five general rate increases within the past
4 years. In these cases, the burden of proof is on the carriers to show cause why the increase
should be levied on a protestant's commodity. The scrap shippers contend that an
across-the-board percentage rate increase on iron ore and scrap iron alike would result in
further increasing the difference in rates between the two commodities. For example, a
10-percent increase in a $5-per-ton rate and a $3-per-ton rate will result in new rates of
$5.50 and $3.30 per ton, respectively. Whereas before the increase, the difference in rates
was $2 per ton, after the increase the difference would be $2.20. Shippers requested ICC to
grant a hold-down on the rates for scrap iron so that the percentage rate increases for iron
ore are greater than for scrap, but the actual increases, on the average, would be no more
than the average increase on iron ore.
In two of the recent general rate increase hearings, Ex Parte No. 256 and Ex Parte No.
25 9, the ICC partially recognized the complaints of scrap shippers and granted hold-downs
on scrap iron and steel rates, while allowing maximum increases for iron ore shipments. In
Ex Parte No. 265 a $0.15 hold-down on scrap was voluntarily introduced by railroads in the
South, but this was later rescinded. Action taken during the most recent proceedings, Ex
Parte No. 267, is briefly described below.
Ex Parte No. 267. The railroads requested a general rate increase of 15 percent.
Responding to scrap iron and steel dealers who requested hold-downs, the ICC noted the
following. "Between 1961 and 1966, when there were no general freight rate increases, the
price of scrap fluctuated between $24 and $39 per ton. The price of No. 1 heavy melting
scrap increased from $27.64 per gross ton in 1967 to $43.50 in 1970, an increase of nearly
60 percent, in spite of the increased freight rates during that same period. The prices of pig
iron and iron ore advanced only slightly."115 The Commission was not persuaded,
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therefore, that rail freight rates have any significant impact on the "decisions which result in
removal of wrecked automobiles and other scrap metals pursuant to antipollution
measures."116 In the same proceedings the Commission noted:
The National Environmental Policy Act of 1968 (P.L. 91-190) expresses the concern
which the Federal Government and the Nation as a whole have with control of
activities which result in pollution of the atmosphere a.nd environment. Our attention
has been called to the possibility that increases in freight rates and charges may tend to
restrict the movement of scrap and waste materials and thus, indirectly, detract from
efforts being made to gather and recycle such materials. We are urged to take into
consideration, in proceedings such as this, the need for encouraging the shipment of
pollutants such as scrap iron and steel, nonferrous scrap and alloy scrap, petroleum
wastes and other secondary materials.
It is unnecessary to elaborate upon the importance of the program instituted by the
National Environmental Policy Act, or the severity of the problems with which it is
concerned. We share that concern and, to the extent that it lies within our statutory
authority, propose to assist in the implementation of the objectives of the act .... At
the same time, we deal with the national need for a viable transportation system, and
the constitutional rights of all parties to these proceedings to a full and fair hearing and
a decision based upon the evidence of record.117
Furthermore, the ICC has taken the position that the transportation industry should not
support the control of pollution created by other activities of the economy by providing
shipment of waste materials at or below the cost of service. However, the Commission
believes "that the transportation industry, like other segments of the economy, must
contribute to the control of pollution."118 Accordingly, the rate increase applied to iron
and steel scrap was limited to 11 percent, versus 14 percent for iron ore. Pig iron was also
subject to this lower rate increase for equity purposes. Interestingly, the 11-percent increase
on scrap amounted to $0.61 per gross ton while the 14-percent increase on iron ore
amounted to $0.40 per gross ton, a 1.51 ratio.119 This figure is also the average ratio of
iron content in scrap versus iron ore.
In addition to iron and steel scrap, the ICC granted lesser rate increases for the secondary
commodities shown below.120
Maximum permissible
Commodity increase (%)
Fly ash 8
Petroleum waste products 8
Nonferrous scrap 11
Textile scrap 11
Paper scrap 11
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It is interesting to note that the Department of Transportation (DOT), testifying in Ex
Parte No. 267, urged that the requested full rate increases be approved. DOT noted that the
railroads' revenue needs were well documented. Even if full rate increases were granted,
according to DOT, the rate of return on investment would remain below levels necessary to
assure railroad service improvements.121
Overview of Scrap Iron and Steel Shipping
It appears that the ICC has taken preliminary steps to establish freight rates for
transportation of secondary materials at levels to encourage resource recovery. However, in
proceedings granting a rate increase for secondary materials that was less than that generally
applied to most other commodities, the Commission noted that "there is no basis in the
evidence for finding that the proposed (full) increase on iron and steel scrap will be
detrimental to the antipollution program (sic) because of any resulting advantage to the
movement of iron ore."122 Yet a partial rate increase for ferrous scrap was approved so
that, ostensibly, more scrap would move from disposal sites to markets for reuse. The
implication is that steel manufacturers would demand more scrap for its processes if total
delivered scrap prices were lower than competing raw materials. Since the only other source
of raw ferrous material for steelmaking is iron ore, the implication noted above is in conflict
with the ICC's statement that "scrap iron and iron ore (do not) specifically and directly
compete . ,"123
Unfortunately, no information is available to indicate the total quantity of ferrous scrap
(or any secondary material) that would move toward recycling or reuse (rather than as litter
and for disposal) if the ICC were to determine that iron ore and scrap compete directly and
were to act accordingly to equalize the freight rates. The development of such data was not
within the scope of this project. The Institute of Scrap Iron and Steel is reportedly
developing such estimates by computer analysis, but the results were not to be available
until late 1971.
A Department of Commerce study in 1966 indicated that "the full amount of most types
of ferrous scrap originated is consumed, as well as about 85 percent of automotive and
similar scrapable materials."124 Assuming a high estimate of 20 million total out-of-service
automobiles in salvage yards and in numerous unauthorized locations throughout the
country and 1 ton per automobile, there are 3 million tons of scrap iron and steel which
would remain unrecovered. Rate adjustments could result in the reclamation of additional
amounts of scrap iron and steel and tend to reduce the 20-million ton backlog of scrap. On a
yearly basis, a 15-percent increase in recovery of automotive scrap could yield an estimated
0.90 million tons per year additional ferrous scrap recovered (based on 6 million autos
junked per year). However, recovery of out-of-service automobiles is a complex subject
which is dependent upon many factors in addition to freight rates. For example, reducing
rail freight rates by $1.66 per ton, or even eliminating all rail transport charges, probably
would not achieve 100 percent recycle of automobile hulks. Such savings to the scrap
processor would not be enough to warrant delivery of all out-of-the-way junked automobiles
to the processor's yard. The amount of unrecovered ferrous scrap represented by auto hulks
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is relatively small compared with its rate of domestic use and export, which totaled 36.9
million tons in 1969.125 However, it was reported by the ferrous scrap industry that a
recent study has concluded that, "national availability (of feiTous solid waste) indicates a
calculated amount approaching 750 million tons."126 Since the report was not available to
the study team at this writing, the present discussion does not reflect the alleged existence
of this large scrap backlog.
ICC's attention to the National Environmental Policy Act (NEPA) and its expressed
position that environmental matters will be considered in future acts are promising signs. If
information indicating rail freight rates hinder the recoveiy of scrap iron and other
secondary materials is developed, the Commission will have the1 data required for analysis of
the problem and effects of alternative actions.
A Supreme Court decision, Baltimore & O. R. Co. v. United States, 345 U.S. 146 (1953),
paved the way for the ICC to approve freight charges that do not necessarily cover the cost
of providing the transportation service:
As long as rates as a whole afford railroads just compensation for their overall
services to the public . . . the fixing of noncompensatory rates for carrying some
commodities when the public interest is thereby served (is not barred).127
Future studies may indicate that scrap and waste materials would be recycled to a greater
extent than at present if transportation charges were altered. If so, ICC is legally empowered
to act to effect a reduction in rates below the cost of service in those instances in which
rates as a whole are providing overall just compensation and in which such recycling would
come within the Court's view of the public interest.
Paper and Timber Freight Rates
No compiled nationwide data were available on movement of waste paper, pulpwood and
related commodities. Meaningful data showing whether there is discrimination in shipping
charges between secondary paper and its "competing" pulpwood are difficult to develop.
The bulk of pulpwood movements are intrastate and/or less than 125 miles, whereas scrap
paper and newsprint moves are considerably longer and are most often interstate. The latter
moves are usually from urban areas to relatively remote plants. The major discriminatory
factor appears to be the fact that longer moves are required to transport waste paper to
processing plants than required for pulpwood.
Representative rail rates were obtained from Southern Railway System for movements of
pulpwood, pulpboard, scrap paper and newsprint. The rates shown in Table 7 are from
straight mileage rate schedules except those for newsprint, which were derived from
point-to-point quotations.
On initial examination it appears that the rates for pulpwood are discriminatory against
waste paper and pulpboard. However, about 3 Ib of pulpwood are required to manufacture
1 Ib of paper, whereas 3 Ib of scrap paper are used to produce 2 Ib of paper. Furthermore,
pulpwood is shipped in open rack cars, which are less costly to operate and maintain than
general purpose box cars used to ship paper.
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TABLE 7
REPRESENTATIVE RAIL RATES*
PulpwoodJ
Miles
50
100
150
200
250
300
350
400
450
500
Scrap Paper t
13
18
22
23
31
32
35
38
40
40
Logs
6.4
8.6
9.6
11.9
13.3
15.5
16.9
18.9
20.4
22.5
Chips
6.4
8.6
10.0
12.2
13.7
15.9
17.4
19.6
21.1
23.4
Newsprint §
A#
21
26
32
37
42
44
53
57
61
65
B**
12.5
16.5
19.0
22.0
25.0
26.0
32.0
33.0
36.0
38.0
PulpboardK
Ctt
18
22
29
33
36
39
45
48
53
55
D*t
13
17
20
22
25
29
33
35
37
39
* From Southern Railway System, X267-B level, (
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Pending ICC Action
Three rulemaking procedures which have a bearing on solid waste recovery with respect
to transportation have recently been concluded or are presently under study by the
Commission.
Ex Parte No. M.C.-85. Recognizing that transportation is a necessary facet of any
successful recycling program, the ICC has approved procedural changes to assist such
community activities. Most for-hire motor carriers under the jurisdiction of ICC do not now
have authority to haul reclaimed waste products from recycling centers to processing plants.
Under standard ICC licensing procedures, motor carriers wishing to obtain this authority are
required to submit numerous forms and wait several months for certification. To encourage
motor carriers to participate in recycling programs, the ICC instituted special licensing
procedures to simplify the filing and certification process. The Commission has taken this
action based on a finding of public convenience and necessity considered on a national
scale.128
Ex Parte No. 55 (Sub-No. 4). In response to the NEPA, the ICC initiated this rulemaking
procedure to determine "-how this agency can best implement the national environmental
policy and meet its statutory obligations."129 The Commission has stated:
It is the goal of this proceeding to develop the procedures necessary to implement the
national environmental policies expressed in NEPA and related statutes and
requirements. We intend to adopt special procedural rules and guidelines which will
best enable us to come to grips with those environmental matters which are within our
regulatory jurisdiction.130
Specifically, the Ex Parte finding requires that a detailed environmental impact statement
be prepared when any regulatory action having a significant environmental impact is
considered. The form and content of the statement will follow the general guidelines
promulgated by the Council on Environmental Quality. In all initial papers filed with the
Commission, the filing party must file a statement indicating the presence or absence of any
effect of the decision on the quality of the environment. In proceedings that have a
significant effect on the environment, all parties must file statements detailed to the fullest
extent possible.
Ex Parte No. 55 (Sub-No. 4) was decided on January 14, 1972. Determinations in all
proceedings that significantly affect the environment will include an evaluation of
environmental factors, as outlined in Section 102 of the NEPA, in conjunction with other
economic and technical considerations. The Ex Parte finding is prepared in the broadest of
terms, with minimal reference to specific elements to be considered in the statement.
Ex Parte No. 270. Scrap iron and steel processors are among the many shippers who have
expressed complaints about the basic rate structure charged by railroads. Because of
widespread Congressional and public interest in freight rates, ICC has initiated an
investigation into the entire basic rate structure in Ex Parte No. 270.
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This Ex Parte proceeding was initiated late in 1970. Interested parties were advised of the
proposed investigation and requested to submit their comments. The ICC is evaluating the
many responses and has initiated the first procedure, referred to as Sub-No. 1, which is
limited to studying transportation aspects at Great Lakes ports.
The other specific topics to be studied have not yet been identified. Only two
representations were filed with respect to recyclable solid waste. One was filed by a private
individual, and the other by the Institute of Scrap Iron and Steel, Inc. It is impossible to say
at this point whether the investigations will encompass the subject of the effect of rates on
recyclable and reusable commodities.
Recommendations
The ICC should sponsor a thorough study of the effects of freight rates on
secondary material recovery and marketability.
The present discussion only touches the surface of the issues. There is need for an
in-depth investigation of the relationships involved between rates and recycling. An
ideal mechanism is available, Ex Parte 270, through which the ICC could support an
independent study of the problem. If funds are unavailable for such work, a special
request to Congress for support is deemed appropriate, given the importance of the
issue in relation to the environment and the national transportation policy. There is
not now sufficient information available to definitively state whether freight rates
do or do not influence resource recovery activity.
The ICC should grant preferential rate increases or rate hold-downs for secondary
materials if it is determined through hearings and studies that recovery of such
material will increase significantly due to freight rate adjustments.
Rates that do not cover the carrier's costs are only permissible when the overall
rate structure provides the carriers an adequate rate of return. At present rail carriers
are experiencing low earnings in general. Thus, preferential rates for shipment of
secondary materials would necessitate rate increases for other commodity classes.
Pending resolution of the freight rate/scrap movement question, the ICC should
continue to follow the present procedures in determining the suitability of rate and
service charge requests.
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CHAPTER VIII
NATIONAL BUREAU OF STANDARDS
DEPARTMENT OF COMMERCE
Abstract
The National Bureau of Standards (NBS) represents the public interest in the
development of voluntary standards for consumer products. Although NBS is not solely
responsible for such standards development, the agency's influence is significant; NBS often
assumes a leading role in standards development. Solid waste recovery has been hindered
because limited markets exist for the recovered material. One reason given for the poor
market condition has been questionable reliability of secondary materials. NBS is one
agency in the government that could contribute toward development of standards for
secondary materials which could stimulate the market considerably. Other related NBS
activities are discussed that could influence solid waste generation and recycling.
Background
As its name implies, NBS is the focal point within the Federal Government where a
complete system of physical measurement is maintained against which to gauge and
calibrate all instruments and measurement devices. The particular activity related to basic
measurement standards is most often associated with NBS work in popular literature.
However, NBS has certain responsibilities in relation to consumer product standards that are
not as widely recognized. These other responsibilities are investigated in this chapter, and
the relationships with solid waste recycling and generation explored.
All NBS activities are carried out within five organizational components as briefly
described below.131
Institute for Baste Standards. Maintains a complete and consistent system of
physical measurement and provides services to assure that accurate and uniform
measurements are used throughout the country.
Institute for Materials Research. Investigates improved measuring techniques and
properties of well-characterized materials. Relates physical and chemical properties
of materials to their behavior.
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Institute of Applied Technology. Provides technical services to promote the use of
available technology and to facilitate innovation in industry and government.
Cooperates with public and private organizations in developing technological
standards and test methods.
Center for Radiation Research. Studies use of radiation in attaining missions of NBS.
Center for Computer Sciences and Technology. Provides support for NBS and other
government agencies and studies best uses of computational equipment.
The NBS was established in 1901 as an agency of the Department of Commerce. Most of
NBS's activities are carried out at its Gaithersburg, Maryland, facility. Its fiscal year 1972
budget was approximately $47.5 million.132
Each Institute and Center contributes to the development of standards, test methods, and
related technologies. Besides developing and maintaining the basic standards used in all
measurement, NBS cooperates with private and public associations in developing product
standards, building codes, and trade practice procedures. These standards can influence
secondary material usage and thereby affect the quantity of solid wastes recovered for use.
Standards Development
Standards are developed in the United States primarily through a private, voluntary
system. Standardization and quality control measures are processed through this voluntary
system, in which NBS plays an advisory, or, at times, a leadership role. The following list
illustrates some of the standards-types that are commonly developed:
Industrial products
Consumer goods
Test methods
Definitions and symbols for technical quantities
Safety criteria.
In certain cases, the public need is so great that Congress may act to require development
of safety standards. Mandatory standards development is usually spearheaded by NBS, but
enforcement is the responsibility of other Federal agencies, such as the Federal Trade
Commission. For example, NBS was working on fabric testing procedures so that mandatory
standards for fabric flammability could be established, as called for in the Flammable
Fabrics Act of 1967.
A primary concern of NBS is the establishment of voluntary standards for items to
protect the public interest. To this end, NBS cooperates with consumers, distributors,
producers, and others in developing standards for important product parameters. Such
organizations as the American National Standards Institute arid the American Society for
Testing Materials are actively engaged in voluntary standards development. In 1970, NBS
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was working in direct cooperation with over 1,000 committees to develop voluntary
product standards.133 Since voluntary standards, are developed in cooperation with
industry, compliance is generally widespread among the affected manufacturers and users.
Voluntary product standards presently exist for various consumer commodity classes,
such as those listed below:
Apparel sizing
Building products and dimensions
Electrical equipment
Hardware
Household supplies
Packaging sizes and quantities
Petroleum products
Plastics content
Only certain specific items in each commodity class are covered by voluntary standards.
For example, under the title "Building Products," voluntary standards exist for the
following items, among others:
Standard stock light-duty 1 3/8- and 1 3/4-in.- thick, flush-type interior steel doors
and frames
Copper conductors for building purposes
Accoustical material
While review of all voluntary product standards was beyond the scope of this project, a
sampling indicated that no restrictions exist that prohibit the use of secondary or reclaimed
materials in any product. Where material requirements are delineated, the requirement is
that the material be suitable, regardless of its source.
A major portion of the effort in developing a product or trade practice standard is
expended in research activities. The research work is sometimes only indirectly related to
the ultimate objective of standard establishment. Consequently, the results can have
significant spin-off value in other technological fields. For example, although not originally
initiated by NBS to solve solid waste problems, certain on-going investigations have possible
application in resource recovery efforts, as briefly described below.
Thermal Decomposition of Hydrocarbons,13* The primary steps of the pyrolytic process
are being studied by the Institute for Materials Research to help explain hydrocarbon
combustion and the cracking process. It is anticipated that an accumulation of data on the
pyrolysis of carbon compounds will be gathered. Since municipal solid waste contains high
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concentrations of carbon, this study is applicable to the development of a pyrolysis system
for recovering the energy value from solid waste.
Quantitative Microscopy.13S Automatic microscopy techniques are being developed by
NBS's Institute of Material Research to aid in determination of the amount, size, shape, and
arrangement of particles in metal alloys, ceramics, minerals, and composites. These factors
influence material performance characteristics. Such a system for analyzing these features
would be beneficial in assessing the suitability of materials containing secondary materials.
NBS was active in two specific areas relative to standards that more directly affect solid
waste generation and reuse. These are discussed in the following two sections.
Building Codes
Most structures constructed in this country must be erected in conformance with a local
building code. Such codes set forth the minimum acceptable design criteria to assure that
buildings are safely constructed. The suitability of construction material is one specific topic
delineated in building codes. It has been suggested that restrictions thereunder prohibit or
discourage the use of materials reclaimed from solid wastes in construction. The veracity of
this allegation and the role of NBS with respect to building code development and use is
examined below.
NBS serves as Executive Secretary to the National Conference of States on Building
Codes and Standards (NCSBCS). The primary goal of this organization is to foster the
development and use of national standards suitable for the advancement of interstate
reciprocity of product evaluations. There are now four model codes used in the United
States, each differing in certain respects. These are the Southern Standard Building Code,
issued by the Southern Building Code Conference; National Building Code, issued by the
American Insurance Association; Uniform Building Code, issued by the International
Conference of Building Officials; and the Basic Building Code, issued by the Building
Officials and Code Administrator International. Most local government entities have
adopted one of these codes for use. However, many local agencies add special provisions and
delete others from the model code so that, in reality, there are thousands of different
building codes in existence. In the process of localization, some standardization features of
the model codes, including materials standards, may be subverted.
The four model codes themselves contain few prohibitions against the inclusion of used
materials in building construction as long as these materials are determined to be equal in
performance to new materials. It has been reported to NBS officials, however, that locally
developed or locally modified codes often prohibit use of secondary materials.
Even where local code modifications do not alter the model code material standards
features, it has been found that local interpretation of the criteria results in effectively
excluding secondary material from use. This is so because there is no reliable means by
which to quickly assess the soundness of used material.
NBS interest in building codes presently centers around code restrictions concerning
industrialized housing. Local building code variations have hindered efforts of residential
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building companies to erect low-cost housing using factory production techniques.
Standardized sizes, materials, and fabrication techniques are important to assembly line
production. Extra effort and cost are incurred by housing companies to design and
construct standardized housing so that they conform with various localized codes and can
therefore be marketed in a sufficiently large area to realize a profit.
The Department of Housing and Urban Development (HUD) has endorsed industrialized
housing construction as an effective means by which to realize the Nation's housing goals.
HUD, under its Operation Breakthrough program, has consequently enlisted the aid of NBS
to help establish the feasibility of applying the performance concept to the problem of
evaluating building innovation, particularly in relation to architectural design features of
factory-built housing. NBS, with the support of HUD, is working with NCSBCS to explore
this approach as an aid in the economical production of housing. Hopefully, performance
standards in the form of Operation Breakthrough Guide Criteria will be used to replace the
Federal Housing Administration's Minimum Property Standards in selected housing projects.
The use of performance standards for construction materials could encourage the use of
secondary materials. Regardless of the origin of the material, if its performance
characteristics meet certain set minimum criteria, it would be acceptable for use. It is
expected that applicability of the performance standards presently under development will
initially be limited to factory-type housing. Administration, enforcement, and interpretation
problems are too severe to attempt more widespread use by building code jurisdictions at
this time. Eventually, NBS hopes that performance standards will be adopted to supplement
present materials criteria in building codes.
NBS began studying performance standards for building materials and construction
techniques used in industrialized housing in late 1970. Generally useful results are expected
in 2 or 3 years. Limited results may be available sooner. Although these performance
standards are being developed specifically for use with the HUD Operation Breakthrough
program, they could have beneficial effects on resource recovery efforts. Performance
requirements of materials will be specified rather than material properties.
NBS is discovering many areas requiring the development of appropriate performance test
methods for new materials. They are also finding it difficult to develop tests providing
accurate prediction of performance limits for materials and composition of materials.
Adding the additional constraint of secondhand materials would not make the undertaking
impossible, but it would certainly increase the difficulty. The priorities of NBS do not
include development of performance requirements and test methods adaptable to both new
and secondary materials.
Packaging
A method of reducing total solid waste generation, especially from municipalities, is to
reduce packaging waste quantities. Packaging wastes represent approximately 13.3 percent
of the 350 million tons of residential, commercial and industrial solid wastes generated in
1966.136 NBS has working relationships with most manufacturers of the packaging
materials and package users and also administers sections of the Fair Packaging and Labeling
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Act (FPLA). However, the FPLA does not give NBS the power to regulate package design.
Its authority under the FPLA involves the prevention of "undue proliferation of weights,
measures, or quantities."
NBS personnel indicated that some thought had been given to the establishment of
voluntary packaging standards wherein use of those materials that are difficult to recycle
would be discouraged. Also overpackaged products, that is those commodities with more
packaging than necessary to contain the product, would be discouraged. Existing
relationships with packaging and packaging material manufacturers would facilitate this
work. However, no definite plans to initiate such a standardization program have been
proposed.
Other NBS Interests in Solid Waste Matters
In response to the increasing national interest in solid waste management problems, a
group of NBS personnel formed an ad hoc study committee to determine how NBS
capabilities relate to the problems of solid waste management. Each of the five Institutes
and Centers were examined to identify how they could contribute to this effort. The
committee produced a report outlining 39 solid waste-oriented projects for which NBS
capabilities are suited.137 Twenty-four proposed projects pertain to solid waste generation
and recovery. The descriptions of all 39 projects discussed in Reference 137 are brief and
only conceptual in nature. Following are discussions of the more promising proposed
projects:
Scrap Tolerance Levels.138 Currently there are no standards to establish the proper mix
of secondary and virgin materials required for an acceptable end product. Manufacturers of
such products tend to exclude scrap in their product mix if there is any doubt as to the
integrity of the final product. Technical work carried out by NBS could lead to the
establishment by others of a tolerance standard for scrap mixed with virgin materials. The
existence of such a standard may lead to increased usage of secondary materials in industry.
Processing and Quality Control.139 It has been estimated that approximately 15 percent
of the annual quantity of automotive and similar scrap is strewn about the countryside,
accumulated in junk yards, or discarded at disposal sites.140 Although there are numerous
reasons why this scrap is not presently reclaimed, one pertains to scrap quality. If processed
scrap quality can be improved and/or assured, an increased demand from consumers (steel
mills in the case of scrap iron and steel) should be expected. Accordingly, research
conducted by NBS on the effects of impurity (tramp element) build-up on the properties of
materials produced could lead to the establishment of processing and quality control
standards. Such industries as auto wreckers and scrap processors could utilize these
standards, and thereby encourage a greater degree of recycling.
Architects Design Standards.141 To assure that onsite solid waste storage facilities are
adequately designed, development of appropriate architects and builders standards was
considered. Solid waste storage facilities are usually given little attention during the design
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of commercial buildings and large apartment complexes. As a consequence, these facilities
are often inadequate, resulting in unsanitary and/or unsightly conditions. Without
adequately planned waste storage facilities, waste recovery (if desired) is hampered.
Product Performance Standards.142 A more complex task that was considered involves
the development of product performance standards. According to secondary materials
industry representatives, the market for reclaimed materials must be expanded and assured
to achieve a significant degree of resource recovery. Because of the widespread feeling that
used materials or products composed of used materials are of inferior quality, the market
for reclaimed materials is presently limited. In addition, engineering design criteria are based
on accurate knowledge of the properties to be used. If such accurate information does not
exist, as is often the case with used materials, preparation of sound designs is a difficult
endeavor. (See similar discussion in Chapter IV, Federal Trade Commission.)
In many products, however, the presence of secondary materials does not render the
product inferior. Standard testing and certification procedures to measure the performance
characteristics of consumer products, regardless of the source of the constituent materials,
would establish a rational basis of choice between competing products. It is possible that
many products manufactured from reclaimed materials are equivalent in performance
characteristics to products made from 100 percent virgin materials. The consumer should
not make his purchasing decision based on the origin of constituent materials but on
certified performance criteria.
Material Recovery Techniques. Through other projects NBS has studied various material
properties. The knowledge gained through these studies can be applied in part to the
solution of such problems as solid waste classification and subsequent reprocessing. The
following examples are illustrative.
NBS has investigated the properties of fabrics and synthetic materials. Such study is
applicable in devising methods whereby textiles, with their increasing synthetic
composition, can be reclaimed.
NBS has conducted many studies of plastics and their properties. The various types
of plastics present in municipal solid waste cannot be reused when mixed together.
NBS officials feel that methods by which polymer plastics are reduced to monomers
would advance plastic reuse technology.
In conjunction with the ongoing research activities on paper, NBS personnel can
work towards development of easily removable inks to facilitate reuse of paper.
Development of methods for reclaiming rubber in discarded tires and uses for this
rubber is also within the capability of NBS, according to officials.
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Recommendations
NBS should encourage packaging users and manufacturers to minimize the use of
unnecessary volumes of packaging and/or materials that are difficult to recycle.
NBS has a close working relationship with packaging manufacturers and users.
NBS encouragement may be beneficial in effecting a reduction in the packaging
component of solid waste. Since packaging comprises nearly 20 percent of all
residential and commercial solid waste, a reduction of 20 percent in packaging
quantity would represent a 4-percent overall reduction, or 10 million tons per year.
If voluntary action leading to volume reductions cannot be attained, consideration
could be given to amending the FPLA so that mandatory design restrictions are
possible.
EPA should guide NBS in developing test methods and performance criteria for
secondary materials by establishing priorities on those materials deemed most
beneficial for reuse.
Prior to initiating research leading to establishment at performance criteria and test
methods for specific materials and commodities, the scope of the required effort
should be determined and compared with the potential benefits.
In conjunction with its work on building code standardization, NBS could
possibly initiate limited efforts to establish testing procedures that can be used to
determine the suitability of secondary materials for construction purposes. If such
procedures exist, building code stipulations that used materials be "sound" can
possibly be met, and thereby the inclusion of secondary materials in building
construction increased.
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CHAPTER IX
OFFICE OF COMMUNITY DEVELOPMENT
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Abstract
The Office of Community Development (OCD) has been assigned responsibility for the
Department of Housing and Urban Development (HUD) programs concerning the urban
community. A significant phase of urban redevelopment is the removal of existing structures
or parts of structures. The least costly and most widely practiced removal method is simply
demolition and disposal. The large quantities of solid wastes generated impose a burden on
local disposal facilities during the redevelopment project period. Accordingly HUD was
studied to determine how it affects demolition waste generation and how it can encourage
beneficial reuse of these waste materials. Certain OCD programs relate to building code
enforcement and standardization. To the extent that building codes influence solid waste
recycling and utilization, the OCD can be influential in encouraging resource recovery.
Background
Title I of the Housing Act of 1949, as amended, is the basic law authorizing Federal
assistance for urban renewal. A series of amendments over the years have broadened the
objectives of the original program.143 In 1965 HUD was established by the Department of
Housing and Urban Development Act.
The basic HUD programs administered by OCD can be categorized as model cities, urban
renewal, rehabilitation loans and grants, open space land and related programs, community
facilities, and planned variations. Urban renewal activities are further subdivided into the
following activities:
Urban Renewal Program
Neighborhood Development Program
Code Enforcement
Demolition Projects
Interim Assistance
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Neighborhood Renewal Plans
Feasibility Surveys.144
This study of OCD has been limited to the first five of these activities. Neighborhood
Renewal Plans are a tool used for study of large or complex urban areas prior to renewal
activity. For such areas a preliminary plan is prepared defining the needs and specific
programs for implementation. Feasibility Surveys may be authorized when there are
questions as to how a contemplated urban renewal project can be executed.145 Since
neither of these involve implementation, there is no direct interface with solid waste
generation. Consequently, Neighborhood Renewal Plans and Feasibility Surveys are not
discussed further in the report.
As shown below less than one-half of the approved expenditures for urban renewal
activities had actually been disbursed since inception of the respective programs.146
Cumulative
funding ($ millions)
Activity Approved Disbursed
Urban Renewal Program
Neighborhood Development Program
Code Enforcement
Demolition Projects
Interim Assistance
Totals
$7,619
1,014
245
22
13
$8,913
$3,476
406
86
5
5
$3,978
This indicates that planning activities had been done and funds obligated, but the projects
had not yet been fully implemented. Personnel in OCD indicated that annual urban renewal
funding approvals during recent years had averaged about $1 billion. Subsequent budgets are
anticipated to rise to $1.5 billion or more annually.
In a public or private project, participation by HUD is limited to providing assistance,
support, and incentives. Furthermore, HUD controls ongoing renewal work only through
the mechanism of approvals; i.e., HUD requires assurances that Federal money and services
are properly expended in the public interest prior to approving disbursements of funds. It
does not impose authority beyond that point, nor does it accept responsibility for
redevelopment and related activities.147 Actual responsibility for investment, construction,
operation, and maintenance of housing and allied programs rests with the direct participants
in the projects: State and local government, nonprofit groups, investors, builders, and
individuals. HUD assistance is provided in the form of loans, grants, subsidies, insurance,
guidelines, and technical advice.
Field operations of HUD are conducted through regional and area offices. There are 10
regional offices and as many as eight area offices in each region. The regional offices are
responsible for supervising and coordinating area office activities on a regional basis. The
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area offices review and process applications, provide field assistance to public bodies, and
monitor projects to assure compliance with HUD policies and requirements. Policy, research
and development, and other support activities are provided by the headquarters staff in
Washington, D.C.
Urban renewal activities supported by OCD programs have been identified as influencing
solid waste generation and reuse. The influence relates to demolition of structures and
public facilities and disposal of the debris. The OCD requirement that a recipient of HUD
funds have adopted a building code also influences solid wastes as these codes often prohibit
the use of secondary materials. In addition, overall HUD policy toward the environmental
impact of OCD-supported projects also influences solid waste generation and reuse. These
influences will be discussed in the following sections.
Demolition of Structures
The OCD provides grant assistance to local planning agencies for urban renewal activities.
An important aspect of urban renewal is site preparation. In many cases the designated
renewal area is in an older section of a city where poorly-maintained and deteriorating
buildings exist. This area must either be selectively cleared of the old buildings or
completely cleared before renewal activities begin.
The basic goal of urban renewal activities is to eliminate and/or prevent deterioration and
blight in urban areas. In funding these projects OCD weighs factors such as the degree to
which the housing supply for low- and moderate-income families will be increased and the
potential for employment opportunities in the planned renewal area improved.
Regardless of OCD's commendable priorities and immediate goals, urban renewal activity
does generate significant quantities of solid waste materials in the form of demolition debris,
street rubble, and old utilities. This material is generally wasted and represents an acute
environmental problem as well as a loss in irreplaceable resources.
Urban Renewal Program. The Urban Renewal Program is the largest single program within
OCD. Currently highest priority is assigned projects that conserve and upgrade property. In
years past, urban renewal generally involved the complete clearance of an area and
replacement with new buildings. This technique often changed the character of the area.
Now OCD is placing more emphasis on improving existing housing and removing only those
buildings that are beyond repair. Thus, the quantity of demolition debris generated by
urban renewal projects now should be somewhat less in terms of tons per acre of project
area than during earlier years.
To qualify for Federal assistance under this program, an applicant must have a specified
number of deficiencies that require action. For example, at least 20 percent of the buildings
in the designated urban renewal area must contain one or more building deficiencies and the
area itself must contain at least two major environmental deficiencies.148 Alternatively,
more than 50 percent of the buildings must be substandard structurally to a degree requiring
clearance.
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Urban renewal projects are conducted in two parts: Part I, Survey and Planning and Part
II, Loan and Grant. Part I involves a detailed inventory of the renewal area by the Local
Planning Agency (LPA) and preparation of a specific plan for renewal. Those structures and
facilities requiring removal are identified in the renewal pla.n. Also, the costs for site
clearance are estimated and supported by data on the number and types of buildings and
public facilities involved, unit prices for estimating clearance, and the estimated monetary
return from salvable materials, including the basis for salvage unit prices.149 The LPA, a
public agency created for the specific purpose of carrying out the urban renewal project, is
responsible for all local activities involving the project. After completing the survey and
planning activity, the LPA submits its plan to HUD along with an application for the Part II
Loan and Grant. After HUD review and subsequent revisions by the LPA, Federal funds are
authorized by HUD to implement the approved renewal plan.
Neighborhood Development Program. The Neighborhood Development Program provides
for accelerated urban development through rehabilitation executed concurrently with
planning. The program is particularly adaptable to areas where the primary purpose of
renewal is to conserve and improve existing neighborhoods, rather than to remove and
redevelop.150 A Neighborhood Development Project (NDP) is similar to and is frequently a
part of an urban renewal project. The primary difference between the two is the application
procedure. A new application must be submitted each year for a neighborhood development
project whereas only one application is required for a multiyear urban renewal project.
The Housing and Urban Development Act of 1970 requires chat no less than 35 percent
of available funds during fiscal years 1970-74 be made available for neighborhood
development projects.151
Code Enforcement Grant Program. The principal objective of the Code Enforcement
Grant Program is to restore stability to neighborhoods by effective building code
enforcement. Adequate supporting facilities and services are also to be provided under the
program. A code enforcement grant provides assistance for repair and revitalization of
property in a deteriorating condition and improving public facilities and services such as
streets, curbs and gutters, sidewalks, storm drainage, and utilities.
The program requires a minimum of property acquisition, demolition, and dislocation of
people and businesses. It is preventative in nature and designed to arrest blight before
extensive rehabilitation and slum clearance become necessary.1S2
Demolition Projects. The primary objective of the Demolition Projects program is to
assist communities in removing hazardous structures that constitute a menace to health and
safety. Generally, only those structures judged to be beyond repair are removed from the
project area under this program. Public facilities are usually not subject to demolition and
thus little street rubble is generated.
The total number of structures to be demolished and a listing of building occupancy is
required in the project application. In addition, HUD requires that the contract between the
LPA and demolition contractor set forth both the total cost of demolition and the net cost,
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defined as total cost less any salvage value of demolition material.153 Title to structures to
be demolished is vested in the contractor who is selected on the basis of the lowest net cost
for the work. He thus must carefully estimate salvage value of usable materials as well as his
costs for demolition and disposal of residues.
Interim Assistance. The Housing Act of 1968 authorized the Interim Assistance program
to alleviate problems in blighted areas slated to receive comprehensive renewal assistance,
but where more immediate public action is required.154 The program has been commonly
applied in emergency situations; e.g., in areas that have experienced riots.
Activities encompassed are similar to those supported under the Demolition Projects
program. The grant application requires identification of the number and type of structures
to be cleared.
Solid Waste Generation. No definitive information was available that accurately indicates
the quantity of demolition and associated debris generated as a result of OCD's programs. A
rough estimate can be made, however, based on the available statistics showing total number
of structures removed with OCD support.
Table 8 summarizes the number of structures and corresponding dwelling units cleared
during the period 1957-69 under the Urban Renewal and the Neighborhood Development
Programs.155 OCD personnel indicated that the Urban Renewal Program was responsible
for most of the removals listed in the table. Table 9 shows the cumulative number of
structures removed under the other programs, Code Enforcement, Demolition, and Interim
Assistance.156 In recent years, activity under the Demolition Projects program has increased
significantly.
Referring to Table 8, it is seen that during the 13-year period, an average of 19,600
structures comprising 32,700 dwelling units were removed each year. Based on an estimated
100 tons of demolition debris per structure, the potential quantity of debris generated from
these two programs averaged nearly 2 million tons annually. This quantity approaches 1
percent of the total municipal solid waste loading. If demolition of public facilities within
the renewal area are included, an annual average of 2.7 million tons of debris was generated.
Demolition activities in recent years under the smaller grant programs could add 1 million
tons per year to the total. However, the records of these programs are not complete and it is
difficult to interpret the figures to arrive at an average annual generation.
It should be remembered that these estimates are rough approximations based on meager
data at best. The figure, 100 tons per structure, was developed with the help of OCD
officials who further indicated the extreme approximation involved in making such an
estimation.
The above-noted figures do not represent the total generation of all types of demolition
solid wastes, but only those generated as a result of OCD-supported projects. At first glance,
a figure representing 1 to 2 percent of the total estimated municipal solid waste generation
appears relatively insignificant. However, these wastes are generated in concentrated areas
and contribute a large additional burden on the locality's solid waste management problems.
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In addition, demolition debris represents a significant quantity of resources that are still
useful in many cases.
TABLE 8
SUMMARY OF URBAN RENEWAL AND
NEIGHBORHOOD DEVELOPMENT PROGRAMS
Fiscal year
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
Structures
removed155
(number)
6,378
7,070
10,880
17,367
23,560
20,440
25,615
19,934
19,508
22,638
25,451
25,899
24,467
Dwelling
units
removed155
(number)
14,703
13,841
21,963
33,229
42,909
36,602
46,154
42,521
26,360
35,596
36,656
39,368
31,386
Demolition debris
(millions of tons)
Privately-
owned
buildings*
0.64
0.71
1.09
1.74
2.36
2.04
2.56
1.99
1.95
2.26
2.55
2.59
2.45
Public
facilitiest
0.23
0.25
0.39
0.62
0.85
0.73
0.91
0.71
0.70
0.81
0.91
0.93
0.88
Total
0.87
0.96
1.48
2.36
3.21
2.77
3.47
2.70
2.65
3.07
3.46
3.52
3.33
* Based on 2 to 2Va story residential buildings with average dimensions of 15 ft
by 30 ft by 40 ft, plus 10 percent for larger nonresidential and mixed buildings.
Demolition debris, including salvable materials, assumed to equal 10 percent of
the building volume.
t Based on the ratio of the acreage of public land to privately-owned land and
assuming that half as much demolition debris is produced from clearance of
public facilities, such as streets, utilities, etc., as from building demolition.
Demolition Waste Salvage. The degree to which salvage is actually practiced varies from
region to region and from project to project. In some locations, certain items within the
demolition debris may have value and are therefore recovered. In Washington, D.C., for
example, used brick has high value and HUD officials estimated that up to 50 percent of the
building debris generated by renewal programs may be salvaged. Salvage is practiced in the
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Southwest region of the United States because cheap labor is available and a ready market
for reclaimed material exists in Mexico. In other areas, such as the Midwest, few building
components are salvaged.
TABLE 9
CUMULATIVE BUILDING DEMOLITION156
Structures removed (number)
Period Projects
ending (number)
Total
Resi-
dential
Nonresi-
dential
Mixed
Dwelling
units
removed
(number)
Demolition
debris*
(millions
of tons)
Code Enforement Program
6/70
12/69
6/69
Demolition
6/70
12/69
6/69
6/68
12/67
NA
NA
NA
3,203
2,752
2,345
NA
2,400
2,010
NA
201
197
NA
151
138
6,150
5,572
5,041
0.32
0.28
0.23
Grant Program
113tt
105t
86t
61t
47t
17,473
14,577
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2,824§
2,617§
1,586§
NA
NA
NA
NA
NA
33,801
26,133
25,942
17,871
11,870
1.75
1.46
0.28
0.26
0.16
Interim Assistance Program^
6/70
12/69
118
116
2,718
1,553
2,510
1,428
168
96
40
29
4,443
3,064
0.27
0.16
* Based on 2 to 2*/2 story residential buildings, averaging 15 ft by 30 ft by 40 ft
plus 10 percent for nonresidential and mixed buildings. Demolition debris,
including salvable materials, equals 10 percent of the building volume.
t Excludes about 10 percent of the projects; the number of structures
demolished was not reported on those.
$ Net cost after credit for salvage was $19,318,000.
§ Includes mixed structures.
f Program has been in existence only 2 years.
NAnot available.
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The demolition contractor will generally not salvage materials from structures unless a
ready market for such materials is present. Much of the hardware in demolished buildings of
urban renewal areas is old and of little value. The concrete, masonry, and steel structural
material is usually too contaminated to warrant extensive salvage efforts (with the exception
of used brick). One use for such demolition debris, however, is as a fill material in
embankment construction for road and other construction. OCD officials indicated that
little demolition wastes are actually used for this purpose unless the materials can be used
onsite.
Present regulations require HUD headquarters personnel to coordinate with headquarters
personnel in the Federal Highway Administration (FHWA). Additionally, LPA's and HUD
Area Offices must coordinate their renewal plans with State and local highway departments.
No evidence was found that these relationships resulted in any secondary use of demolition
debris for highway construction. Embankments on major highway projects are excellent
sites for disposal of inert demolition debris while achieving a beneficial use of the debris.
FHWA officials have indicated that a major problem with using inert solid wastes for
roadway embankments was the lack of adequate quantities (see Chapter III). LPA officials,
on the other hand, often have an excess of inert demolition debris and no readily available
disposal method or site. Obviously, effort would be required to coordinate demolition waste
disposal with embankment construction for a highway project. However, the difficulty in
coordination could be more than offset by the savings in disposal costs.
Assuming one-quarter of the 3 to 4 million tons of demolition debris from urban renewal
activities can be economically reclaimed, and one-half requires landfill and/or incinerator
disposal because it is organic material or is a mix of organic and inert material, about 1
million tons of solid waste would be available for disposal within highway construction
projects. This estimated quantity is about equivalent to the total annual solid waste
generation of a city of nearly 1 million, or 0.5 percent of the Nation's municipal solid waste
generation.
OCD Policies Regarding Solid Wastes. While an applicant for HUD funds under any of the
previously described programs must detail such things as the number and type of structures
and public facilities to be cleared, the cost of the project, and the number of people to be
affected, there is no requirement for the LPA to estimate the quantities of solid waste to be
generated or plan for its disposition. Such estimates could be made relatively easily, because
the raw data required to estimate the quantities and types of waste and salvable material
generated by clearance activities is included in the renewal plan. Nor is there a requirement
or even a suggestion that demolition wastes should be utilized where possible. The lack of
such consideration, while deficient from a resource recovery standpoint, has also caused
project delays in the past. HUD officials indicated that on several projects neither the
demolition contractor nor the LPA had considered solid waste disposal until the project was
underway.
OCD has felt that it is the responsibility of the LPA to determine the management of
demolition debris. The LPA in turn passes on this responsibility to his demolition
contractor. Aside from requiring that the bid cost for demolition reflect the potential
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salvage value of reclaimed materials, OCD is presently unconcerned about the fate of waste
byproducts generated as a result of its activities. Even where demolition can be avoided,
regulations discourage the intact removal of buildings in an urban renewal area. For
example, the cost of moving buildings intact may be charged to the project only if the
buildings are of historic value and will be restored and maintained as such. The LPA may
permit building owners or purchasers to relocate buildings to sites outside of the project
area, but without reimbursement, and only if such relocation will not result in the creation
or extension of blighting conditions in another area.157 Structures cannot be sold unless the
sale is identified within the approved demolition contract and the contract price reflects the
value of these structures.158
Overall, it appears that the nonexistence of specific OCD policy relating to the solid waste
generation and salvage aspects of building demolition has the effect of discouraging
reclamation and encouraging generation of demolition debris.
Codes
A municipality must have an approved Workable Program to be eligible for participation
in HUD programs. The Workable Program is required to include a system of local codes,
such as a housing code, zoning regulations, and building, plumbing, electrical, fire protection,
and related codes. The local building codes must be comparable with one of four nationally
recognized model codes.159 The model building codes are considered performance-oriented,
to the extent that available test methods for materials will realistically allow. The codes are
periodically reviewed and revised to include new materials and methods of construction.
A major problem with existing building codes lies with their enforcement. One HUD
official stated his opinion that, "90 percent of the problems with codes have been in
enforcement rather than the building code itself." Individual States and cities interpret and
modify the codes to suit their own special needs. The National Commission on Urban
Problems reported that thousands of local code provisions are often written by or for
speculators, builders, and the building trade unions.160 Pertinent to this study are
provisions added by local governnments stipulating that all materials used in construction
must be new. This obviously limits use of secondary materials but does facilitate code
enforcement and simplify code administration. The primary interest of HUD in regard to
building codes lies with minimizing the cost of home construction, rather than to facilitate
secondary materials recovery.
Under HUD's Operation Breakthrough program, the National Bureau of Standards (NBS)
has been developing performance standards for industrial housing. The performance
standards being developed, for the most part, are to be architectural in nature. This is a
preliminary step toward expanded use of secondary materials in building construction.
HUD is also working to establish uniformity of the various model codes, under the
auspices of the National Conference of States on Building Codes and Standards. Results are
not expected for some time, as more than 1 year was required for the various State officials
to agree upon a uniform set of definitions. When attempts are made to standardize technical
aspects of the codes, even more time delays can be anticipated.
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It is doubtful whether a single code will ever be adopted for use throughout the United
States. HUD officials indicated a single code would be impractical even if geographical
differences in weather, loadings, and other factors could be resolved.
Environmental Impact Considerations
HUD has reacted cautiously to the National Environmental Policy Act of 1969 (NEPA),
P.L. 91-190. This act calls for preparation of environmental impact statements for major
projects. Following are excerpts from a June 19, 1970, letter to the Council on
Environmental Quality (CEQ) from HUD Secretary Romney i llustrating HUD's position on
NEPA.
Almost every program that HUD administers relates to the urban environment, and
there are literally thousands of project approvals for which environmental statements
could be prepared. We plan in the immediate future to concentrate our efforts on
programs, handbooks, policy circulars, and controversial or precedent making decisions
on projects. It would be infeasible to provide comprehensive coverage in the immediate
future, and the incorporation of the policies and goals of P.L. 91-190 into our general
decision-making processes and policy documents appears to be the activity which will
contribute to environmental goals.161
For environmental statements relating to individual projects, HUD will rely on the
applications for information and will supplement this by field checks and checks with
other Federal agencies as appropriate.162
To date, according to OCD personnel, no program handbooks or policy circulars requiring
preparation of environmental statements have been issued. The Neighborhood Development
Program Handbook is currently being revised, and criteria relating to environmental
statements has been included, but this handbook, which is now in draft form for HUD
review, will probably not be issued for some time.
Since the June 1970 memorandum, a number of intra-oifice memoranda have been
written and meetings conducted, but no positive action has been taken. On July 16, 1971,
new HUD policies designed to implement P.L. 91-190 and CEQ's guidelines for preparation
of environmental impact statememts were issued.163 The memorandum requested each
HUD office, including OCD, to issue an office-wide circular with environmental policies,
standards, and clearance procedures governing all programs administered. These circulars are
to be prepared prior to June 30, 1972. Included in the memorandum are criteria setting
forth conditions under which detailed environmental impact statements are to be prepared.
On projects involving urban renewal activity at least one of these four conditons must exist:
The proposed concentration of population, traffic, energy demand, or demand for
other public services in the renewal area must approach or exceed a 50-percent
increase over pre-renewal conditions.
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The new development is expected to cause increased noise levels, waste products, or
waste energy that will exceed the absorption capacity of existing facilities and
airsheds in a manner meeting applicable standards.
The project involves historic structures.
The plan would entail an increase of 100 ft or more in the height of any structure.
OCD personnel reported that these threshold levels warranting preparation of environmental
impact statements were submitted to EPA for review and were subsequently approved. Few,
if any, urban renewal projects are expected to require detailed environmental impact
statements under these restrictions. For example, HUD policy required that, to be given first
priority, urban renewal projects must include 50 percent or more dwelling units for low- and
moderate-income families. Thus, population densities are seldom increased significantly over
previous conditions. The other three conditions would likely occur only as special cases. If
none of the four thresholds are met, a negative statement would be prepared to indicate that
the project is "not significant" or does not have an adverse effect on the environment.
A review of HUD guidelines prepared to assist staff personnel in the preparation of
impact statements seem related only to possible effects of the completed project. The
impact of clearing and construction work during the project was conspicuously absent. The
generation, salvage, and/or disposal of this material was apparently not considered an
environmental problem by HUD officials.
Recommendations
Each LPA, upon applying for Federal funds under OCD's Urban Renewal,
Neighborhood Development, Demolition Projects, and/or Interim Assistance prog-
rams, should be required to estimate the types and quantities of demolition debris to
be generated from clearing operations and to prepare specific alternative plans for
disposal of wastes.
Early identification of expected quantities of demolition debris during planning
phases of a project will better enable the LPA and its contractors to provide for
beneficial reuse of these materials. Also, disposal of residual materials can be more
effectively planned. In certain situations, it may be desirable to identify specific
materials for salvage by the contractor, but this decision must be made on an
individual project basis.
OCD should increase efforts to coordinate renewal projects with the FHWA and
State highway departments to facilitate use of demolition debris in roadway
embankments.
Present regulations require headquarters personnel in HUD to coordinate with
those of the FHWA. Additionally, LPA's and HUD Area Offices must coordinate
their renewal plans with State and local highway departments.
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// detailed environmental impact statements are prepared for HUD-sponsored
projects, factors relating to generation, reuse, and disposal of solid wastes should be
considered.
From the standpoint of solid waste management and waste utilization, imple-
mentation of the first recommendation can solve the solid waste problem without
preparation of detailed environmental impact statements
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CHAPTER X
DEPARTMENT OF DEFENSE
Abstract
Large quantities of goods are purchased, used, and discarded by the vast military
establishment administered by the Department of Defense (DOD). A thorough study of all
possible DOD influences on solid waste generation and recycling was not feasible under the
time constraints of this investigation. Accordingly, only certain aspects of DOD's activities
are briefly considered in relation to solid waste generation and resource recovery problems.
The role of the Defense Supply Agency (DSA) in surplus property management
vis-a-vis solid waste generation and recovery.
The base and headquarters levels of the Department of the Air Force as related to
solid waste management.
The headquarters level office of the Environmental Office of the Deputy Chief of
Staff for Logistics, Department of the Army.
Regulations and policies governing excess property reutilization or disposal were found to
encourage recovery of materials and inhibit solid waste generation. Improper interpretation
and lax enforcement can subvert the system; however, this study was not in sufficient depth
to indicate the efficiency of the system.
DOD's purchasing policies and specifications can have significant influence on secondary
material utilization. For example, existing specifications may stipulate that items purchased
by DOD not be composed of used material. Such influences are the subject of another
EPA-sponsored study, and are not dealt with herein.
Background
As originally planned, the study of DOD was to concentrate on the policies and programs
relating to solid waste generation at the military installation level. However, this approach
was found to be unworkable for several reasons. General policy and regulations were found
to be established by headquarters, and only those required for implementation of
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headquarters directives are developed at the installation. Also, regulations were found to
vary from base to base, so a meaningful study of solid waste generation at military
installations, per se, would have been impractical within the limited time and resources
available.
This report discusses certain activities of the Defense Supply Agency (DSA), the
Department of the Air Force, and the Department of the Army in relation to solid waste
generation and recovery, and gives a brief background of the DOD. Activities outside the
continental United States are not considered.
History, Purpose, and Organization of DOD. DOD was established as an executive
department of the Federal Government by the National Security Act amendments of
j949 164 jts creation was part of a plan for integration of the policies and procedures of the
various departments, agencies, and functions of the government concerned with national
security.165 DOD is charged with providing for the security of the United States. The
Departments of the Army, Navy, and the Air Force are separate military departments within
DOD.
DOD employs approximately 6 million civilian and military personnel to conduct the
many activities and support functions designed to further its goal of providing for national
security. Its fiscal year 1972 budget was $77.5 billion, representing about 34 per-
cent166'167 of the budget for Federal Government activities. The DOD budget for material
procurement was in excess of $18 billion.168 There are approximately 450 major military
installations in the continental United States and about 3,000 installations worldwide.169
Defense Supply Agency (DSA)
DSA was established in 1961 for the purpose of providing supplies and services used in
common by the military services. Establishment of DSA was authorized by the Secretary of
Defense under provisions of the Property and Administrative Services Act of 1949, as
amended. Responsibility for excess and surplus Federal property disposal was assigned to
the Administrator of the General Services Administration (GSA). Under the Act, the
Secretary of Defense is responsible for management of excess property held by DOD
overseas. The Administrator of GSA has since delegated to the Secretary of Defense
responsibility for disposition of excess and surplus DOD property within the United
States.170 DSA has been designated by the Secretary of Defense as Administrator of the
DOD surplus property disposal program. DSA provides the following services to DOD
operating activities:
Supply support, including procurement, storage, and distribution of items com-
monly used by both the armed forces and civil offices of DOD. In fiscal year 1970,
DSA procurements totaled $4.1 billion, representing nearly 2 million items.171
Logistic support, under such activities as the Materiel Utilization Program, DOD
Coordinated Procurement Program, Surplus Property Disposal Program, and
Industrial Plant Equipment Reutilization Program.172
96
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Defense contract administration, involving support for the military departments,
other DOD components, the National Aeronautics and Space Administration
(NASA), other Federal and State agencies, and friendly foreign governments. Value
of prime contracts being administered as of June 30, 1970, was approximately $53
billion.173
To carry out these programs and activities, DSA had 55,784 employees as of June 30, 1970,
most of whom were civilians.174
Of all DSA activities, the Defense Logistics Services Center (DLSC) relates most closely to
solid waste generation and reuse. DLSC is responsible for personal property cataloguing,
material utilization monitoring, and managing the surplus property sales program for DOD.
Procurement functions and defense contract administration services of DSA were also
excluded because the activities are the subject of another EPA-supported study.
A description of the basic property management system used by DLSC is beneficial in
understanding the influence this center has on solid waste generation and utilization.
Reference to "property" in this chapter is intended to mean personal property or
commodities as distinct from real property.
Property Management. Nearly all nonconsumable personal property purchased by DSA
and used by the various activities of DOD is accountable regardless of value. Each military
activity has supply or material officers responsible for all accountable property assigned to
the activity. The excess property is classified into two main categories:
Usable property. This can be any item suitable for use as is or as a source of usable
parts. Jeeps, aircraft, ships, heavy construction equipment, electrical wiring, and
radio tubes are typical examples of usable property.
Scrap. These items have value only for their material content. Film, metals, paper,
rubber, textiles, food, and oil wastes generated in the normal course of military base
operations are examples of scrap.
Certain excess usable military items such as ammunition, fire arms, tanks, combat aircraft,
and ships are required by law to be demilitarized and sold as scrap if further use within the
military is not planned.
Personal property becomes excess to the military service for many reasons. For example,
technological changes may alter equipment design and cause obsolescence of current
supplies. Normal use results in wear and breakage.
Life Cycle and Excess Property. In order to minimize new procurements and maximize
property usage, DSA has established a system to locate new uses for property declared to be
excess by the services. Figure 1 was prepared to illustrate the system DSA uses for disposal
of excess property within DOD. The sequence of events described in the figure is for typical
materials and varies for certain items.
97
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MILITARY BASE
BASE MATERIEL
OFFICER
INVENTORY CONTROL
POINT(ICP)
PROPERTY DISPOSAL
OFFICER (PDO)
DEFENSE LOGISTICS
SERVICES CENTER
(DLSC)
SCREENING FOR
MILITARY SERVICES
SCREENING FOR
FRIENDLY FOREIGN
GOVERNMENTS
DEMILITARIZATION
GSA SCREENING FOR
CIVILIAN FEDERAL
AGENCIES
OTHER MILITARY BASES
WITHIN THE SERVICE
$
SCREENING FOR
DONATION
SALE BY DSSO'S
PURCHASERS
V- PROBABLE SOLID WASTE
GENERATION POINTS
Figure 1. Schematic flow diagram, system for excess property disposal.
98
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Personal property found to be no longer required by the user is reported to the base
supply officer. If the base supply or materiel officer determines that the property is not
needed on that military installation, he reports the excess to either the Inventory Control
Point (ICP) for the service, or it is turned over to the local representative of the Property
Disposal Office (PDO). Items reported to the ICP, such as those of a military nature and
items useful to only one service, are either stored for future use within the service or
screened for use by other military installations of that service. Intraservice use is given first
priority by the ICP. At 6-month intervals, the ICP reviews its supplies in storage and declares
unneeded property as excess and releases this property to the PDO.
If the excess property is believed to have a reasonable prospect for utilization, the PDO
files a report describing the property with the DLSC. DLSC assigns stock numbers and
inputs the information to a computerized inventory system. Concurrently, requests for
equipment and materials are received at DLSC from the other services. Requirements are
matched against excess property within the computer system. Interservice transfer of excess
property is thereby accomplished.
In addition to computerized matching of property needs with excesses, DLSC also
distributes weekly listings of excess property to all military installations, defense
contractors, and civil agencies. An undetermined amount of excess property, including scrap
and some usable property, according to DSA personnel, is not processed through the system
because of associated costs and reduced system effectiveness.
Excess property is also screened for use by friendly foreign governments under the
Military Assistance Program (MAP). If no demand for the property is found after this step,
it is declared DOD excess. Excess property of a military nature is normally demilitarized and
the components processed for sale as scrap or as excess spare parts. Some property is
undoubtedly disposed as solid waste at this point, but no information was available to
indicate its composition or magnitude.
Excess property is next referred to GSA for possible use by civil agencies of the Federal
Government. Only after screening by these prospective users is the excess considered surplus
to the Government's needs. It is then made available to State agencies, nonprofit
organizations, and other eligible donees.
After all screenings, the material remaining is sold. DLSC manages the sale of surplus
DOD property in the continental United States through a nationwide chain of 10 sales
offices called Defense Surplus Sales Offices (DSSO's). Each DSSO provides a comprehensive
merchandizing service for a number of military installations within its area. Many of the
sales conducted by DSA involve scrap and other potential waste materials.
Sales. The DLSC of DSA is the primary sales agency for DOD property within the
continental United States. DLSC uses a nationwide computerized mailing list of sales
prospects to advertise excess property for sale through their DSSO's. The bidder's list is
arranged geographically and identifies the commodity interest of over 28,000 prospective
buyers. DLSC maintains the Defense Surplus Bidders Control Office as the single point of
contact for individuals who are interested in purchasing DOD surplus property.175
99
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In an attempt to increase its sales volume and to effect better utilization of excess
property, DOD has instituted several scrap processing operations. The Bureau of Mines
(BOM) assisted DOD in establishing a scrap processing facility in Ogden, Utah. The primary
function of this facility was to separate more valuable nonferrous metals from low-valued
metals and other contaminates. BOM personnel indicate the facility works satisfactorily and
is cost-effective. However, they also expressed an opinion that further improvement can be
achieved. In addition to the Ogden facility, there are reportedly four other scrap processing
facilities located in the United States.
A scrapping operation has also been established at Davis Monthan Air Force Base in
Arizona. A contractor is furnished with a continuous supply of excess demilitarized aircraft
at this facility. Usable components are removed and residual metals sized to be compatible
with shipping requirements. This operation was reported to be successful. The operation is
thus economical both for DOD and the contractor while achieving resource recovery.
Scrap and other excess property are sold by a number of methods. Selection of the sales
method depends on the type and quantity of property to be sold, among other factors. The
methods are-.
Sealed bidfor one-time sales and for term contracts
Spot bidfor one-time sales
Local spot bidfor one-time sales
Auction sales, nationwide and local
Negotiated sales
Retail sales176
DSA personnel report that essentially all excess property offered for sale is sold.
Generally, items are first offered on a bid basis. If no acceptable bids are received, it may
readvertise. A second bid is often then received that is acceptable. Alternatively, if no
acceptable bids are received, the negotiated sale mechanism may be instituted. If a
negotiated sale is unsuccessful, the material is disposed as solid waste by the PDO, who
generally retains physical custody of the property throughout the utilization screening
process. If the property is still located at the originating military installation, the PDO may
direct the installation to dispose of it in an acceptable manner.
Table 10 presents a summary of the sales volume conducted by the DSSO's. 177-J78
Total proceeds for fiscal year 1970 were $77.1 million, comprised of $43.8 million from
sale of usable property and $33.3 million from the sale of scrap. Other scrap wastes include,
but are not limited to, such items as glass, rubber, plastics, wood, paper and cardboard,
cloth, petroleum (used oil and grease), insulation, leather, and wire. The table does not
reflect sales of items outside of the continental United States nor sales by other agencies
within or connected to DOD.
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TABLE 10
DOMESTIC SALES CONDUCTED BY DEFENSE LOGISTICS SERVICES
CENTER, DEFENSE SURPLUS SALES OFFICES*
Acquisition
value
Description ($ millions)
First half of Fiscal Year
Usable property
Ferrous scrap
Nonferrous scrap
Other wastes &
scrap
Total proceeds
Fiscal Year 1970^ 178
Usable Property
Ferrous scrap
Nonferrous scrap
Other wastes &
scrap
Total proceeds
Fiscal Year 19691
Usable property
Ferrous scrap
Nonferrous scrap
Other wastes &
scrap
Total proceeds
1971m
639.4
NA
NA
NA
NA
975.4
NA
NA
NA
NA
584.5
NA
NA
NA
NA
Sale
quantity
(1000 tons)
NA
195.0
41.9
111.2
NA
NA
335.3
87.9
250.7
NA
NA
365.9
70.3
250.3
NA
Rate of
Gross proceeds return
($ million) ($/ton) (%)
22.9
4.2
10.1
1.8
39.0
43.8
6.7
23.3
3.3
77.1
26.9
5.4
16.0
2.9
51.2
NA 3.6
21.57 NA
241.99 NA
16.49 NA
NA 4.5
19.88 NA
265.27 NA
13.14 NA
NA NA
14.75 NA
227.59 NA
11.58 NA
* Continental United States
101
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Table 11 provides a comprehensive listing of proceeds received by DOD for all excess
property sales.179 Also, applicable DOD expenditures to process these sales are recorded.
The figures reflect foreign sales, sales of the Army Ammunition Procurement and Supply
Agency, sales of standing timber by the Corps of Engineers, and transactions of other offices
within or connected with DOD. It is significant to note that gross proceeds from excess
property sales for the first half of fiscal year 1971 were almost $68 million, while the
military expended $52 million to process, demilitarize, rehabilitate, and otherwise
administer the sales. Thus, cost amounted to 76 percent of the gross proceeds.
DSA personnel expressed confidence in the sales operation, however. The sales program is
successful according to these personnel primarily because large quantities of material are
generally available at regular intervals. It is DSA policy to seek sale of property unless it has
no commercial value, or the estimated cost of continued maintenance, handling, and sale
preparation exceeds the estimated sale proceeds.180 A formula is used to determine if
property can be held economically for future sale. The net sale value is equal to
(a) - (b + c + d), where:
a = Gross sales value of the property based on historical sales, related experience, and
other sources
b = Collection, segregation, and processing costs
c = Other sales preparation and sale costs exclusive of supervisory and administrative
overhead
d = Direct sales overhead at 15 percent of c.181
When the net sales value is greater than zero, the property is processed for sale. If the net
sales value is negative, the negative value will be compared with the estimated cost of
disposal by abandonment or destruction. If abandonment or destruction can be accomp-
lished at less cost than the negative sales value, the property will be abandoned or destroyed.
If the cost of abandonment or destruction exceeds the negative sales value, the items will be
processed for sale even though the net sales value is negative.182 The abandonment or
destruction method must not be detrimental or dangerous to public health or safety.183
The PDO may not accept all excess property for processing and sale. For example, scrap
materials and other property of questionable value can be rejected if it is not economically
feasible for the PDO to process it. DSA personnel indicated that if the PDO accepted all
excess items, the cost of processing, handling, and disposing of low-value or unsalable
property would exceed returns. Thus, undetermined quantities of possibly usable materials
are discarded as solid waste before they reach the processing stage.
Figure 2 illustrates the magnitude of the DOD utilization and disposal programs for the
past 6 years.184 Table 12 is a further breakdown of the utilization and disposal for fiscal
years 1969 and 1970.185186 187 The total reuse activity shown for fiscal year 1970 saved
$7.286 billion based on original acquisition value. Approximately 20 percent of the total
goods handled was reutilized within DOD, while 5 percent was utilized by Federal civil
102
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TABLE 11
DEPARTMENT OF DEFENSE
GROSS PROCEEDS AND DISPOSAL EXPENSES
FIRST HALF OF FISCAL YEAR 1971
179
Property type
Proceeds
( $ millions)
Cost category
Amount
($ millions)
Usable property 33.718
Rate of return (%) 4.1
Scrap
Ferrous 8.184
Non ferrous 16.284
Other 4.012
Combatant ships 1.613
Lumber & timber* 2.117
Other disposals 0.040
Reimbursements from
transfers 0.014
Exchange/sale
property-DSSO 1.665
Precious metals-DSSO 0.003
Other proceedst-DSSO 0.187
Administration 11.736
Receiving-storing
shipping 7.740
Scrap segregation
and preparation 2.824
Maintenance, equip-
ment & construction 1.711
Demilitarization 11.921
Reclamation 1.864
Sales 5.396
Non-identifiable
service center 3.287
Lumber & timber* 1.930
Subtotal 48.409
Non-reimbursable
military personnel 3.150
Total proceeds
67.837
Total expenses
51.559
* Harvesting of standing timber.
t Including storage and handling charges.
103
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agencies and friendly foreign governments. Three percent was donated to nonprofit
organizations, 16 percent sold as usable property, and 50 percent sold as scrap. The
remaining 4 percent was abandoned or destroyed or were combat ships.
Solid Waste Generation. The limited time and funds for this study did not allow the
in-depth study necessary to define the quantities and types of solid wastes generated by
DSA's excess property management system. Information upon which this study is based was
obtained from personal interviews and numerous manuals, catalogs, regulations and their
revisions. No first-hand observations of the property management system were made to
determine where practices and/or policies may unnecessarily result in solid waste generation.
As indicated previously, some low-value excess material is discarded because of expenses
involved in processing, handling, and storing. In other cases, scrap and wastes, including rags,
used oil, food wastes, lumber, etc., are recycled. Other excess property is likely disposed of
because of human error and other imperfections in the system. Unfortunately, no
quantitative estimates of the amounts of such solid wastes were available. As far as DSA
personnel are concerned, the problem is minimal and all resources are utilized to the extent
economically possible.
The military office having custody of lost, abandoned, or unclaimed personal property is
responsible for trying to find the owner of the property. If the owner cannot be found or if
the owner will not claim the property, the property is generally treated as excess
government property. However, it can be disposed of only by sale or by abandonment or
destruction.188 It cannot be donated unless the original owner has signed a release
document.
Department of the Air Force
A complete study of all services was not possible given the limited scope of this project
and the complexity of DOD. Accordingly, Air Force installation activities were selected to
serve as an example of service activities with respect to solid waste generation and recovery.
There are many specific differences in the types and quantities of wastes generated from
service to service, and the policies and regulations promulgated by the services regarding
solid waste management vary.
A typical Air Force base is similar in some respects to a small city. Residents live in
civilian-type dwelling units and in barracks. Military operations on the base are somewhat
comparable to civilian industrial establishments. The solid wastes generated are representa-
tive of municipal solid wastes and all types of industrial solid wastes to be expected from a
city.
The problems related to municipal solid waste generation and reclamation on Air Force
bases are generally similar to those encountered in a city. On the other hand, industrial solid
waste generation and reclamation are more closely controlled on military bases because a
single manager, the base commander, is responsible for all base activities. Because many
items used by the military are accountable, as discussed in the preceding section, it can be
expected that unnecessary solid waste generation is minimized.
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TABLE 12
TOTAL UTILIZATION AND DISPOSAL OF EXCESS
AND SURPLUS PERSONAL PROPERTY185
($ millions acquisition value)
DOD utilization
Interservice transfer of supply
System stocks (ICP-con trolled)*
Intraservice transfer of supply
System stocks (ICP-controlled)*
Interservice excess utilization
Intraservice excess utilization
Subtotal
DOD disposal
Transfers
Civil agencies
Military Assistance Programs (MAP)
Donations
Department of Health, Education
and Welfare
Public airports
Public buildings
Service education centers
Other
Sales
Usable property
Scrap
Other (combat ships, abandoned or
destroyed, and other disposals)
Subtotal*
TOTAL*
FY69
202
141
268
637
1,248
450
NA
NA
232
NA
NA
NA
NA
NA
791
2,998
118
4,589
$5,837
FY70
173
142
381
868
1,564
414
177186
237i86
225
211187
5187
J187
5187
3187
1,195
3,612
276
5,722
$7,286
* Excludes PURA referrals.
106
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Due to the limited project scope, there was insufficient time for an adequate review of all
base regulations and practices that influence solid waste generation and/or recovery.
Therefore, certain example situations are examined as they existed at an Air Force base
located in Virginia. This base contained family housing, commissaries, shops, aircraft
hangars, and maintenance quarters. Nearly 10,500 people lived on the base, and 10,000
civilian and military personnel were employed.
The following examples are illustrative of practices and policies in relation to the
generation and reuse of garbage, cardboard, oily wastes, and metallic wastes.
Garbage. In past years, food wastes were collected by a Navy-monitored contractor who
distributed the garbage to hog farmers. When the State law was enacted requiring food
wastes to be cooked before feeding, interest in sales of garbage decreased. Thus, there was a
need to determine an alternative method of disposal. Monthly accumulation of garbage was
estimated at about 312 compacted cu yds.189 An investigation was initiated by the Deputy
Base Civil Engineer to determine alternate methods for processing and disposing of the
garbage. About the same time, most Federal activities in the area entered into an area-wide
contract for the collection and disposal of wastes. Since the garbage no longer had a buyer,
it was included in the area-wide contract and is now being discarded with other solid wastes.
Cardboard. Approximately 2 years ago a base representative and the refuse collection
contractor reportedly investigated the feasibility of installing a stationary compactor at the
commissary to facilitate cardboard box processing for sale. At the time, the collector was
servicing three 8-cu-yd bins, four or five times each day, for a total volume of 500 cu yd
weekly of uncompacted corrugated material. However, an economic evaluation indicated
that burning would be a less costly solution than compaction and sale.190 Accordingly, an
incinerator was constructed.
Oily Waste. The refuse collector contractor has been required to collect waste oil,
solvents, and other petroleum products. When observed, there were 250 barrels of oily waste
stored in Government-owned 55-gal drums at the landfill awaiting disposition by the Air
Force. The contents (type of oily waste, source, whether or not the oil wastes were mixed)
of the barrels were not known exactly. The oily waste can be sold for recycling as long as
the Air Force is assured that its subsequent use will not create a pollution hazard, but no
buyers had offered to buy this lot.
The Air Force has now issued a policy letter that requires segregation of oily wastes in
order to enhance its marketability.
Oily wastes are disposed of only after all attempts to market it for reuse fail, and even
then, the Air Force must be assured that disposal of the waste oil will not cause pollution.
The base representatives noted that the Judge Advocate General had ruled against the
donation of such material, although such donation could result in useful application of the
waste. For instance, several individuals and private companies had successfully attempted to
secure the oil for use in road dust control.
Metallic Scrap. In an effort to recover scrap metals, the Air Force base provides separate
refuse and scrap storage bins at strategic locations. One bin is marked, "metallic scrap" and
107
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a second bin, "refuse." The collection contractor collects the refuse for disposal. Air Force
personnel collect the scrap for salvage. However, base personnel do not always segregate
metallic wastes from ordinary refuse for various reasons, including lack of interest or
concern and lax enforcement by supervisors. At the time of inspection, the refuse bins
contained approximately 10 percent metals, and the metallic scrap bins contained upwards
of 50 percent nonmetals (volume estimates).
Thus, resource recovery was adversely affected, not by regulations or policies, but by
employee attitudes.
Other. Another example of positive steps being taken by the Air Force is its pilot
program to recycle paper, glass, and metal at 14 Air Force bases.191 The purpose of the
program is to determine the effectiveness and inherent problems associated with recycling.
From these examples it can be seen that resource recovery aspects of solid waste
generation are frequently considered by the Air Force. However, positive action does not
always result. Even when formal steps are taken to encourage reclamation of valuable
resources, such as the installation of separate storage bins, cooperation of personnel cannot
be guaranteed.
In some cases, regulations and/or operating procedures preclude the beneficial use of
waste material, as in the case of the waste oil. When these procedures result in uneconomical
use of property, changes have been effected that often lead to increased resource recovery
and/or decreased solid waste generation. For example, prior to 1968, Air Force regulations
directed that broken items that could not be repaired at the base level should be returned to
special repair depots. The base could scrap the items if they were judged to be beyond repair
or if the repair costs were estimated to be in excess of 65 percent of replacement costs.
In a study by the General Accounting Office (GAO), it was found that $6.7 million worth
of supplies were scrapped under the latter condition in 1967. However, in a sampling of 78
discarded items, GAO found that 51 (or 65 percent) could have been readily repaired for
much less than 65 percent of the replacement cost. The items were scrapped because
inexperienced personnel could not accurately assess the repair costs, and it was an
inconvenience to report the items for repair. No measure of the weight or volume of
material unnecessarily discarded as a result of this action is available, but the dollar value is
significant.
Department of the Army
The activities of the Army with respect to solid waste generation and recycling are only
briefly explored. Of particular interest are studies entitled, "Cost Reduction, Individual
Savings Programs." These describe the ways in which revised operations methods and
practices reduce overall costs. As a secondary result, these revisions also may influence solid
waste generation and recycling. Examples of "Cost Reduction Individual Savings Programs"
reports reviewed are as follows:
108
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Retreading tires rather than replacing with new tires. It estimated that 75 percent of
the tires used by the Army could be retreaded and thereby diverted from disposal as
solid waste.
Reclamation of power shafts having excessive bearing area wear pitting by
institution of a new repair procedure.
Renovation of defective components. Components screened out of a block assembly
line due to defects were formerly scrapped. Using modified assembly line
procedures, the defective components are screened out of the line, renovated, and
used again in the assembly line.
Reuse of damaged crankcases. Instead of scrapping nicked, penetrated, and
otherwise damaged engine crankcases, 75 percent are now repaired and reused.
There are undoubtedly many other examples of past actions in the Army and other
services that have improved resource utilization and decreased solid waste generation. There
are possibly other procedures and activities that are detrimental in relation to resource
recovery goals.
Recommendations
Excess and unclaimed personal property should be eligible for donation, if such
donation results in the use of the property rather than disposal as solid waste.
At present, Federal law prohibits the donation of unclaimed personal property
and unsold excess items unless these items are processed through proper channels.
Frequently property of marginal monetary value does not warrant screening and is
discarded as solid waste. The Federal Property Act should be amended to allow such
property to be donated to local organizations, individuals, or private companies
when such donation would result in recovery or reuse of the property.
A more extensive investigation of DOD regulations and policies that affect solid
waste generation and reclamation is needed.
Under the scope of the present study, only the surface of the problem could be
explored. There are indications that other situations exist in which solid wastes are
needlessly generated and resources are not recovered because of outdated policies
and/or lax attitudes of personnel. It is recommended that the EPA sponsor more
in-depth investigation. The study should include coverage of the following topics:
An input-output system analysis of selected personal property items to
determine where accountable material is consumed, lost, broken, scrapped,
and/or wasted.
109
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Documentation of the quantities of materials purchased, consumed, lost,
scrapped, and discarded to indicate where policy changes can most effectively be
made.
Motivational analysis of DOD employees and military personnel to determine
how human-dependent resource recovery techniques can be structured to
function most effectively.
110
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CHAPTER XI
UNITED STATES POSTAL SERVICE
Abstract
The United States Postal Service (USPS) was created by the Postal Reorganization Act of
1970. In fiscal year 1970, mail deliveries in the United States totalled 6.64 million tons, or
approximately 65 Ib per person. Third class mail, widely termed "junk mail", comprised
nearly 19 percent by volume and 9 percent by weight of the total mail handled by the
USPS. The effects of historical postal rate increases on volume of third class mail were
investigated and found to be minimal.
Background
The USPS became an independent agency of the government under the Postal
Reorganization Act of 1970, replacing the Post Office Department. The main purpose of the
USPS is to provide the Nation with an efficient and reliable mail delivery service. The USPS
is headed by a Board of Governors, including the Postmaster General. Administration and
finance responsibilities are under the direction of the Senior Assistant Postmaster General
for Support, who reports directly to the Deputy Postmaster General.
The total budget for the USPS in fiscal year 1971 was $9.23 billion. Of this figure, $6.80
billion was received in payment for postage and related charges. The projected figures for
fiscal year 1972 at the rates now in effect are $10.01 billion and $7.88 billion,
respectively.192
In fiscal year 1970, mail deliveries in the United States totalled 6.64 million tons, or
approximately 65 Ib per person. Assuming all mail is eventually discarded, and that the
average person generates 5.3 Ib of solid waste daily, mail represents about 3 percent of the
total municipal solid waste generated. The USPS was studied to determine the extent to
which this agency can cause a reduction in that portion of solid waste generation originating
from delivered mail.
Theoretically, as postage rates are increased, a decrease in the use of the mails should
result. Thus, postage rate increases are one means by which the USPS may effect a reduction
in the total quantity of mail entering the solid waste stream.
There are other mechanisms the USPS could use to influence solid waste generation, such
as establishment of packaging requirements for fourth class mail that would minimize
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packaging material quantity, and letter size and weight criteria that would minimize total
weight processed. However, this investigation was limited to postage rates and their effects
on solid waste generation. Therefore, only those USPS activities relating to administration
and finance are discussed; operations pertaining to marketing, mail processing, or building
and vehicle management were not investigated.
In 1879, a classification system was instituted for domestic mail to facilitate mail
handling and future planning. This has evolved into the present system consisting of four
main classes of mail:
First class
Second class
Third class
Fourth class (including parcel post).
Each main class is further subdivided into subclasses according to such criteria as weight,
intended mode of transportation, and degree of presorting by the mailer.
Third class mail has been thought to be a greater source of solid waste than the other
classes. In fact, third class mail has been widely termed "junk mail." Other classes of mail,
such as personal correspondence, (first class and airmail), periodicals and newspapers
(second class) and packages (fourth class), are generally welcomed by the public. A volume
reduction in these mail classes could cause reduced solid waste generation, but at the
expense of a service valued by the public. On the other hand, third class mail is apparently
not as highly regarded by the public and a reduction in this type of mail would likely be
welcomed. Therefore, this study concentrated on possible influences the USPS could exert
that would result in reduced volumes of third class mail.
Third Class Mail
Third class mail consists of form letters, certain merchandise, books, catalogs, and other
printed matter not exceeding 16 oz in weight per piece. The third class rate is generally
lower in cost than first class and provides an economical means for an advertiser to reach a
large audience. The major subclasses of third class mail are listed in Table 13 along with the
respective volumes and weights processed by USPS in fiscal year 1970.193 Bulk rate regular
mail was the largest subclass of third class mail, accounting for over 75 percent of all third
class mail. Bulk rate circular mail comprises nearly 19 percent by volume and 9 percent by
weight of all mail handled. Bulk rate circular mail is almost exclusively used for direct mail
advertising purposes. Rates for each subclass can be on a per piece or per unit of weight
basis and vary depending on the subclass.
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TABLE 13
THIRD CLASS MAIL VOLUMES
(All figures in billions)
Subclass
Single piece rate
Bulk rate-regular, total
Printed matter,
circulars, form letters, etc.
Books and catalogs
Bulk rate nonprofit, total
Printed matter
Books and catalogs
Total, third class
Number of
pieces
0.952
15.050
12.210
2.840
3.971
3.562
0.409
19.974
Weight
db)
0.267
1.573
1.031
0.542
0.191
0.155
0.036
2.032
History of Volumes and Rates
The Post Office Department began compiling statistical data on quantity of mail handled
by class in 1926. Figure 3 illustrates graphically the increase in third class mail volume, both
in number of pieces and total weight, from 1926 to the projected 1972 volume.194 The
vertical lines on the curve indicate years in which postal rate increases were initiated. Table
14 shows the record of minimum charges per piece levied on bulk rate mail from 1952 to
1969.195
After the postal rate increase of 1958, the Department of Commerce conducted a study
to determine the overall economic effects of third class bulk mail rate increases.196 In
addition to studying the rate increase effects on all business and on printers and letter shop
industries, the specific effects on the bulk mailing industry were investigated. The study
presented the following conclusions:
Commercial and business firms constituted the most important segment of third
class mail users, representing: (1) 66 percent of all third class users; (2) originating
89 percent of all third class mail pieces; and (3) paying 91 percent of all charges for
third class mail.
Over 90 percent of the surveyed third class mail users reported that the rate increase
had little or no influence on their marketing practices. Five percent said that the
increases caused a reduction in mailings. Of those firms reporting the degree of
dependence on third class mail advertising for their gross receipts, 62 percent
indicated this dependence was less than 10 percent. After the 1958 rate increase, the
113
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22
20
18 -
16 -
14 -
to
Z
O
d 12
CD.
Q
UJ
{£.
UJ
£ 10 '
UJ
Q
to
UJ
o
UJ g
Q.
6 .
2 -
YEAR OF RATE
INCREASE
to
OQ
Q
UJ
DC
UJ
LJ
Q
to
Q
Z
i
1926 1940 1950 1960
FISCAL YEAR
1970
1980
Figure 3. Volume of third class mail.
114
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number of third class pieces mailed by this group increased 7 percent. Third class
mailings of the group indicating a greater than 10-percent dependence decreased
only 2 percent.
The Department of Commerce study further found that postage accounted for a relatively
small part of expenditures by all business. Bulk mail postage expenditures in the surveyed
firms averaged $0.43 per $1000 gross receipts after the 1958 rate increase, compared with
$0.38 per $1000 before. Notable exceptions were the publishing houses, mail-order and
direct selling businesses, and correspondence and vocational schools. Their bulk rate postage
costs ranged from $6.38 to $58.13 per $1000 of gross revenue. These businesses make up
less than 4 percent of all third class mail users.197 Referring to Figure 3, it can be seen that
the 1958 increase in third class mail rates did not decrease the volume of third class
mailings.
TABLE 14
MINIMUM CHARGES FOR SELECTED SUBCLASSES
OF THIRD CLASS MAIL
195
Fiscal
year
1952
1953
1958
1959
1961
1963
1964
1965
1968
1969
Bulk
per piece
(cents)
1.000
1.500
1.500
2.000
2.500
2.625
2.750
2.875
3.600
4.000
Subclass
Single piece,
first 2 oz.
(cents)
2.000
2.000
3.000
3.000
3.000
4.000
4.000
4.000
6.000
6.000
Unfortunately, the Department of Commerce study was undertaken after a relatively
minor rate increase affecting the single piece third class mailings only. As shown on Table
13, this subclass accounts for less than 1 billion pieces of third class mail annually compared
with the almost 20 billion total. Examination of Figure 3 shows that past variations in the
third class mail volumes have occurred independently of rate increases. For example, in
1942 and 1956 third class mail volume (per piece basis) declined, yet no rate increases had
recently been instituted. It can be assumed the 1942 volume reductions resulted from
wartime conditions. However, no significant outside influence is connected with the 1956
decline. Of the 12 rate increases since 1926, the volume of mailing declined during the year
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of the increase on only three occasions (1927, 1967, and 1968). Following the rate increases
of 1952, 1960, and 1969, the rate of increase in third class mail volume slowed.
A comparison of the percentage increase in bulk regular mailing rates during the 1949-69
period was made with the purchasing value of the dollar for the same period. During the
period, the dollar's value declined about 42 percent while bulk mailing rates (per pound and
per piece) increased 57 percent and 300 percent, respectively. Thus, users of third class mail
service are increasing this use while paying more in terms of real dollars for the service
received. Apparently, past third class mail rate increases have not been of sufficient
magnitude to cause the demand for this service to decrease.
USPS Postage Rates, Mail Volumes, and Solid Waste
A detailed study of the demand for third class mail and related economics would be
required to ascertain the magnitude of rate increases necessary to cause a given reduction in
third class mail volumes. Past information is inconclusive, but it is expected that rate
increases would have to be substantially larger than past increases to significantly affect
third class mail volume.
Postal Service officials have expressed the opinion that sufficiently large rate increases in
any or all classes of mailings would decrease the volume of mail delivered. It is likely that
businesses would increase their utilization of private mail delivery firms if USPS rate
increases were greatly increased. Use of the mail rate structure to stimulate or otherwise
affect segments of the economy not directly related to USPS operations is presently
practiced. For example, nonprofit organizations pay lower postage rates than profit-making
organizations. Educational, religious, agricultural, and veterans publications receive preferen-
tial rate consideration to encourage their dissemination and use. So, there is precedence for
setting mail rates to influence certain activities, much as tax laws are now used to stimulate
specific endeavors. However, USPS officials indicated that the USPS would not likely raise
postage rates for the purpose of reducing solid waste generation. A discussion of the basis
for this position follows.
USPS Position Basis
The USPS is not a profitmaking organization; however, it considers itself a business
enterprise. This agency is in existence to provide a needed service. Postage rates are intended
to cover costs only. The predecessor to USPS, the Post Office Department, operated at a
deficit of approximately $1.51 billion in fiscal year 1970; that is, the costs of providing
postal service exceeded by this amount the charges made to customers for services.198 It
was apparent, therefore, that postal rates must be increased if the USPS was to begin
operating at the break-even point.
The Statute creating the USPS requires that revenues from rates and reimbursements plus
specified appropriations must equal the total costs of operating the Postal Service. To attain
this goal, the USPS has planned a series of rate increases for all classes of mail over the next
5- to 10-year period. Ultimately, the rates in effect for each class will generate sufficient
116
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revenue to at least cover its attributable costs and make a reasonable contribution to
institutional costs. Institutional costs are those for common mail processing and handling
steps applicable to all classes of mail, while attributable costs reflect the direct costs
applicable to the particular class of mail. Table 15 shows the present and projected
attributable costs and revenues for selected classes of mail.199
TABLE 15
SUMMARY OF ESTIMATED FISCAL YEAR 1972 FINANCES199
(All doUar figures in millions)
Revenue from
current rates
Mail
class
First
Second
Nonprofit
Regular
Other
Projected
costs ($)
$2,357
55
238
37
Revenues
($)
$3,517
13
135
15
Percent of
attributable
costs (%)
149
23
57
41
Revenue from
proposed full rates
Revenues
($)
$4,691
55
328
38
Percent of
attributable
costs (%)
199
100
138
102
Total
Bulk-
nonprofit
Total
330
163
49
106
82
623
864
77
139
421
106
1,150
128
Third
Single piece
Bulk-regular
101
416
108
674
107
162
180
864
178
208
100
184
From Table 15 it can be seen that third class mail, at the proposed full rate levels, will
generate twice as much revenue as the attributable direct costs to handle it. USPS officials
have expressed the opinion that they would not institute higher rates for third class mail
even though a reduction in solid waste generation might result. They do not want to lose the
'profitable' third class bulk rate mail business to competitors such as private delivery
services, periodical advertising, and television.
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Recommendations
The use of increased postal rates to control the volume of mail discarded in
municipal wastes cannot be recommended based on the limited information
available for this study.
Further analysis could possibly better define the relationship between postal rate
increases and mail volume delivered. If such future analysis should indicate that
beneficial reductions in solid waste generation would occur if increased postal rates
were imposed, there is a strong likelihood that private delivery and mail services
would become more cost competitive for the advertising mail market. In that case,
government actions would have no net influence in reducing solid waste generation.
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CHAPTER XII
PROPERTY MANAGEMENT AND DISPOSAL SERVICE
AND
PUBLIC BUILDING SERVICE,
GENERAL SERVICES ADMINISTRATION
Abstract
Activities of the Property Management and Disposal Service (PMDS) and Public Building
Service (PBS), both part of the General Services Administration (GSA), can influence solid
waste generation and recycling efforts in various ways. For example, PMDS has
responsibility for personal property management within the civilian sector of the Federal
Government. In this capacity, PMDS determines the fate of excess property and ultimately
arranges for its disposition as either waste or salvable materials for sale. PBS has
responsibility for the design and maintenance of Federal buildings. Since solid wastes
frequently require preparation and processing before recovery and sale for reutilization, PBS
can account for such processing needs in both building design and maintenance practices.
PBS and PMDS are discussed in a single chapter because their activities concerning solid
waste are related, and they are both subagencies of GSA.
Background
GSA has recently been active in efforts to encourage resource recovery through
alterations in purchasing policies. Thus, the Federal Supply Service has begun a review of
product specifications to determine those specifications that are biased against secondary
material usage. Less publicity has been afforded the actual and potential influences of PMDS
and PBS on solid waste generation and resource recovery.
History and Organization of GSA. GSA was established in 1949 by the Federal Property
and Administrative Services Act to provide the Federal Government with a centralized
system for such activities as property procurement and management. With the creation of
PMDS in 1966, the present organizational structure was formed as described below.
Federal Supply Service (FSS). This GSA activity has responsibility to procure personal
property commonly used by all Federal agencies. FSS promulgates the Federal specifica-
tions and standards for personal property purchases and stores and distributes those
119
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commodities purchased. The fiscal year 1972 budget for the FSS was $86 million.200 The
budget amount does not include the cost of procurements made for other agencies.
Federal specifications used by the FSS for purchases can have a marked impact on usage
of reclaimed material. However, the effects of Federal purchasing policies on solid waste
generation and reuse are not discussed herein. This topic is the subject of another study now
being undertaken by EPA.
Transportation and Communication Service (TCS). The TCS has responsibility to provide
motor equipment, public utilities, and communications for civilian agencies of the Federal
Government. The fiscal year 1972 budget for the TCS was $7.1 million.201 Possible
relationships between TCS duties and solid wastes were not investigated during this study.
National Archives and Records Service (NARS). As the name implies, NARS has
responsibility for managing and storing Federal records.202 As dated records are
systematically discarded, solid wastes are generated, but PBS and PMDS have jurisdiction
over these problems. NARS had a $27.7 million budget in fiscal year 1972.203 NARS
relationships with solid waste generation or recycling were not studied.
Property Management and Disposal Service (PMDS). In addition to previously stated
duties, PMDS has responsibility for management of materials stockpiled for use in national
emergencies and disposal of excess materials no longer required. It also identifies excess
Federally owned real property, screens the property (offering it to other Federal agencies
for use), and disposes of excess property by sales or donation. The budget for PMDS
activities in fiscal year 1972 is $39.3 million.204
Public Building Service (PBS). As briefly described above, PBS has responsibility for the
design, construction, and management of Federally owned and leased buildings. The
acquisition, utilization, and custody of all GSA owned real property is also the
responsibility of PBS. PBS had a budget of $700.9 million for fiscal year 1972.205
Building material and architectural design standards promulgated by PBS that could
influence secondary material usage will not be discussed herein. This topic was beyond the
scope of this study and is the subject of an investigation covering Federal procurement
policies as previously noted.
PMDS Activities in Relation to Solid Waste
The PMDS strives to maximize utilization and minimize new procurements of personal
property by the Federal Government. A property accounting and screening system has
evolved to facilitate attainment of this goal. The 1949 Property Management Regulations
required all agencies (except the Maritime Administration, the Atomic Energy Commission,
and the Postal Service) to account for personal property and report all excess property to
PMDS. Each civil agency has a Board of Survey that periodically reviews internal property
management. This Board was empowered to relieve accountability if property was declared
lost, broken, or otherwise unusable. Repairable items are repaired by agency personnel or by
private contractors.
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Figure 4 illustrates the life history of common use commodities purchased, used, and
declared excess by the operating Federal civil agencies.206 The FSS acts as the purchasing
agent for all items used in common by civil and military agencies. In fiscal year 1970, FSS
purchased in excess of $2 billion worth of 49,000 different commodities.207
As indicated above, the Property Management Regulations direct the Administrator of
GSA to account for Federally owned personal property. To more efficiently administer
these responsibilities, tthe Administrator has delegated the accounting responsibility for
personal property used by the military to the Secretary of the Department of Defense, as
discussed in Chapter X. GSA maintains overall responsibility and still administers the
transfer and donation of excess personal property from both civil and military agencies, as
indicated in the following sections.
Excess Property Management. When personal property in the possession of a Federal
civilian agency becomes excess to that agency's needs, it is reported to PMDS. While the
property remains in the possession of the reporting agency, PMDS conducts a systematic
search of other agencies to determine if a need for the property exists elsewhere. The
military services are given first opportunity to request the excess items. Civilian agencies are
canvassed next if the military has no use for the items. In fiscal year 1970 commodities with
an original acquisition cost totaling $635 million were transferred from one Federal agency
to another.208 Included in this figure was $177 million worth of military property that was
handled through PMDS facilities.209
Items for which no demand exists within the Federal Government are made available for
donation. PMDS has been authorized to donate excess Federal property to the following
types of organizations:
Educational, public health, and civil defense
Public airports
Public bodies
Organizations of educational interest to the armed services.
Thus, school systems, universities, the Red Cross, the Boy Scouts and Girl Scouts, and
Boys Clubs, among others, are eligible to receive excess Federal property. The Department
of Health, Education, and Welfare and each State assist PMDS in identifying eligible
organizations needing excess property. In fiscal year 1970, PMDS donated Federal property
worth $361 million (original acquisition cost) to qualified organizations, 21° including $225
million worth of property derived from military activities.211
Personal property from civil agencies not transferred or donated are subject to public sale
through the PMDS Sales Division. Items sold are classified either as excess usable property
or scrap. Examples of items sold are automobiles, aircraft, hardware, office supplies, and
drugs. The property is sold by competitive bid and offered on an "as is," "where is" basis.
Potential foreign and domestic buyers are encouraged to participate in excess property sales.
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FEDERAL SUPPLY
SERVICES
$2.149 BILLION
BROKEN
REPAIR
FIXED
DISTRIBUTED TO
AGENCIES
USED BY AGENCIES
CONSUMED
IN USE
SOLID
WASTE
EXCESS PROPERTY
REPORT ED TO PMDS
PROPERTY
MANAGEMENT AND
DISPOSAL SERVICES
SCREENING
$635 MILLION
MILITARY
AGENCIES
CIVILIAN
AGENCIES
DONATION
$361 MILLION
SALES TO PUBLIC
$82 MILLION
DISPOSAL
SOLID WASTE SALES j
Figure 4. Life history of common use commodities purchased by the Federal Govern-
ment.206 Dollar figures represent fiscal year 1970 acquisition cost equivalents.
122
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Unclaimed military property is referred back to the Department of Defense for sale through
its own offices.
Nationwide sales figures for fiscal year 1970 indicated that property with an original
acquisition cost of $82 million was sold to the public.212 The gross income from these sales
was approximately $17 million. All PMDS expenditures in connection with public sales
amounted to $12 per $100 of sales according to agency officials or approximately $2
million. Excess property has been sold to both domestic and foreign customers in the past,
according to PMDS personnel.
Table 16 summarizes the quantity and value of scrap materials sold in fiscal year
1970.213 Of the more than 57,000 tons of excess Federal personal property sold as scrap,
(many materials were not weighed so the total weight is not known) paper represented the
largest portion at almost 44,000 tons. All paper sold as scrap was generated at GSA operated
Federal office buildings throughout the country and would otherwise be disposed of as solid
waste if not sold by PMDS to scrap paper dealers. In fact over 19,000 tons of the total
wastepaper sold was composed of mixed papers collected from wastebaskets. Table 17
presents a summary of paper waste sales by grade.214 Note that the value of segregated
grades of paper was generally much higher than the corresponding value of mixed paper.
As might be expected, volumes of scrap sold vary significantly from year to year. PMDS
figures for fiscal year 1971 indicated that approximately $3.7 million was received from the
sale of scrap materials. As previously noted, the income from the sale of excess government
property from civil agencies for fiscal year 1971 was $17 million. Accordingly, scrap sales
represented about 22 percent of all GSA sales to the public.
As described above, PMDS attempts to achieve maximum utilization of government
personal property. PMDS officials contacted during the study expressed confidence that the
system works well. One estimate indicated that 99 percent of all items not transferred or
donated are eventually sold, donated for direct reuse, or sold as scrap.
In order to readily sell scrap, it must be in a form in demand by the secondary materials
industry. Paper, for example, must be relatively free of contaminants and be in a readily
transportable form. Much of the scrap that PMDS sells, especially the paper wastes,
originates from PBS operated facilities. Although PBS collects the mixed paper generated by
building occupants, the agency contends that it cannot enforce separate collection systems
necessary to upgrade paper waste quality and thereby increase paper waste sales.
PBS Activities in Relation to Solid Waste
PBS provides janitorial services for more than 10,000 buildings housing Federal
agencies.215 The Federal Government owns approximately 2,500 of these buildings; the
others are leased.216 PBS is responsible for maintaining approximately 187 million sq ft of
floor space, including the collection and storage of solid wastes generated within the
government's property or leased space. As an indication of the quantity of solid wastes
generated, 152,000 tons per year of trash and debris are hauled away from government
operations by contractors, according to GSA officials. (This figure does not represent the
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TABLE 16
SCALE OF SCRAP (SOLID WASTE) MATERIALS
FISCAL YEAR 1970213
Type
Paper (11 grades)
Metals
Ferrous
Nonferrous
Rubber tires & tubes
Drums & barrels
Batteries
Bones, meat scraps,
grease, etc.
Rags, wool, canvas
Film
Ashes, cinders, soot
Rope
Plastics
All other scrap
Grand total
Quantity
43,942 tons
3,700 tons
5,041 tons
32,668 units
72 tons
2 lots
4,476 units
3 lots
9,378 units
100 tons
1 lot
303 tons
2 lots
134 units
2,603 tons
1 lot
291 tons
23,543 cuyd
71 tons
2,900 units
1 lot
1,129 tons
Total
$ 34,896
1,113
478
6,158
420
56,472
10,963
87
11.556
3,471
603
178,337
2,468
500
20
Total
receipts*
$ 378,510
44,241
606,512
36,487
6,578
67,522
15,630
180,805
167,292
1,175
6,105
520
107,251
$1,618,628
* Sales receipts received from contractors.
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TABLE 17
SALE OF PAPER WASTES
FISCAL YEAR 1970
214
Type of paper
Mixed paper
Corrugated (cardboard)
Books and magazines
Colored ledger
White ledger
Colored tabs
(IBM cards)
Manila tabs
(IBM cards)
Hard white shavings
File stock
Wet strength
Mascerated paper
Total
Tons
19,137
335
8,019
542
1,109
4,500
928
77
3,930
462
4,898
43,942
Average
price/ton
$ 1.90
18.57
0.58
10.00
15.99
47.01
66.58
43.72
2.44
1.23
4.30
Sales
receipts
$ 36,417
6,233
4,622
5,420
17,745
211,645
61,793
3,393
9,597
568
21,072
$378,515
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total Federal generation of solid wastes because not all government-use buildings are served
by GSA contractors. For example, post office buildings are managed by the Postal Service.)
The manner in which solid wastes generated in PBS operated buildings are collected and
stored within the building has a significant impact on the quantity recovered for salvage sale
and the monetary return realized.
Paper Waste Preparation. With the exception of writing the contract under which paper
waste is sold, all recovery operations are conducted by PBS. While available space in a given
building may determine whether or not mechanical solid waste processing can be installed,
the primary basis for decision has been cost-effectiveness. PBS operates baling machines for
reclamation of salable paper at 13 locations. Paper wastes from some additional locations
where a baler installation was not warranted are being hauled to available balers. Paper
wastes have also been bagged for sale at locations where quantities generated would not
support a baling operation. Computer room waste and print plant scrap have normally been
collected at the source in bags or trays supplied by the paper waste purchaser. Regardless of
baler availability, PBS janitorial personnel are instructed to remove obvious contaminants,
such as glass, metals, lunch bags, and the like from wastes.
Combined shredding and baling processes have been used to significantly increase the
return to the government on paper waste sales. At a Federal Records Center in Pennsylvania,
for example, 1,300 tons of cancelled checks each year were originally sold for $54 per ton.
With the addition of a $70,000 shredding and baling system, the checks were processed and
sold for $85 per ton. Thus, $40,300 more per year was realized, and, assuming an operation
and maintenance cost of $10,000 per year, the machine was paid for in less than 3 years.217
Those agencies generating classified waste materials present an additional problem. The
paper waste must first be processed to render it illegible before being sold to a contractor. A
wet pulping system has been used by PBS for this purpose. While the pulped paper was
satisfactory from a security standpoint, the material was too wet to attract buyers. Paper
wastes processed in this manner were discarded rather than sold for reuse. Interestingly, the
wet pulping devices were purchased and installed after an informal market survey by PMDS
indicated that the pulped material could not be sold to wastepaper dealers. PBS was
opposed to new wet pulping installations because of excessive cost and difficulties
encountered in waste disposal. However, security paper destruction equipment has usually
been selected by the occupant agency, with little PBS influence.
According to PBS and PMDS officials, an alternative system is now available to
satisfactorily shred and pulp classified papers. Using a screw-type dewatering system, this
alternative shredding method yields a readily transportable mass of paper fiber that can be
reused by paper manufacturers. However, agencies requiring security paper waste processing
have now installed the wet pulping process, and no plan exists to replace these systems.
Separate Collection. Experiments are underway at PBS-operated buildings in Denver and
Washington, D.C., to initiate separate collection of office wastes. The method undergoing
tests entails use of two waste cans in a given area. One can is labeled "trash" while the other
is labeled "paper only." An attempt will be made to keep paper wastes separate from other
126
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contaminants at the source. The value of the wastepaper will be increased; however, the
cost-effectiveness of such a system may not warrant widespread use.
Separate collection has been attempted in PBS buildings according to PBS officials with
little success. A small segment of employees disregard the waste can labels and cause
undesirable results. Janitorial personnel, whether employees of PBS or contractors, must be
carefully instructed and supervised to keep container contents separated. PBS officials also
point out that janitors are paid $4.30 per hour, including fringe benefits, and that extra time
is necessary for separate collection. This extra cost would probably not be offset by the
higher returns for the segregated wastepaper. No definitive study was available, that either
supported or disputed this position. However PBS is currently conducting tests to determine
its cost-effectiveness.
Where materials are already separated because of the nature of the activity, such as
computer room wastes, or used corrugated boxes from the receiving rooms, separate
collection has been less expensive and relatively effective according to PMDS officials.
Solid Waste Storage. GSA personnel are divided in their opinions regarding the effects of
building design on solid waste recovery efforts. PBS officials indicated that special storage
areas to encourage recovery of solid waste from office buildings are not necessary because
most buildings receive daily collection service. In addition, PBS stated that large amounts of
waste could not be sold because of excessive contamination.
PMDS, on the other hand, indicated that special storage areas in Federal buildings would
provide the necessary space to store segregated grades of paper until sufficient quantities
were accumulated to warrant collection. For example, it was noted in a speech at the
Composting-Waste Recycling Conference in May, 1971, ". . . the Federal Government makes
little effort in Washington, D.C., to separate usable paper for recycling on the grounds that
government buildings do not have adequate space for the separation, packing, and storage
necessary."218 Furthermore, the lack of adequate space in a building can prevent the
installation of a baler or shredder even where desirable.
In the face of all the roadblocks, GSA administrative personnel pointed out that 42
percent of all solid waste generated in PBS-operated buildings in the Washington, D.C., area
was sold as scrap for eventual recycle. This high percentage applied only to the particular
region involved, reflecting a long-time active interest in such matters by Region III PMDS
and PBS staffs. Nationally, only a small percentage of office wastes were sold as scrap. This
was true partly because Federal facilities were not as concentrated elsewhere as in Region
III. But a contributory factor was the insufficient degree of cooperation between PBS and
PMDS on such matters in other regions. PMDS attempts to market wastes that are
frequently poorly prepared for recovery by personnel under supervision of the PBS.
Federally Owned vs. Leased Buildings
As previously noted, PBS provided janitorial services in buildings owned and occupied by
the Federal Government. In most leased buildings, however, janitorial services were included
in the lease rate. PBS had minimal control over solid waste collection and storage practices
127
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at leased buildings and thus could not readily assist PMDS in scrap sales in these cases. In
order to take better advantage of lease alternatives, legislation was being prepared to provide
GSA greater flexibility with respect to planning and contracting for acquisiton of building
space.219 Indications were that more buildings would be leased in the future because
economic analysis indicated that leasing of buildings has, in most cases, been less costly than
Federal ownership.2'20
Special arrangements can be made with the owner of a leased building to facilitate
recovery of wastepaper. In one case, proceeds from the sale of wastepaper generated in a
Federally leased building in the Washington, D.C., area were to accrue to the building owner
rather than the government. A reduced lease price reflected only the savings in waste
collection and disposal costs. The owner was able to keep any excess proceeds. In this
manner all sectors of the economy may benefit; the government reduces the lease cost, the
building owner may realize added income, and public disposal facilities are not burdened
with paper waste.
Recommendations
All regional PMDS and PBS offices should actively coordinate their activities that
influence solid waste storage, collection, processing, and sales.
Since PMDS is empowered to market the materials processed by PBS, PMDS
should be consulted as to desired characteristics for the solid waste materials to be
salvaged. The PMDS should advise the PBS on storage space and processing
equipment requirements to enhance the marketability of reclaimed solid wastes.
Building lease contracts arranged by PBS should include the stipulation that solid
wastes generated by Federal activities be sold if markets are located by PMDS.
PBS should conduct studies of collection and disposal costs and logistics to define
the economic and environmental impact of solid wastes generated in Federally
operated buildings and to better assess the feasibility of waste separation for salvage.
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REFERENCES
1. The National Environmental Policy Act of 1969; Public Law 91-190, January 1, 1970.
Washington, U.S. Government Printing Office, 1970. p. 7.
2. Council on Environmental Quality. Environmental quality, the first annual report of
the Council on Environmental Quality, 1970. Washington, U.S. Government
Printing Office, p. 265.
3. The budget of the United States government, fiscal year 1972. Washington, U.S.
Government Printing Office, p. 522.
4. Slitor, R., Office of Tax Analysis, Treasury Department. Federal recycling policies:
tax incentives. Unpublished paper, May 3, 1971, 34 p.
5. Lentz, O. Mineral economics and the problems of equitable taxation. Quarterly of the
Colorado School of Mines, 55(2): 38, Apr. 1960.
6. Internal Revenue Service. Depreciation, amortization, and depletion. Washington, U.S.
Government Printing Office, 1970. p. 14.
7. Ibid., p. 17.
8. Ibid., p. 14-15.
9. Slitor, R. Federal recycling policies, op. cit., p. 15.
10. Internal Revenue Service. Source book of statistics of income. Unpublished tables.
Washington, 1968. p. 89.
11. U.S. Department of the Interior, Bureau of Mines. Iron ore. Washington, U.S.
Government Printing Office, 1968.
12. U.S. Department of Agriculture, Forest Service. The demand and price situation for
forest products, 1970-71. Miscellaneous Publication No. 1195, 1971. p. 67-69.
13. Internal Revenue Service. Source book, op. cit., p. 141.
14. Slitor, R. Federal recycling policies, op. cit., p. 17.
15. Ibid., p. 18.
16. Federal laws, regulations, and material relating to the Federal Highway Administra-
tion. Washington, U.S. Government Printing Office, Apr. 1970. p. 1-3.
17. U.S. Department of Transportation, Federal Highway Administration. Unpublished
data. Apr. 12, 1971.
129
-------
18. Ibid.
19. United States government organization manual, 1971-72. Washington, U.S. Govern-
ment Printing Office, July 1971. p. 373.
20. Ibid., p. 374.
21. U.S. Department of Transportation, Office of the Secretary. Implementation of
section 102(2) (C) of the Environmental Policy Act of 1969; section 4(f) of the
Department of Transportation Act; and portions of section 16 of the Airport and
Airway Development Act of 1970, Order DOT 5610.1. Washington, Oct. 7, 1970.
Attachment 1, p. 2.
22. U.S. Department of Transportation, Federal Highway Administration. Interim
guidelines for implementation of section 102(2) (C) of the National
Environmental Policy Act of 1969. Draft instructional memorandum subject to
revision. Washington, Nov. 24, 1970. p. 7 and attachments.
23. U.S. Department of Transportation, Office of the Secretary. Implementation of
section 102(2) (C) of the Environmental Policy Act, op. cit., p. 12 and
attachments.
24. Anonymous. Draft environmental impact statement, Plattsburgh-Keeseville Pt. 3,S.H.
258, Clinton County (New York), Peru Bridge, 1971. p. 11.
25. Arizona Highway Department. Draft environmental impact statement for Nogales
Tuscon Highway in Santa Cruz and Pima Counties, Ariz., May 1971. p. 19.
26. Division of Highways, State of Colorado. Draft environmental impact statement,
Project I 70-2-(ll), Glenwood Canyon, Col. Grand Junction, Col. July 1971. 17
p. summary and 154 p. appended report.
27. State Highway Department of Georgia. Draft environmental impact statement for
1-75-3 (3) (270) P.E., 1-75-73 (2) (291) P.E., Cobb-Cherokee-Bartow Counties,
1971.
28. Crosstown Associates. Draft environmental impact statement, Chicago Crosstown
Expressway. For the City of Chicago, County of Cook and State of Illinois
through the Crosstown Executive Board. Chicago, 111. July 12, 1971.
29. U.S. Department of Transportation, Federal Highway Administration. Standard
specifications for construction of roads and bridges on Federal highway projects,
FP-69. Washington, U.S. Government Printing Office, 1969. 451 p.
30. U.S. Department of Transportation, Federal Highway Administration. Unpublished
data, op. cit.
31. U.S. Department of Transportation, Federal Highway Administration. Washington
Forest Highway Project 13-2(6) and F 016-2(9) proposal and contract. Portland,
Ore., June 17, 1971. 86 p.
130
-------
32. U.S. Department of Transportation, Federal Highway Administration. FP-69, op. cit.,
p. 75.
33. Ibid., p. 76.
34. Ibid.
35. U.S. Department of Transportation, Federal Highway Administration. Washington
Forest Highway Project, op. cit., p. D-27.
36. U.S. Department of Transportation, Federal Highway Administration, FP-69, op. cit.,
p. 79.
37. Ibid., p. 83.
38. Ibid., p. 86.
39. U.S. Department of Transportation, Federal Highway Administration. Washington
Forest Highway Project, op. cit., p. D-30.
40. U.S. Department of Transportation, Federal Highway Administration. FP-69, op. cit.,
p. 87.
41. Ibid., p. 88-89.
42. Ibid., p. 106.
43. Ibid., p. 107.
44. U.S. Department of Transportation, Federal Highway Administration. Washington
Forest Highway Project, op. cit., p. D-32.
45. Ibid., p. D-33.
46. U.S. Department of Transportation, Federal Highway Administration. FP-69, op. cit.,
p. 120.
47. Ibid., p. 358.
48. General Services Administration. General provisions (construction contract). Standard
Form 23-A. Washington, U.S. Government Printing Office, Oct. 1969. p. 2-3.
49. Federal laws, regulations, and material, op. cit., p. 1-7.
50. Anonymous. Waste utilization in highways. Unpublished paper obtained from the
Federal Highway Administration. 6 p.
51. Goodyear tests old tires for use as highway crash cushions. Solid Waste Report, Aug.
23, 1971. p. 157.
52. Black, Sivalls & Bryson, Inc., Applied Technology Division. Carbonate bonding of coal
refuse. Report prepared for the Environmental Protection Agency. Washington,
U.S. Government Printing Office, Feb. 1971. 44 p.
53. Federal Trade Commission. Annual report of the Federal Trade Commission, fiscal
year ending June 30, 1970. Washington, U.S. Government Printing Office, p. 63.
131
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54. Federal Trade Commission. Annual report of the Federal Trade Commission, fiscal
year ending June 30, 1968. Washington, U.S. Government Printing Office, p. 63.
55. Federal Trade Commission. Annual report of the Federal Trade Commission, fiscal
year ending June 30, 1969. Washington, U.S. Government Printing Office, p. 65.
56. Scrap iron & steel industry. In Code of Federal Regulations, Title 16, section 76,
(16CFR76). Washington, U.S. Government Printing Office.
57. Waste paper dealers and packers. In Code of Federal Regulation, Title 16, section 76,
(16 CFR 81). Washington, U.S. Government Printing Office.
58. Proper labeling of rebuilt fuses. In Code of Federal Regulation, Title 16, section 76,
(16CFR15.84). Washington, U.S. Government Printing Office.
59. Use of terms "virgin" or "new." In Code of Federal Regulations, Title 16, section 76,
(16CFR303.35). Washington, U.S. Government Printing Office.
60. ACH Fiber Service. Investigation of test method for the determination of reprocessed
wool. Unpublished report for the Bureau of Textiles and Furs, Federal Trade
Commission, Boston, Mass., Jan. 3, 1963. p. i.
61. Comptroller General of the United States. Review of duty-free sales of certain waste
produced from imported conditionally duty-free carpet wool. Washington, June
1967. p. 8.
62. Darnay, A., and W. Franklin. The role of packaging in solid waste management.
Washington, U.S. Government Printing Office, 1967. p. 5.
63. Fair Packaging and Labeling Act; Public Law 89-755, section 1, p. 1, Nov. 3, 1966.
64. Ibid., section 5 (c) (1). p. 3.
65. Ibid., section 5 (c) (4). p. 3.
66. U.S. Department of Agriculture, Forest Service. Timber trends in the United States. In
Forest resource report No. 17. Washington, U.S. Government Printing Office,
1965. p. 102.
67. U.S. government organization manual, op. cit., p.. 245.
68. The budget of the U.S. government, op. cit., p. 252.
69. U.S. Department of Agriculture, Forest Service. Timber trends, op. cit., p. 100.
70. Ibid., p. 119.
71. Ibid., p. 102.
72. Ibid., p. 107.
73. Comptroller General of the United States. Need for effective controls of
timber-cutting practices in Pacific-Northwest region, Forest Service. Sept. 1966.
p. 4.
74. Ibid., p. 6.
132
-------
75. U.S. Department of Agriculture, Forest Service. Timber trends, op. cit., p. 58.
76. Ibid., p. 57.
77. Millett, M.A., Baker, Statter. Cattlefeed from wood residues? Southern Lumberman,
Dec. 15, 1970. p. 25.
78. Ibid.
79. U.S. Department of Agriculture, Forest Service, Forest Products and Engineering
Research Division. Forest Service concern for environmental quality.
Unpublished paper, 1970. p. 3.
80. U.S. Department of Agriculture, Forest Service. Timber trends, op. cit., p. 119.
81. U.S. Department of Agriculture, Forest Service. Forest Service concern for
environmental quality, op. cit., p. 4.
82. U.S. Department of Agriculture, Forest Service. The demand and price situation for
forest products, 1970-71. op. cit., p. 11.
83. U.S. Department of Agriculture, Forest Service. Timber trends, op. cit., p. 133.
84. Carr. W. F., U.S. Forest Service. Increased wood fiber recycling a must. Unpublished
paper, 1970. p. 5.
85. Recycling waste paper. In Proceedings; American Paper Institute, Washington, D.C.,
Oct. 16, 1970. p. 17.
86. U.S. Department of Agriculture, Forest Service. The demand and price situation, op.
cit., p. 23.
87. Ibid., p. 69.
88. Joseph E. Atchison Consultants, Inc. A preliminary study of waste paper and
prospects for its recycling. Unpublished report for the Forest Service, 1970. p. 4.
89. U.S. Department of Agriculture, Forest Service. The demand and price situation, op.
cit., p. 67.
90. U.S. Department of Agriculture, Forest Service. Unpublished tables, 1971.
91. Spooner, C. Solid waste management in recreational forest areas. Washington, U.S.
Government Printing Office, 1971. p. 11.
92. Comptroller General of the United States. Possible savings from improving the
management control of projectile fuse covers and other reusable ammunition
components, Department of the Navy. Washington, Jan. 1966. p. 1-13.
93. Comptroller General of the United States. Savings that can be attained by rebuilding
used motor vehicle tires, Department of the Air Force. Washington, June 1966. p.
1-10.
94. Comptroller General of the United States. Opportunity for improving results of tire
rebuilding programs in Europe, Department of Defense. Washington, Jan. 1971.
p. 1-18.
133
-------
95. Ibid., p. 6.
96. Department of the Army, Office of the Adjutant General. Maximum use of retread
tires. Memorandum. Washington, Aug. 5, 1970. p. 3.
97. Comptroller General of the United States. Recovery of needed parts from excess
aircraft engines, Department of the Air Force. Washington, May 1966. p. 1-10.
98. Comptroller General of the United States. Need for effective controls of
timber-cutting practices in Pacific-Northwest region, Forest Service. Washington,
Sept. 1966. p. 1-20.
99. Fellmeth, R. The Interstate Commerce Commission. New York, Grossman Publishers,
1970. p. XIV.
100. Economic report of the President. Washington, U.S. Government Printing Office,
1971. p. 123.
101. The budget of the U.S. government, op. cit., p. 468.
102. Story, W., Executive Director, Institute of Scrap Iron Steel, Inc. Verified statement
before the Interstate Commerce Commission on Ex Parte No. 267, Increased
freight rates, 1970. Oct. 14, 1970. p. 1.
103 Interstate Commerce Commission. Increased freight rates, 1971, Ex Parte No. 267.
Washington, Mar. 23, 1971. p. 219.
104. Cutler, H. Role of transportation in disposal of obsolete metallic waste, one year later.
Waste Age Magazine, July-Aug. 1971. p. 22.
105. Cutler, H. Role of transportation in disposal of obsolete metallic waste. Reprint from
Waste Age Magazine, July-Aug. 1970. p. 2.
106. Ibid., p. 4.
107. Story, W., Executive Director, Institute of Scrap Iron Steel, Inc. Iron and steel scrap
switching. Statement before the Interstate Commerce Commission. Washington,
Sept. 3, 1968. p. 29.
108. Interstate Commerce Commission. Increased freight rates, op. cit., p. 149.
109- Story, W. Iron and steel scrap switching, op. cit., p. 2.
110. American Iron Ore Association. Iron ore, 1969. Cleveland, Ohio, 1970. p. 48.
111. Ibid., p. 42.
112. Ibid., p. 41.
113. Interstate Commerce Commission, Increased freight rates, op. cit., p. 207.
114. Cutler, H. Role to transportation in recycling obsolete metallic waste, one year later,
op. cit., p. 24.
115. Interstate Commerce Commission. Increased freight rates, op. cit., p. 205.
116. Ibid.
134
-------
117. Ibid., p. 207-8.
118. Ibid., p. 209.
119. Cutler, H. Role of transportation in recycling obsolete metallic waste, one year later,
op. cit., p. 23.
120. Interstate Commerce Commission. Increased freight rates, op. cit., p. 209.
121. Ibid., p. 209.
122. Ibid.
123. Ibid., p. 207.
124. U.S. Department of Commerce. Iron and steel scrap problems. Washington, U.S.
Government Printing Office, 1966. p. 41.
125. Personal communication. W. Story, Executive Director, Institute of Scrap Iron Steel,
Inc., to SCS Engineers, Jan. 1971.
126. Personal communication. H. Cutler, Transportation Consultant, Institute of Scrap Iron
and Steel, Inc., to SCS Engineers, Sept. 22, 1971.
127. Interstate Commerce Commission. Increased freight rates, op. cit., p. 276.
128. Interstate Commerce Commission. Transportation of "waste" products for reuse and
recycling, Ex Parte No. M.C.-85. Washington, Dec. 31, 1970. p. 5-6.
129. Interstate Commerce Commission. Implementation of Public Law 91-190, National
Environmental Policy Act of 1969 and related requirements, Ex Parte No. 55
(Sub-No. 4). Washington, May 26, 1971. p. 513.
130. Ibid., p. 511.
131. U.S. government organization manual, op. cit., p. 283.
132. The budget of the U.S. government, op. cit., p. 268.
133. U.S. Department of Commerce, National Bureau of Standards. NBS technical
highlights. Washington, U.S. Government Printing Office, 1971. p. 8.
134. U.S. Department of Commerce, National Bureau of Standards. Solid waste
management: opportunities for NBS contributions. Unpublished report, Aug. 13,
1970. p. 89.
135. Ibid., p. 91.
136. The role of packaging in solid waste management. Washington, U.S. Government
Printing Office, 1969. p. 5.
137. U.S. Department of Commerce, National Bureau of Standards. Solid waste
management, op. cit., p. 1.
138. Ibid., p. 93.
139. Ibid.
135
-------
140. U.S. Department of Commerce. Iron and steel scrap consumption problems.
Washington, U.S. Government Printing Office, 1966. p. 41.
141. U.S. Department of Commerce, National Bureau of Standards. Solid waste
management, op. cit., p. 93
142. Ibid., p. 94.
143. U.S. Department of Housing and Urban Development. Urban renewal handbook.
Washington, U.S. Government Printing Office. 1968. p. 144.
144. U.S. Government organization manual, op. cit., p. 354.
145. U.S. Department of Housing and Urban Development. Urban renewal handbook, op.
cit., p. 1.
146. U.S. Department of Housing and Urban Development. Urban renewal directory.
Washington, U.S. Government Printing Office, 1970. p. 6.
147. U.S. Department of Housing and Urban Development, International brief. Washington,
U.S. Government Printing Office, Jan. 1971. p. 8.
148. U.S. Department of Housing and Urban Development. Urban renewal handbook, op.
cit., Feb. 1968. RHA 7205.1, Chapter 1. p. 1-2.
149. Ibid., Feb. 1971. RHA 7206.1, Chapter 2. p. 19.
150. U.S. Department of Housing and Urban Development. Neighborhood development
program handbook. Washington, U.S. Government Printing Office, Nov. 1968.
RHA 7380.1, Chapter 1, p. 1.
151. U.S. Department of Housing and Urban Development. Urban renewal handbook, op.
cit., Apr. 1971. Circular CD7202.6.
152. U.S. Department of Housing and Urban Development. Code enforcement grant
handbook, Washington, U.S. Government Printing Office, 1968. RHA 7250.1
153. U.S. Department of Housing and Urban Development. Demolition grant handbook.
Washington, U.S. Government Printing Office, 1968. RHA 7300, Chapter 1, p. 1.
154. U.S. Department of Housing and Urban Development. Urban renewal handbook, op.
cit., RHA 7200. p. 1.
155. U.S. Department of Housing and Urban Development. Unpublished statistical data.
156. Ibid.
157. U.S. Department of Housing and Urban Development. Urban renewal handbook, op.
cit., Mar. 1969. RHA 7209.1, Chapter 2, p. 4.
158. U.S. Department of Housing and Urban Development. Urban renewal handbook, op.
cit., May 1970. RHA 7209.1, Chapter 4, p. 3.
159. U.S. Department of Housing and Urban Development. Workable program for
community improvement, answers on codes and ordinances, program guide 1.
Washington, U.S. Government Printing Office, 1965. p. 5-6.
136
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160. U.S. Department of Housing and Urban Development. The building code dilemma.
HUD Challenge, Nov.-Dec. 1970.
161. Romney, G. Secretary of Housing and Urban Development. Letter to R.E. Train,
Chairman, Council of Environmental Quality, June 1970. 2 p.
162. Ibid.
163. Orlebeke, C. Deputy Under Secretary of Housing and Urban Development.
Memorandum to HUD personnel, July 16, 1971. 42 p.
164. U.S. government organization manual, op. cit., p. 122.
165. Ibid.
166. The budget of the U.S. government, op. cit., p. 86.
167. Ibid., p. 84.
168. Ibid., p. 86.
169. Blue Ribbon Defense Panel. Report to the President and Secretary of Defense on
DOD. Washington, U.S. Government Printing Office, July 1970.
170. U.S. Department of Defense, Office of the Assistant Secretary of Defense (Installation
and Logistics). Defense disposal manual, DOD 4160.21-M. Washington, U.S.
Government Printing Office, Apr. 1967.
171. Defense Supply Agency. An introduction to the Defense Supply Agency. Washington,
U.S. Government Printing Office, Jan. 1971. p. 7.
172. Ibid., p. 2.
173. Ibid., p. 35, 37.
174. Ibid., p. 4.
175. Ibid., p. 30.
176. U.S. Department of Defense. Defense disposal manual, op. cit., p. 3-V-4 to 10.
177. Defense Supply Agency. Program administrator's progress report (PAR), defense
material utilization and disposal programs, 4th quarter-FY 70, RCS:DDI&L Q
891. Alexandria, Va., Aug. 1970. p. 53.
178. Ibid., 2nd quarter-FY 71, Feb. 1971, p. 74-75.
179. Ibid., p. 72-73.
180. U.S. Department of Defense. Defense disposal manual, op. cit., p. 3-IV-3.
181. Ibid.
182. Ibid., p. 3-IV-3, 4.
183. Ibid., p. 3-IV-5.
184. Defense Supply Agency. PAR, 4th quarter-FY 70, op. cit., p. 3.
185. Ibid., p. 5.
137
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186. Ibid., p. 50.
187. Ibid., p. 48-49.
188. U.S. Department of Defense. Defense disposal manual, op. cit., p. 3-1-3,4.
189. Specifications, refuse collection and disposal, Langley Air Force Base, Va., 1971.
190. Personal communication. J. A. Busterud, Department of Defense, to H. F. Freeman,
Environmental Protection Agency, Nov. 23, 1971.
191. Ibid.
192. The budget of the U.S. government, op. cit., p. 125.
193. U.S. Postal Service. Finance and Administration Department. Revenue and cost
analysis, fiscal year 1970. Washington, p. 13.
194. U.S. Postal Service. Unpublished tables, Washington, 1971.
195. Ibid.
196. U.S. Department of Commerce. Survey of economic effects of third class bulk mail
rate increases. Washington, 1960.
197. U.S. Department of Commerce. Printing and publishing and allied industries,
economic summary, v. 2, No. 3. Washington, U.S. Government Printing Office,
1960.
198. The budget of the U.S. government, op. cit., p. 125.
199. U.S. Postal Service. Unpublished tables, op. cit.
200. The budget of the U.S. government, op. cit., p. 415.
201. General Services Administration. Annual report, 1970. Washington, U.S. Government
Printing Office, 1971. p. 31.
202. Ibid., p. 31.
203. Ibid., p. 36.
204. The budget of the government, op. cit., p. 418.
205. Ibid., p. 416.
206. General Services Administration. Annual report, op. cit., p. 36.
207. Ibid., p. 100.
208. Ibid., p. 36.
209. Defense Supply Agency. PAR op. cit., p. 50.
210. General Services Administration. Annual report, op. cit., p. 36.
211. Defense Supply Agency. PAR, op. cit., p. 5.
212. General Services Administration. Annual report, op. cit., p. 36.
213. Property Management and Disposal Service. GSA's solid waste recycling and disposal
activities. Unpublished paper. Washington, 1971. p. 2.
138
-------
214. Ibid.
215. General Services Administration. Annual report, op. cit., p. 9.
216. Facts about the General Services Administration. Washington, U.S. Government
Printing Office, 1970. p. 6.
217. Property Management and Disposal Service. GSA's solid waste recycling, op. cit., p. 3.
218. Quimby. T. What new incentives are needed to increase recycling. Presented at the
Composting-Waste Recycling Conference, Denver, Col., May 20-21, 1971.
219. Executive Office of the President. The budget in brief, fiscal year 1972. Washington,
U.S. Government Printing Office, 1971. p. 53.
220. Ibid.
139
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GLOSSARY
BARK
External natural covering of trees. (Tissue outside the cambium layer). Bark is
considered a contaminant in papermaking and is not readily used in other wood product
manufacture.
BAUXITE
A naturally occurring mineral ore from which aluminum metal is primarily obtained.
BOARD FOOT
A volume of wood measuring 12 in. by 12 in. by 1 in. thick.
COMMERCIAL FOREST LAND
Forest land that is capable of producing crops of industrial wood and is not withdrawn
by law from timber production.
CONSUMABLE PROPERTY
Commodities that are used up in their normal life cycle such as stationery, office
supplies, and gasoline.
CULL TREES
Live trees of sawtimber or pole timber size that are unmerchantable because of
roughness, rot, or species.
DEPLETION ALLOWANCE
An income tax deduction provided to owners of extractive industries.
EXCESS PROPERTY
There are three classifications:
A. Service excess. Property no longer required by the controlling military service.
B. DOD excess. Property determined to be unneeded by all DOD activities after
utilization screening.
C. Government excess. Commodities found to be not needed by DOD or civil agencies.
GROWING STOCK
Live trees of all sizes, meeting specified standards of quality or vigor.
GROUNDWOOD PULP
Paper pulp made from wood by mechanical grinding action with little or no attempt to
chemically delignify.
141
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GRUBBING
Clearing and breaking up land before construction begins.
INVENTORY CONTROL POINT
An organizational unit within a military service or DSA supply system that is
responsible for management of a group of specified items.
LIGNIN
The nonfibrous material in wood that bonds cellulose fibers. Lignin is removed from
wood in the chemical pulping process to free the fibers.
MINIMUM PROPERTY STANDARDS
Codification of construction requirements that must be met by builders to qualify for
Federal Housing Administration approval.
MOTOR CARRIERS
Licensed commercial freight-carrying truckers.
MULCH
A substance spread on the ground to protect roots of plants from extreme temperatures
and to suppress weed growth.
NEWSPRINT
Paper used for newspapers. Made largely from mechanical pulp with a small amount of
chemical pulp added.
PEAT
Semi-decomposed vegetative matter.
POZZOLAN
A mineral material having the property of forming a cement-like substance in the
presence of water.
PULPWOOD
A [soft] wood used in making paper pulp.
PYROLYSIS
Chemical decomposition by the action of heat.
RECLAMATION
See recycle.
RECOVERY
See recycle.
RECYCLE
As used herein, the words recycle, reclamation, salvage, reuse, and resource recovery are
interchangeable. They all refer to the practice of obtaining materials from solid wastes for
later use in a beneficial manner. Technically, each word carries a specific meaning that is not
relevant to the goals of this study.
142
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REPROCESSED WOOL
Wool material made from wool fibers that were previously manufactured but not used
by consumers.
REUSE
See recycle.
REUSED WOOL
Reprocessed wool made from wool fibers reclaimed from garments and other items
previously used by consumers.
RIPRAP
Rocks or other heavy inert materials placed on the banks of watercourses to prevent
scouring.
ROUGHAGE
Coarse, indigestible food, high in bulk, used to stimulate digestion and peristalsis in rumi-
nants.
ROUNDWOOD
Logs, bolts, and other round sections cut from trees.
SALVAGE
See recycle.
SAW KERF
Thickness of slit or cut made by a saw as it cuts through timber.
SAW TIMBER
Live trees of commercial species containing at least one saw log.
SCRAP
Discarded or rejected material or parts of material, resulting from manufacturing or
fabricating operations, that are suitable for reprocessing.
SECONDARY MATERIAL
Materials that have either fulfilled their original useful function and can no longer be
used in their present form by the owners or those materials that are generated as waste from
manufacturing processes.
SLASH
Unused or unusable forest residues killed by timber harvesting, including tree tops,
branches, leaves, and small and broken trees and tree parts.
SOLID WASTE
Useless, unwanted, or discarded solid material with insufficient liquid content to be free
flowing.
143
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UTILIZATION SCREENING
Review process used by DOD to determine availability of usable property to ensure
economical use in lieu of new procurement.
VIRGIN MATERIALS
Materials made wholly or predominantly from raw resources.
WOOD CHIPS
Various sizes of thin slices of wood produced as a result of cutting and usually produced
for the purpose of facilitating the pulping process.
144
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APPENDIX A
OFFICIALS INTERVIEWED DURING THIS STUDY
Treasury Department
John Copeland
Robert D. Hauxhurst
Leo Ingelsby
Michael Mitchell
James Murry
Richard E. Slitor
Burke W. Willsey
Ray Abernathy
Howard Anderson
Marvin Espeland
Staff Member, Office of
Tax Analysis
Space Program Manager,
Internal Revenue Service
Chief, Facilities Branch,
Internal Revenue Service
Management Analyst,
Facilities Branch, Internal
Revenue Service
Chief, Publications Branch,
Internal Revenue Service
Assistant Director, Office of
Tax Analysis
AttorneyAdvisor, Office of
Tax Legislative Council
Federal Highway Administration
Department of Transportation
Administrative Assistant, Office
of Research and Development
Chief, Environmental Design
and Control Division, Office
of Research and Development
Staff Engineer, Environmental
Development Division, Office
of Environmental Policy
145
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Ed Jastremski
Logan Ratliff
Rex I. Wells
William Wood
Roy Buckwalter
Edward Finch
Robert Freer, Jr.
Staff Member, Construction
and Maintenance Division
Chief, Federal Highways
Projects Division, Office of
Highway Operations
Chief, Office of
Environmental Policy
Chief, Construction Methods
and Practices Branch,
Construction and Maintenance
Division
Federal Trade Commission
Investigator, Division of
Textiles and Furs
Assistant Director,
Division of Textiles and
Furs, Bureau of Consumer
Protection
Staff Member, Office of the
General Counsel
John T. Drown
Barry Flamm
Norman E. Gould
Dwight Hair
Forest Service
Department of Agriculture
Chief, Forest Products
Technology Research, Forest
Products and Engineering Research
Division
Environmental Affairs
Coordinator
Staff Assistant to the Director,
Timber Management Division,
National Forest System
Assistant to the Director,
Forest Economics and
Marketing Research Division
146
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David B. Johnson
H. R. Josephson
Vernon W. Meyer
William Mitchell
Paul Neff
Dean Quinney, Ph.D.
Craig Rupp
Herbert C. Story
John I. Zerbe, Ph.D.
John A. Butcher
Will Campbell
Chief, Wood Chemistry and
Fiber Products Research,
Forest Products and Engineering
Research Division
Director, Forest Economics
and Marketing Research Division
Chief, Forest Products Utilization,
Cooperative Forest Management
Division, State and Private
Forestry
Librarian
National Forest System
Chief, Marketing Research
Branch, Forest Service
Research
Multiple Use Coordinator,
National Forest System
Associate Deputy Chief,
Forest Service Research
Director, Forest Products
and Engineering Research.Division,
National Forest System
General Accounting Office
Member, GAO-EPA Staff
Edward A. Densmore, Jr.
Lloyd Smith
Joseph Valonas
Al Voss
Member, GAOCorps of
Engineers Staff
Assistant Director, Civil
Division
Associate Director,
Civil Division
Member, GAO-EPA Staff
Associate Director, Office
of Policy and Special Studies
147
-------
Michael Zimmerman
Supervisory Civil Engineer,
GAOCorps of Engineers Staff
Interstate Commerce Commission
Michael Erenberg
Edward Margolin
Donald Shaw
Sheldon Silverman
Henry Snavely
Samuel Towne
AttorneyAdvisor, Office of
Proceedings
Director, Office of
Economics
Principal Attorney, Rate
Section, Office of
Proceedings
Director, Office of
Proceedings
Deputy Director, Operating
Rights Section, Office of
Proceedings
Chief, Section of Cost Finding,
Bureau of Accounts
National Bureau of Standards
Department of Commerce
Charles T. Mahaffey
Karl F. Plitt
Eric A. Vadelund
William K. Wilson
Assistant Chief, Codes
and Standards Section,
Building Research Division,
Institute for Applied Technology
Chief, Products Systems
Section, Product Evaluation
Technology Division,
Institute for Applied Technology
Program Manager, Fair
Packaging and Labeling Act,
Office of Weights and Measures,
Institute for Applied Technology
Chief, Paper Evaluation
Section, Product Evaluation
Technology Division, Institute
for Applied Technology
148
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Office of Community Development
Department of Housing and Urban Development
Ardee Ames
Floyd B. Arms
Abram Grossman
Helen Halbig
George Karas
Robert Reichel
S. T. Strang
George Wright
Ernest Zupancic
Executive Administrator,
Office of Housing Management
Director, Program Management
and Program Training Division,
Office of Renewal Assistance
(Now within OCD)
Chief, Planning and Engineering
Branch, Redevelopment Division,
Office of Renewal Assistance,
(Now within OCD)
Chief, Organization Management
Branch, Renewal and Housing
Management Division
Chief, Program Regulations
Division
Chief, Codes and Demolition
Projects Branch, Special
Renewal Division, Office of
Renewal Assistance (now
within OCD)
Assistant Chief, Codes and
Demolition Projects Branch,
Special Renewal Division,
Office of Renewal Assistance,
(Now within OCD)
Staff Member, Office of the
Deputy Under Secretary
Staff Member, Program
Management and Program Training
Division, Office of Renewal
Assistance, (Now within OCD)
149
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Major Johan Bayer
Col. Herbert Bell
George Cunney
Harry Graham
Edward Cramps
John Henley
Wayne Hudson
Col. C. King
Jay Masenich
George Moss
Clark Sessions
P. Somerville
A. Weis
Department of Defense
Environmental Office, Civil
Engineering Group, U.S. Air Force
Staff Assistant, Office of
Assistant Secretary of
Defense (Health and Environment)
Acting Chief, Environmental
Office, Directorate of Installations,
U.S. Army
Chief, Materiel Control,
Langley Air Force Base,
U.S. Air Force
Property Utilization
Specialist, Defense Supply
Agency
Construction Representative, Langley
Air Force Base, U.S. Air Force
Environmental Protection
Engineer, Tactical Air
Command, Langley Air Force Base,
U.S. Air Force
Supply Systems Division,
U.S. Air Force
Defense Supply Agency
Supply System Division,
U.S. Air Force
Industrial Specialist, Field
Support Division, Defense
Supply Agency
Chief, Technical and
Logistics Services, Disposal
Division, Defense Supply Agency
Staff Member, Programs
Management Branch, Disposal
Division, Defense Supply
Agency
150
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United States Postal Service
Herman Dodson
Arthur Eden
Maria Eldridge
David F. Harris
Rita Moroney
James R. Thomasen
Stuart Winston
Expert Consultant,
Consumer Affairs Department
Director, Office of Rates and
Classification
Director, Office of
Statistical Programs and
Standards
Chief Administrative
Officer, Postal Rate
Commission
Director of Research, Office
of the Postmaster General
Deputy Assistant Postmaster
General and Comptroller
Manager, Rates Division
General Services Administration
Marshall Anderson
Peter Glading
Tom Kopp
Beatrice Lipman
Herbert Matthews
Robert McNolty
Chief, Building Services
Branch, Region 3, Public
Building Service
Director, Sales Division,
Property Management and
Disposal Service
Staff Member, Office of
Environmental Affairs
Special Projects Officer,
Region 3, Property Management
and Disposal Service
Chief, Sales Branch, Region 3,
Property Management and
Disposal Service
Assistant Director, Office
of Environmental Affairs
151
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J. Ward
Donald Butts
John Granger
Jacob Levin
Leonard Mobley
Howard Post
Building Manager, Public
Building Service
Department of Commerce
Pulp and Paperboard Division,
Bureau of Domestic Commerce
Office of Textile, Bureau
of Domestic Commerce
Metals Division, Bureau
of Domestic Commerce
Office of Textile, Bureau
of Domestic Commerce
Pulp and Paperboard Division,
Bureau of Domestic Commerce
Department of the Interior
Robert Adams
Charles Kenahan
William Vogley, Ph.D.
L. Knowles
S. Pendleton
Staff Member, Statistics
Department, Bureau of Mines
Chief, Division of Solid
Waste, Bureau of Mines
Director, Office of Economic
Analysis, Office of the
Secretary
Congressional Offices
Staff Member, Joint Economic
Committee
Staff Member, House Committees
on Post Office and Civil Service
National Academy of Sciences
Robert Crozier
Executive Secretary for
Committee on Pollution
Abatement and Control
152
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Non-Federal Government
James Abert, Ph.D.
Blair Bower, Ph.D.
Phillip L. Buckingham
Herschel Cutler, Ph.D.
Ralph O. Foster
James A. Hagen
James Harkins
Norman Heller
H.Jackson
Jerome Klaff
Howard Ness
James Parker
Norman Quimby
Earl Thompson
Eugene Wingerter
Director of Research,
National Center for Resource
Recovery, Inc.
Resources for the Future, Inc.
Director, Solid Waste Services,
Southern Railway System
Transportation Consultant,
Institute of Scrap Iron
and Steel, Inc.
Market Analyst, Southern
Railway System
Director, Market Research
Section, Southern Railway
System
American Truckers Association
General Manager, Services
Industries, Southern Railway
System
American Textile Manufacturing
Institute
President, H. Klaff and
Company, Inc.
National Association of
Secondary Materials Industries
Textile Fibers and Byproducts
Association
Resources for the Future, Inc.
Textile Fibers and Byproducts
Association
Technical Director,
National Solid Waste
Management Association
AU.S.Government Printing Office: 1972 759-909/3122
Region No. 5-11
153
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