! 1-623
                                  RESOURC E
                                    R  ECOVERY
                                               H-NOLOGY
                                               JPDK
                                     FROM  THE  USEJ?k
                                     Office of Solid Waste Management Programs
        THE RESOURCE CONSERVATION  AND  RECOVERY ACT

             OF 1976:  HOW WILL IT  IMPACT ON RESOURCE

                      RECOVERY AND CONSERVATION?
                                              By
                              Nicholas Humber and Stephen Lingle
      On October 21, 1976, the Resource Recovery and
     Conservation Act of 1976 was signed into law as Pub-
     lic Law 94-580. The authorities provided by the Act
     are far broader than suggested by the title. The new
     regulatory authorities on hazardous wastes manage-
     ment, the closing of open dumps and the creation of
     environmentally sound sanitary landfills for other
     wastes are the major new thrusts of this legislation.
     The 1978 funding authorizations are:
                           FY 78 Authorizations
                             (million dollars)

       General Authorization           40
       Hazardous Waste
        Management Programs
        (Subtitle C)                  25
       State Planning Programs
        (Subtitle D)                  30
       Implementation Grants
        (Subtitle D)                  15
       Rural Assistance Grants
        (Subtitle D)                  25
       Special Grants (Subtitle D)       2.5
       Research, Development,
        and Demonstration
        (Subtitle H)                  35
     Nicholas Humber
     is Director of the
     Resource Recov-
     ery Division, Office
     of Solid  Waste.
     Stephen  Lingle
     is Chief  of  the
     Technology and
     Markets Branch,
     Resource Recov-
     ery Division and
HUMBER
LINGLE
    edits the Technology Update series.
                             Special Studies (Subtitle H)        8
                             Resource Conservation
                              Committee (Subtitle H)          2

                            True to its title, the Act contains several significant
                           provisions, which, if carried out as proposed, would
                           stimulate implementation of resource recovery and
                           resource conservation. These provisions  include
                           technical assistance, elimination of open dumping; re-
                           search, development, and demonstration; a Cabinet-
                           level Resource Conservation Committee; and federal
                           procurement.
 Technical Assistance
  Section 2003 of the Act calls for establishment of
 Resource Recovery and  Conservation Panels. This
 section requires that EPA provide teams of personnel
 to provide States and local governments, upon re-
 quest, with technical assistance on solid waste man-
 agement, resource recovery, and resource conserva-
 tion. The teams  are to include technical, marketing,
 financial, and institutional specialists. Their services
 would be provided without charge  to States or local
 governments. The Act mandates that not less than 20
 percent of the general appropriation for the Act must
 be used for the panels.

  The concept of technical assistance is  not new to
 the federal solid  waste program, but the  specific re-
 quirement that multidisciplinary assistance be pro-
 vided and that a significant portion (20 percent) of the
 budget be allocated to this activity clearly indicates
 Congress' intent to expand and emphasize this activ-
 ity.

  Technical assistance has been viewed by EPA as
an activity which will  alleviate the constraints EPA
sees as inhibiting the  progress of resource recovery
implementation. The marketing, financial, contractual,
and legal realities of  resource recovery are  unique

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and,  thus, unfamiliar to  many municipalities. The
technologies and techniques which must be employed
are, in many cases, not fully developed and in most
cases, not well understood by municipal governments.
Source separation and waste reduction are often over-
looked as alternatives. Technical assistance can be a
valuable asset  to municipalities in addressing these
issues.
   EPA has carried out technical assistance  in the
past,  with generally impressive results for a modest
effort. The expanded authority  provided  in the Act
provides the potential for far more impressive impacts
through greater resources. Furthermore, this mandate
can  be implemented  and expected to show results
more quickly than many of the other resource  recov-
ery provisions. It is precisely the kind of activity which
EPA,  as well as others who testified before Congress
on this legislation, felt was needed at this time.
   The exact manner in which EPA will carry out this
mandate is still being developed. However, it seems
clear  that EPA regional offices and private consultants
under contract to EPA will play major roles.
Sfafe Plans /Elimination of Open Dumping
  Guidance  and financial assistance for development
of state solid waste plans is authorized in Subtitle D of
the Act.  Although generally not thought of as a re-
source recovery provision, Subtitle D  could be one of
the most significant in terms of impact  on resource
recovery.
  The  stated objective of Subtitle D is to "assist in
developing and encouraging methods for the disposal
of solid waste that are environmentally sound and that
maximize the utilization of valuable resources and en-
courage  resource conservation." Authorities that re-
late  directly  to  resource recovery include  guidelines
for development of  plans, technical  assistance, and
implementation grants.
  The guidelines for plan development  are advisory
rather  than  mandatory. However, they offer a signifi-
cant new opportunity for EPA to provide assistance to
States in determining how resource recovery and
conservation can fit into their overall solid waste man-
agement plans. This is particularly true when the pro-
visions of Subtitle D for technical assistance and im-
plementation grants are included.
  The states  and their designated  solid  waste re-
gional  agencies stand as major potential recipients of
the technical assistance panel program required in
Section 2003. Together, the guidelines and technical
assistance can be of significant benefit to the states in
their development and implementation of plans.
  The provision for implementation grants carries this
one  step further. Implementation grants can be pro-
vided  to carry  out specific solid waste management
and  resource recovery programs. This assistance can
include "planning and feasibility studies;  consultation;
surveys  and analysis of market needs;  marketing of
recovered resources;  technology assessments; legal
expenses; construction  feasibility studies; source
separation projects; and fiscal or economic investiga-
tions or  studies."  No construction expenses are al-
lowable,  however.
  The greatest benefit to resource recovery is likely to
be  the provisions  of Subtitle D which  relate to land
disposal. By October 21, 1977, EPA  is required  to
develop  criteria defining open dumps  and  sanitary
landfills.  Within  one year of promulgation  of these
criteria, States are required to publish an inventory of
open dumps. One of the requirements for  EPA ap-
proval of State plans (and subsequent  approval of fi-
nancial assistance)  is that the  plans  provide a
schedule for closing or upgrading of all  open dumps.
  Although states can have as long as five years from
the date  of publication of the inventory  to upgrade  or
close open  dumps, the Act suggests  that this time
frame is allowable only when  other alternatives  to
these dumps cannot be employed more quickly. This
provision may be an inducement for citizens to bring
suit to close open dumps.
  The removal of environmentally unacceptable land
disposal will eliminate an unrealislically  low cost alter-
native for waste disposal that has limited the attrac-
tiveness of resource recovery to municipalities. There-
fore, the  regulation of land disposal should provide a
major new incentive and opportunity for resource  re-
covery.

Research, Development, and Demonstrations
  This act is similar in  RD&D authorities to  its pre-
decessor, the 1965 Solid Waste Disposal  Act  as
amended by the Resource Recovery  Act of 1970.
EPA is authorized  to provide financial support for  re-
search, development, and demonstration of promising
techniques for recovery of resources from solid waste.
Grants or contracts to public agencies  or the private
sector are permitted. In addition,  EPA  is  directed  to
enter into contracts to provide monitoring of full-scale
solid  waste  facilities, whether or not partially funded
by  EPA.
  The major differences between this and the previ-
ous Act in this regard are the following: 1) Under the
new Act, it  is possible to  contract directly  with the
private sector for construction of full-scale demonstra-
tion facilities,  in  addition to making  grants   to
municipalities; 2) The evaluation by EPA of munici-
pally or privately owned facilities is unique to the new
Act; 3) The  Act specifically authorizes construction of
pilot plant facilities; 4) The funding authorizations  in
this Act are  somewhat larger than those in the previ-
ous law; i.e., the new legislation authorizes $35-
million for these  and other provisions of Subtitle H.

  In addition to these "hardware" provisions  of Subti-
tle  H, several studies are mandated. One study will
evaluate small-scale  and  low  technology recovery
techniques, including  source separation  of solid
waste. Similarly, a  study of the compatibility of source
separation and  high technology  resource recovery
systems  is mandated.
  The impact which these provisions  may  have  on
development of resource recovery technology will de-

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 pend largely on the appropriations provided for Subti-
 tle H. Appropriations can be for the full amount au-
 thorized, but frequently are less.  Appropriations are
 not expected before late spring.
cally efficient incentive package is developed that is
attractive to Congress,  a major change in resource
recovery markets could result.
   One of the most significant resource recovery pro-
 visions of the previous solid waste act, the Resource
 Recovery Act of 1970, was the authorization for full-
 scale demonstration  facilities, Section 208. Approxi-
 mately $20-million was ultimately appropriated  under
 Section 208. One might guess that demonstration ap-
 propriations under the Resource Conservation and
 Recovery Act would,  at best, be of similar magnitude
 if significant appropriations are made.  Even if the full
 authorization of $35-million  is appropriated, the fund-
 ing will be sufficient to support only two or three dem-
 onstrations  of limited  scale,  several  source separation
 demonstrations, and  research and development sup-
 port  studies. However, even this level of funding is
 uncertain.

   The new Act did not provide funding for construc-
 tion grants, loans, or  loan guarantees to subsidize the
 construction of resource recovery facilities. A loan
 guarantee provision  was included in early drafts but
 was  dropped because  of convincing arguments and
 evidence that well-conceived resource recovery proj-
 ects were  already  attractive to municipalities and
 could be financed without federal involvement.
Federal Procurement Guidelines
  The failure  of the federal  government to provide
leadership in the procurement of products  manufac-
tured from recycled resources has long been pointed
out as a failure in federal leadership. Section 6002 of
the Act requires widescale federal leadership in pro-
curement of such products. Agencies are instructed to
eliminate any  bias in specifications  against products
containing recycled materials and to  procure products
containing the highest percentage of recycled materi-
als practicable. Associated with this  mandate is a re-
quirement that EPA write guidelines to aid  federal
agencies in complying  with this mandate. These
guidelines will, in  essence, clarify the potential and
opportunities for such procurement.
  Federal purchases alone constitute only a small
percentage (less than 2 percent) of  the total national
consumption of any given product. However, the po-
tential for such practices being adopted  by state and
local  governments is significant.  If this "ripple effect"
takes place, the result could be  an  important expan-
sion in the market for recovered resources.
Resource Conservation Committee
  Economic inequities of the marketplace that dis-
criminate against recycled resources have long been
recognized as one  of the major impediments to re-
source recovery. A  number  of incentives have been
proposed  to Congress, but none have been accept-
able.
  The Resource  Conservation Committee is  a
Cabinet-level committee, chaired by the Administrator
of EPA and  comprised of the Secretaries of Com-
merce, Labor, Treasury, and Interior,  as  well as the
Chairman of the Council  on Environmental Quality
and a representative of the Office of Management and
Budget.

  The Committee is charged with analyzing and re-
porting recommendations to Congress  on a wide
range  of incentives and disincentives to foster re-
source recovery and  conservation.  This includes
analysis of the effect of removing existing subsidies
and allowances for virgin materials. It also includes a
specific mandate to  evaluate the feasibility of employ-
ing solid waste management charges  (product
charges) that reflect the costs of collection, disposal
or recovery of products.

  The high-level representation of this committee, as
well  as the specificity of its mission, suggest that
Congress is serious about correcting the economic
inequities that have restricted resource recovery in the
past.

  Results of this committee  are required to be re-
ported to Congress  by October 1979.  If an economi-
Conclusions
   The problems and constraints  inhibiting a more
rapid rate of  resource  recovery implementation are
addressed appropriately in the Resource Conserva-
tion and Recovery Act of 1976. Federal funding pro-
grams for plant construction were not included in this
legislation.

   However, a need  to  provide technical  assistance
was well  satisfied in the Act. Authorities to continue
technology research and  development were needed
and were provided. The significant issue of economic
inequities between virgin  and recycled resources,
though not resolved by  the Act, was addressed in  a
way that suggests that in two to four years, a legisla-
tive solution could emerge. Cheap, but  environmen-
tally unacceptable land disposal, is clearly on its way
out, thus enhancing the  potential for resource recov-
ery. The federal  house will at last be put in order as
the result of  new requirements relating  to procure-
ment, and the implementation of  previously  issued
guidelines for mandating recovery of  both materials
and energy.

  Yet, though the authorities are generally correct, the
overal impact is still uncertain. The level  of resources
ultimately  to be appropriated by Congress is still not
determined. Within the Agency, the realities of having
to issue regulations required in the Act by mandated
deadlines, tend to direct attention  and resources to
those activities.                                 •
                                   Reprinted from Waste Age - April 1977

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