QUESTIONS AND ANSWERS
                       f^.            T ..-_ .1.._ -

                   RETURNABLE BEVERAGE CONTAINERS
                      FOR  BEER AND SOFT  DRINKS

                             July 1975
1.  What are returnable beverage containers?

    Returnable beverage containers are containers that are accepted
    for return after use.   Usually a cash deposit is paid when  the
    beverage is purchased  and refunded when the container is returned.
    The purpose of the deposit is to provide an incentive for the
    return of the container either for refilling or for recycling of
    the container materials.

2.  What are the environmental and resource conservation benefits of
    returnable beverage containers?

    The return of beverage containers reduces the generation of beverage
    container waste and litter.  Reuse and recycling of containers
    reduces air and water  pollution resulting from the production of
    containers, and conserves energy and materials.

3.  What is mandatory beverage container deposit legislation?

    Mandatory deposit legislation is a law or ordinance which requires
    a deposit on all beverage containers sold in a particular jurisdiction,

4.  Is there mandatory deposit legislation in existence today?

    Three States have enacted mandatory deposit or returnable container
    laws for beer and carbonated soft drinks:  Oregon, Vermont  and
    South Dakota.

    In Oregon, a refund value of 2 cents is carried by all  "certified"
    containers, which can  be reused by more than one manufacturer.
    All other containers carry a refund value of 5 cents.   Metal
    containers with detachable tab tops are banned.

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    In Vermont,  all  beer and  soft  drink  containers carry a refund
    value of at  least 5 cents.   The manufacturer  or distributor is
    also required to pay the  retailer  a  fee of 20 percent of the
    deposit (1 cent  per 5 cent-deposit container) to cover the costs
    of handling  the  returned  containers.   In January 1977 nonrefillable
    bottles will  be  banned in Vermont, as  will metal containers with
    detachable tops  and non-biodegradable  container carriers.

    South Dakota has passed a law  which  requires  that every beverage
    container sold in that State,  subsequent to July 1, 1976 shall be
    either a reuseable container or a  container which is biodegradable.

    Several communities including  Bowie, Maryland; Loudoun County,
    Virginia and Ann Arbor, Michigan  have  passed  similar laws which
    have not been implemented due  to  legal challenges.

5.   Does mandatory deposit legislation eliminate  the use of the metal
    can as a beverage container?

    Mandatory deposit legislation  does not prohibit the use of metal
    cans.  However,  in Oregon,  after  passage of the law, the use of
    refillable bottles increased and  the use of cans decreased.  For
    soft drinks, refillable bottles increased from 53 percent of the
    market prior to  the law to  88  percent  of the  market in the year
    following the law.1  Soft drink cans decreased from 40 percent of
    the market to 12 percent.2   Refill able beer bottles increased
    from 31 percent  of the market  before the law  to 96 percent after-
    wards.   Beer cans declined from  40  percent to 3.5 percent.
    The use of nonrefillable  glass bottles was practically eliminated
    for both beer and soft drinks.

    In Vermont comprehensive  data  on  pre-law and  post-law container
    useage is not available.  However, as  of April 1975, cans and
    nonrefillable bottles were  still  being sold for both beer and soft
    drinks, but  a trend towards more  wjdescale use of refillable bottles
    for soft drinks  has been  reported.5

    Nationwide in 1972 approximately  39  percent of all soft drinks
    were packaged in refill able bottles, 27  percent in nonrefill able
    bottles and  34 percent in cans.6   For  beer the figures are
    approximately 18 percent  for refillable  bottles, 24 percent for
    nonrefill able bottles and 58 percent for cans.7  The market mix of
    containers varies significantly for  different geographic regions.

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          Mandatory deposit  legislation would probably result in a shift
          towards  the  increased  use of refill able bottles.  Nonrefiliable
          glass  bottles may  well disappear from the market  (however for larger
          sizes  nonrefillable  bottles may remain).  Cans would probably decline
          in market share  but  would remain in some quantities, especially in
          areas  where  they are currently predominant.

      6.   How much solid waste can be prevented by such laws?

          On a national basis, beer and soft drink containers accounted
          for 8  million tons of  solid waste in 1973.°  This represented
          6 percent of total municipal (household and commercial) waste.
          Beverage containers  are a rapidly growing segment of municipal
          waste, with  an estimated growth rate of 10 percent per year from
          1962 to  1972.9

x        If 90  percent of the containers bearing a deposit were returned
^>        for refilling or recycling, there would be a reduction in beverage
          container waste  of 70  to 75 percent, or 5 to 6 million tons on a
          national basis.
~%j
      7.   What about littered  beverage containers?

^        Most studies show  that beer and soft drink containers comprise
t/->        between  20 to 30 percent of roadside litter by item count.10'']»12
^;        However  many other littered items are smaller and less visable
r^        than beverage containers and degrade more rapidly in the natural
^        environment.  On a volume basis, which is a better measure of litter
          visibility,  beverage containers have been found to represent
          62 percent of highway  litter.''  For the year following enactment
          of deposit legislation, beverage container litter decreased by
          66 percent in Oregon and by 67 percent in Vermont.13'5

      8.   How much energy  could  be saved by use of returnable containers?

          Beverage containers  that are refilled or recycled save energy and
          materials.   A glass  beverage container used 10 times consumes less
          than one-third of  the  energy of nonreuseable containers used to
          deliver  the  equivalent quantity of beverage.14  Aluminum and all-
          steel  cans that  are  recycled save 78 and 39 percent, respectively,
          of the energy required to manufacture a can from virgin raw
          materials.1^

          The energy that  would  be saved through mandatory legislation depends
          upon the resulting container mix and the return and recycling rates
          for the  containers.  For example, if national mandatory deposit
          legislation  had  been in effect in 1973, and if the bottle and can
          container mix had  not  changed, and if 90 percent of all bottles
          had been returned  and  refilled and 80 percent of all cans had been

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     recycled, approximately 151  trillion  British Thermal  Units  (BTU)
     of energy would  have  been  saved.   If  on  the other  hand  in 1973
     refillable bottles  had  represented 80 percent of the  market share
     (and bottle and  cans  had been  returned and recycled at  the above
     rates)  approximately  209 trillion  BTU's  of energy  would  have been
     saved.16

 9.   How significant  are these  energy savings?

     A saving of 209  trillion BTU's is  equivalent to the energy content
     of 39 million barrels of oil.   It  is  also equal to about one-half
     of the  energy used  in producing the current mix of beverage containers,
     While this amounts  to a saving of  just 0.3 percent of total national
     energy  use, it is  important  to note that it is of  similar magnitude
     to the  saving achievable through other energy conservation measures
     currently being  considered.  For example, it is equivalent to one-
     half of the energy  saving  that can be achieved from strict
     enforcement of a 55 mile per hour  speed  limit nationwide.!7

10.   How much materials  could be  saved  through the use  of  returnable
     containers?

     If in 1973 90 percent of all bottles  had been refilled,  and
     80 percent of all  cans  had been recycled, between  5 and  6 million
     tons of raw materials would  have been saved that year.   This would
     represent a savings of  3.8 to  4.6  million tons of  glass, 1.1 to
     1.3 million tons of steel  and  300,000 to 350,000 tons of aluminum.16

11.   How would a returnable  system  affect  beer and soft drink prices?

     Beer and soft drinks  sold  in refillable  containers are  generally
     cheaper to the consumer than beverages in one-way  bottles and
     cans.  Savings in  the range  of $.03 to $,05 per 12 ounce container
     have been frequently  observed.1**'   '»    However, it  has been
     argued  that the  costs of handling  and transporting returned
     containers are not fully reflected in retail prices.  These costs
     have been estimated to  range from  less than $.01 to $.02 per
     container.22,23   Therefore,  even if these costs are assumed not to
     have been reflected and are  added, beverages in refillable
     containers cost  less  to the  consumer. To the extent  that
     mandatory deposit legislation  induces a  shift to refillable
     bottles, average prices for  beer and  soft drinks should  decline.

     However, it should  be pointed  out  that a rapid widescale shift to
     an all  refillable bottle system would require considerable equipment
     changeover in the brewing  and  soft drink industries and  would result
     in additional costs that could be  passed on to the consumer.  If
     the transition to refillables  takes place gradually over a  period
     of years, the costs of  rapid changeover  would be avoided.

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12.  How many times do containers have to be returned before energy and
     cost savings are achieved?'

     For an energy saving to be achieved from use of a refillable  bottle,
     it must make at least four trips or have a return rate of 75  percent.24
     Refillable bottles generally become cheaper than one-way containers
     at return rates of 80 percent (5 trips), although this varies from
     bottler to bottler.25

     In Oregon one year after passage of the deposit law,  refillable
     soft drink containers were returned at a 96 percent rate,2^ and
     refillable beer containers at an 80 to 95 percent rate.2''2**
     Approximately 65 to 70 percent of all  cans were being returned and
     this rate was increasing.26,28  Detailed data are not available
     from Vermont, although several bottlers have indicated return
     rates of 90 to 95 percent.5

     The subject of average national  return rates for refillable bottles
     is a matter of considerable debate.  An estimate calculated by dividing
     container fillings by container purchases results in  an average return
     rate during the period 1963 to 1972 of 94 percent for soft drinks  and
     96 percent for beer.29  These figures  may not represent actual
     return rates since bottle inventories  may have been changing.
     Furthermore, these figures include both "on-premise"  beverage
     consumption (in taverns and restaurants) where return rates would
     be expected to be higher than for "off-premise" consumption (e.g.
     beverages purchased from supermarkets  or retail stores).   Another
     estimate indicates soft drink container trippage of 10 to 1530
     (return rate of 90 to 94 percent) and  a beer container trippage of
     183' (return rate of 95 percent).

     In any case, for a mandatory deposit system it appears reasonable
     to expect a return rate for beer and soft drink containers that
     would be much greater than that necessary for energy  and cost savings.

13.  How would a mandatory deposit law impact on the beverage production,
     container manufacturing and distribution industries?

     The impacts of mandatory deposit legislation upon industry would
     depend upon the extent of the change in the market mix of containers
     and the time period over which this change takes place.   Most estimates
     of economic impact have been based upon the extreme assumption of  a
     complete and sudden switch to refill able bottles.  Under these
     circumstances, facilities for the production, storage and distribution
     of one-way containers, not convertible to returnable  systems, would
     become obsolete and would have to be replaced.   Glass and metal
     container production would decline.  Bottlers and brewers would
     initially have to  invest  in  additional  bottle washing  equipment and
     refillable container lines.   Additional  transportation costs  would

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     be  incurred  for  the distribution of beverages and the return of
     containers.   Some retailers would need additional storage space
     and would  have to add employees to handle returned containers.

     Based  on 1969 data in an industry-sponsored study of the impacts of
     a ban  on nonrefillables, tax writeoffs would amount to $1.3 billion,
     and total  new investments $1.2 billion.    More recently the brewing
     industry has claimed total "conversion costs" of $5 billion for a
     sudden switch to refillables and a ban on one-way containers.33

     The 1969 study indicated that cost increases in the brewing and
     soft drink bottling industries would be more than offset by container
     cost savings.3^  Some of these sayings could also be passed on
     to  beverage  distributors and retailers to offset increased costs in
     these  sectors.   The study found that the aggregate cost to all
     sectors of the industry (beverage producers through retailers,
     inclusive) would be $250 million in the first year of a ban, but
     would  actually become a $40 million gain in subsequent years due
     to  container savings.

     Tax losses and new investment requirements would be lower for a
     mandatory  deposit system in which nonrefillable containers were
     not completely eliminated.  Capital losses would be reduced if
     time were  allowed for normal amortization of current investments
     over a period of years.  A 1975 study for the State of New York,
     assuming a 3 year phase-in to a market mix of 80 to 90 percent
     refillables, concluded that new investment requirements in that
     period would be  $53 million per year, compared to a normal
     investment requirement of $30 million per year with no legislation.35

     It  should  also be noted that normal industry competition resulting
     in  changes in relative container prices or introduction of new
     container  types  (such as the plastic bottle) could have similar
     impacts on the container industries.

14.   What would be the effect of National mandatory deposit legislation
     on  employment?

     The impact of mandatory deposit legislation upon employment would
     also depend  on the rate of change of container useage.  A rapid shift
     toward the use of refillable bottles would eliminate some jobs,
     primarily  skilled positions in the container manufacturing industries.
     It  has been  estimated that a complete ban of nonrefillable containers
     in  1969 would have resulted in the loss of 60,000 jobs that year.
     However it was also estimated that the establishment of a returnable
     system would also create a roughly equal number of new jobs,
     primarily  jobs of lower skill classification and pay, in the  retail
     and distribution sectors of the economy.    It is important to note
     that the employees displaced would not be directly transferable to

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     these new jobs.   Employment dislocations  would  be  reduced  if
     nonrefiliable bottles and metal  cans  continued  to  be  sold  or
     if the change in container useage took place  over  a period of
     time.  A transition period would allow natural  attrition in
     employment to absorb some of the job  losses.  Also it would
     provide time for employment to  shift  to other plants  or
     industries manufacturing other  containers or  similar  products.
     For example, it  has been estimated that a gradual  transition
     over a 5 year period to a 90 percent  reduction  in  nonrefillable
     containers would result in the  loss of 39,000 positions.37
     A 10 year transition to a similar market  would  result in the
     loss of about 17,000 positions.37

     Studies conducted for the States of Maryland, Minnesota, New York,
     Connecticut, Illinois, Michigan and Maine all found that the job
     gains in the retail and distribution  sectors  would be greater  than
     the losses in container manufacturing.38'44   in New York,  for
     example, a job gain of 5,200 and a loss of 1,200 jobs was
     predicted, with  a net annual payroll  increase of $35  million.45

     In Oregon, where a deposit law  is in  effect,  one study estimated an
     addition, of 175 to 200 new jobs and  a loss of  340 to 427  existing
     jobs but did not estimate job increases in retail  stores.4^
     Another study estimated a net job gain of 365 jobs (including
     retail).47

15.   Is mandatory deposit legislation at cross-purposes with plants built
     for the recovery of energy and  materials  from waste?

     A resource recovery plant processes mixed municipal waste  in order
     to extract materials and other  products which can  be  sold.  Changing
     the composition  of municipal waste through mandatory  deposit
     legislation would not significantly affect the  economics of most
     resource recovery plants.  Approximately  80 percent of the municipal
     waste stream is  organic materials—paper, plastics, etc.   This
     fraction should  be the primary  concern of a resource  recovery
     facility, as it  represents the  bulk of the waste,  and provides the
     bulk of revenue  ($10 to $15 per ton of waste  processed) needed to
     make resource recovery economically feasible.48

     As a maximum result of mandatory deposit  legislation, glass in the
     waste stream could be reduced by about 35 to  45 percent, ferrous
     metal wastes could be reduced by 15 percent,  and,  where use of
     aluminum cans is substantial, aluminum wastes could decline by 30
     to 45 percent.   Under favorable  market conditions, gross revenues
     from the beverage container fraction  of the waste  stream amount to
     about $1 to $2 per ton of waste  processed.  When the  costs  of
     recovering and transporting these fractions are considered, the
     net revenue contribution is considerably  less.   Removal of the

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                                   8
     beverage container fraction  through a mandatory deposit system
     would probably not cause  a net  revenue reduction  in excess of
     $1  per ton of waste processed.49

     It  should be  emphasized that recovery technologies for glass and
     aluminum are  for  the most part  not yet fully demonstrated and
     markets for recovered glass  and metal resources have just begun
     to  be developed.   In light of the uncertainties of separating and
     marketing aluminum and glass from solid waste, beverage container
     legislation does  not entail  undue risk for  the installation of
     resource recovery facilities.

     Resource recovery system  feasibility should not be decided solely
     on  the basis  of glass, aluminum and steel recovery economics.
     Other more important factors are the general uncertainty regarding
     future markets (especially for  the organic  fraction) and the insti-
     tutional  obstacles to organizing and implementing a venture of this
     sort.  A significant number  of  future recovery investment decisions
     should not be adversely impacted by mandatory deposit legislation.

16.   Are there other mechanisms,  such as the litter tax enacted by the
     State of Washington, that will  achieve benefits similar to a
     mandatory deposit law?

     Litter taxes  are  generally very small taxes (a fraction of a cent
     per product)  imposed at the  time of sale  of products likely to be
     littered.  Such taxes could  provide additional revenues to collect
     litter along  streets, highways, and recreational  areas.  The major
     shortcoming of a  litter tax  is  that it does not create a disincentive
     for littering (the tax is paid  regardless of whether the individual
     purchasing the product litters  the item or  not).  Furthermore, such
     a mechanism would not reduce the generation of solid waste, nor
     would it result in savings of energy or materials.  Thus while a
     litter tax is not incompatible  with mandatory deposit legislation,
     it  is not a substitute for such legislation.

17.   Is  there a sanitation problem in storing  used containers?

     While there is a  possibility of insect problems associated with  the
     storage of bottles and cans  containing beverage residues, it should
     be  noted that returnable  containers have  been used for many years
     without significant adverse  public health impacts.   If public health
     laws and sanitation codes are strictly enforced,  and containers  are
     picked up on  a frequent and  timely basis, such problems should be
     minimized.

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18.   Isn't there a loss  of convenience  to  the  consumer?

     A deposit law does  not require  return of  the  container,  but does
     make the consumer who discards  the container  pay  the amount of  the
     deposit.  A study for the State of Oregon found that 87  percent
     of those surveyed found no inconvenience  with returnables.^O
     Furthermore this  survey found that 91  percent of  the respondents
     approved.of the legislation and only  5 percent voiced any disapproval
     at all.51

19.   What is the position of the U.S. Environmental Protection Agency
     on mandatory deposit legislation at the Federal,  State and local
     levels?

     The U.S. Environmental  Protection  Agency  has  testified in favor of
     the adoption on a nationwide scale of a mandatory deposit system
     for beer and soft drink containers.^  Based  upon several years of
     analysis and observations in the States which have enacted mandatory
     deposit laws, it  is concluded that a  mandatory deposit program
     would result in significant conservation  of energy and materials,
     and a reduction in  solid waste  and litter caused  by beverage
     containers.   A sudden shift to  a returnable system, however, would
     likely result in  excessive economic disruption and unemployment.
     To minimize the adverse economic repercussions, it is recommended
     that a nationwide system be phased in over an extended period of
     time.

     While ideally such  legislation  should be  national, State-level
     legislation, based  upon the experience in Oregon  and Vermont, also
     appears to be effective in achieving  the  benefits.  Below the
     State-level, ordinances requiring  mandatory container deposits  would
     probably be effective in large  regions, counties  or metropolitan
     areas.  Not enough  experience has  been acquired to indicate whether
     local ordinances  for smaller communities  would be effective.

     EPA neither supports nor opposes State or local deposit  legislation.
     EPA favors national  legislation in this area  and  has decided not
     to promote the adoption of State or local  laws, which may be super-
     seded by a national  law at a later time.   Furthermore the Agency
     does not have the resources to  analyze the economic impacts of
     different State laws.  However  EPA does not oppose State or local
     deposit legislation that is designed  to reduce negative  employment
     and economic impacts and contains  provisions  anticipating possible
     national laws.

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                                 References


 1.   Applied  Decision  Systems,  Inc.  Study of  the effectiveness and  impact
       of  the Oregon minimum  deposit law.  Legislative  Fiscal Office,
       Salem, Oregon,  1974.   p.   II-3.

 2.   Applied  Decision  Systems.   Study of the Oregon deposit  law.   p.   II-4.

 3.   Applied  Decision  Systems.   Study of the Oregon deposit  law.   p.   11-67.

 4.   Applied  Decision  Systems.   Study of the Oregon deposit  law.   p.   11-68.

 5.   Loube, M.   Beverage  containers, the Vermont experience.  U.S. Environmental
       Protection  Agency,  Washington, D.C., 1975.  Draft.

 6.   Franklin,  W.  E.,  and  D.  Hahlen, W. R. Park and J.  M.  Urie.   Baseline
       forecasts of  resource  recovery,  1972 to 1990.  Midwest Research
       Institute,  Kansas  City,  Missouri, 1975.  p. 241.

 7.   Franklin,  W.  E.,  Baseline  forcasts.  p. 255.

 8.   Smith, F.  A.  Technical  possibilities for solid  waste reduction and
       resource recovery:   prospects to 1985.  U.S. Environmental  Protection
       Agency,  Washington, D.C., 1975.  (In press.) p.5.

 9.   U.S.  Environmental  Protection Agency calculations  from  Franklin,  W.E.
       Baseline forescasts.  p.  79, 98.

10.   Applied  Decision  Systems.   Study of the Oregon deposit  law.  p.  1-31.

11.   Bingham, T. H., and  P.  F.  Mulligan.  The  beverage  container  problem.
       Washington, U.S.  Government Printing Office, 1972.  p. 30.

12.   Scheinman, T.  Mandatory deposit  legislation for beer and  soft  drink
       containers  in Maryland,  an economic analysis.  State  of  Maryland
       Council  of  Economic Advisors, 1974.  p. 3.

13.   Applied  Decision  Systems.   Study  of the Oregon deposit  law.   p. 1-26.

14.   Hunt, R. G.,  and  W.  E.  Franklin.   Resource and environmental  profile
       analysis of nine beverage container alternatives.   Environmental
       Protection  Publication SW-91c.   Washington, U.S. Government
       Printing Office,  1974.  p. 21.

15  Hunt.  R.  G., and W.  E. Franklin.   Resource and environmental  profile
       analysis, p.  40.

16.  U.S, Environmental Protection Agency  calculations from data presented
       in References 6 and 14.

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17.   Personal  communication.   National  Science Foundation  to  H.  Samtur,
       U.S.  Environmental  Protection Agency,  April,  1975.

18.   Dildlne,  R.  and R.  Rainy.   Impacts of beverage  container regulations
       in Minnesota.  Minnesota State Planning Agency,  St.  Paul,
       Minnesota, 1974.   p.  14.

19.   Environmental  Action, Inc.  Washington,  D.C.  Press Release.   October  17,
       1974.

20.   Stern,  C., E.  Verdieck,  S. Smith,  and T.  Hedrick.   Impacts  of  beverage
       container legislation  on Connecticut and a  review of the
       experience in Oregon,  Vermont and Washington  State.   Report
       to the  Connecticut State Legislature,  1975.   Final  Draft,  p.  28.

21.   Smith,  J. L.  President, Coca-Cola, Inc.   Hearings before the
       Subcommittee of the Judiciary, United  States  Senate on S.3133,
       August  8, 1972.  Washington, U.S. Government  Printing  Office,
       1973.  p. 164.

22.   Alpha Beta Acme Markets, Inc.   Bottle survey  1971: a California
       supermarket report on  the cost of handling  returnable  soft drink
       bottles.  La Habra, California,  1971.

23.   SCS Engineers.  Solid Waste Management in retail  food stores.   Long
       Beach,  California,  1973.  p. 111.

24.   Hunt, R.  G.   Resource and environmental  profile analysis,   p.  38.

25.   Stern,  C.  Impacts  of container legislation on  Connecticut, p.  5.

26.   Applied Decision Systems.   Study of the  Oregon  deposit law.  p.  II-4.

27.   Applied Decision Systems.   Study of the  Oregon  deposit law.  p.  11-68.

28.   Gudger,  C. and J. Bailes.   The economic  impact  of Oregon's  bottle
       bill.   Oregon State University Press,  Corvallis, Oregon,  1974.
       p. 24,  26.

29.   U.S. Environmental  Protection  Agency calculations from data presented
       in Reference 6.

30.   Franklin, W. E.  Baseline forecasts,  p.  247.

31.   Franklin, W. E.  Baseline forecasts,  p.  256.

32.   Mai Hie,  J.   The National  economic impact of  a  ban on nonrefillable
       beverage containers.   Midwest Research Institute, Kansas  City,
       Missouri, 1971.  p.  2.

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33.  United States Brewers Association, Inc.   Resource/energy recovery
       and recycling vs.  source reduction:   A simple economic analysis
       of two basic resource conservation strategies.   Prepared by
       R. S. Weinberg & Associates, St. Louis, Missouri, 1975.

34.  Mallie, J.  National impact of a ban on nonrefillable containers.
       p. 35.

35.  Quinn, R. R., and S. F. Sloan.  No deposit no return... A report on
       beverage containers.  New York State Senate Task Force on Critical
       Problems, Albany, New York, 1975. p. 7.

36.  Bingham, T. H.,  The beverage container problem,  p. 59.

37.  Average of estimates presented in:  Employment dislocations data.
       Research Triangle Institute memo to the U.S. Environmental Protection
       Agency, April 10, 1974.

38.  Scheinman, T.  Mandatory deposit legislation in Maryland,   p. 10-16.

39.  Impact of beverage container regulations in Minnesota,  p. 76-83.

40.  Stern, C.  Impacts of container legislation on Connecticut,  p. 3.

41.  Quinn, R. R.  No deposit no return,  p. 68.

42.  Folk, H,  Employment effects of the mandatory deposit regulation.
       Illinois Institute for Environmental quality,
43.  Ross, M.  Employment effects of a ban on nonreturnable beverage
       containers in Michigan.  Kalamazoo Nature Center for Environmental
       Education, Kalamazoo, Michigan, 1974,  p.  1-15.

44.  O'Brien, M.   Returnable containers for Maine:   an  environmental and
       economic assessment.   Maine Citizens for Returnable Containers.
       Portland,  Maine.  1975.

45.  Quinn, R. R.  No deposit no return,   p. 5.

46.  Applied Decision Systems.  Study of the Oregon deposit law.  p. iii.

47.  Gudger, C.  Economic impact of Oregon's bottle bill.   p. 69.

48.  U.S. Environmental Protection Agency.  Third report to Congress;
       resource recovery and waste reduction.  (Draft)   p. 130.

49.  U.S. Environmental Protection Agency calculations  based upon
       estimate of solid waste stream composition,  material recovery
       processing costs and revenues.

50.  Applied Decision Systems.  Study of the Oregon deposit law.  p. Ill - 38.

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51.   Applied Decision Systems.   Study of the Oregon  deposit  law.
       p.  III-6.

52.   Quarles, J.  R.   Statement  of the Deputy Administrator,  U.S.
       Environmental  Protection Agency before the  Subcommittee  on  the
       Environment,   Committee  on Commerce,  U.S. Senate.   Washington,  D.C.,
       May 7, 1974.

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