United States
Environmental Protection
Agency
Office of
Communications. Education
and Public Affairs
Volume 18, Number 3
July August 1992
175 N-92-006
                   r~  -^
                                                     A
Recycling:  Closing  the Loop

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                           r/EPA   JOURNAL
United States
Environmental Protection Agency

Office of Communications.
Education, and Public Affairs

William K. Reilly
Administrator
Lew Crampton
Associate Administrator
Charles Osolin
Director of Editorial Services
John Heritage
Editor
Karen Flagstad
Associate Editor
Teresa Opheim
Assistant Editor
Gregg Sekscienski
Assistant Editor
Ruth Barker
Assistant Editor

Nancy Starnes
Assistant Editor
Marilyn Rogers
Circulation Manager
Editorial Assistance
Leighton Price

Design Credits
Ron Farrah
James R. Ingram
Robert Flanagan
 Front cover: Making the
 recycling process complete and
 effective is a contemporary
 environmental challenge.
 Illustration by Robert Flanagan.
 A Magazine on National and Global Environmental Perspectives

July/August 1992 • Volume 18, Number 3     175 N-92-006

 From the Editor
    Recycling. Millions of Americans are demonstrating their environmental
    concern by cooperating in recycling initiatives. Clearly, recycling has
 popular appeal as something real and relatively simple that individuals can
 do to help protect the environment.
   But as is made clear in this issue of EPA Journal, recycling is a
 several-step process. It begins, of course, when a citizen separates out old
 newspapers for curbside pickup, takes bottles and plastic milk jugs to a
 community recycling bin, or puts empty soda cans into receptacles at work.
 But that is just the beginning. True recycling continues through processing
 collected items, finding markets, and reusing the materials  in new
 products.
   "Closing the loop," so to  speak—proceeding full circle from collection to
 finding new, marketable uses for recyclables—is proving to be quite a
 challenge, and government  agencies, legislatures, and companies are
 focusing a lot  of attention on the matter. There are situations around the
 country where collected material has piled up, unprocessed, unused,
 because the recycling system has not yet fully developed—perhaps the
 plant is not there to process the material to the standards required; the
 market may not have developed for the product containing a certain
 recycled material; the price may not be right....
   Adding to the complexity is the question, Why is the United States
 relying so heavily on recycling when there is another approach that might
 alleviate a hefty portion of the municipal solid waste problem? The
 approach is source reduction, which means, for example, using reusable
 rather than throwaway cups, so that waste isn't produced in the first place.
   It used to be said that the environment is a "mom and apple pie" issue,
 easy to support. But with recycling as an example, bridging the distance
 between great public concern and enthusiasm and actual, meaningful
 change—in place for the long run—takes some time and ingenuity.
 EPA JOURNAL Subscriptions
 The annual rate for subscribers in the U.S. for
 EPA Journal is $10. The charge to subscribers in
 foreign countries is $12.50 a year. The price of a
 single copy of EPA Journal is $3.50 in this
 country and $4.38 if sent to a foreign country.
 Pricas include mail costs. Subscriptions to EPA
 Journal as well as to other federal government
 magazines are handled only by the U.S.
 Government Printing Office. To subscribe to EPA
 Journal, send a check or money order payable to
 the Superintendent of Documents. The requests
 should be mailed to: P.O. Box 371954
 Pittsburgh PA 15250-7954

 EPA JOURNAL is printed on recycled paper.

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Contents
  THE SITUATION
  TODAY

  Putting the Crusade
  into Perspective
  by William. E. Franklin
  and Marjorie A. Franklin


  Speaking of
  Composting
  by Gregg Seksciensfci
   A Tale of One City
   by Liz Chandler
INTO
THE  LOOP

Collection:
The First Step
by Brace fl. Weddle

Processing: The
Unheralded
Middleman
by Jerry Powell

When It Doesn't
Make the Grade
by Edward F. Connelly
COMING
FULL CIRCLE

The Challenge
of Markets
by Michael Alexander

A "Cradle  to Cradle"
Debate in Congress
by /ulie C. Becker

Urgent Responses by
the States
by Eugene /. Wingerter

From Lumber to
Lampshades
by Kalhrin Day Lassila

A Forum: Will the
U.S. Recycling
Approach Work?
SOURCE
REDUCTION

Slowing the Waste
Behemoth
by Betle Fishbein
and David Saphire

Getting Serious in
Germany
by Cynthia
Pollack Shea
 DEPARTMENTS
 Newsline
 News and Comment
 on EPA

 For the Classroom
Tweety and the
 Beanstalk

 For the Classroom
 A Lesson Plan on
 Recycling

 Featuring EPA
 A Meeting with the
 Dynamometer
 by Lily Whifenian

 Cross Currents
 A Book Review
by E. Donald Elliot!

Habitat
A Conservationist in
the Wings

On the Move
New Names in Key
Agency Posts

Letters to the  Editor
EPA is charged by Congress to protect the nation's land, air, and water systems. Under a mandate of national environmental laws, the Agency strives to
formulate and implement actions which lead to a compatible balance between human activities and the ability of natural systems to support and nurture life.
  EPA JOURNAL is published by the U.S. Environmental Protection Agency. The Administrator of EPA has determined that the publication of this periodical
is necessary in the transaction of the public business required by law of this agency. Use of funds for printing this periodical has been approved by the
Director of the Office of Management and Budget. Views expressed by authors do not necessarily reflect EPA policy. No permission necessary to reproduce
contents except copyrighted photos and other materials.
  Contributions and" inquiries should be addressed to the Editor, EPA JOURNAL (A-107), Waterside Mall, 401 M Street, SW,, Washington, D.C. 20460

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  EPA Energy Star Logo  Premieres
 Several leading computer
 manufacturers have signed
 partnership agreements with
 EPA to promote
 energy-efficient personal
 computers (PCsJ. The new
 PCs could save enough
 electricity to power Vermont
 and New Hampshire each
 year and save ratepayers up
 to $1 oil/ion in annual bills.
 The agreements are the first
 to be made under an EPA
 Energy Star program; the
 Agency expects to extend the
 program to  manufacturers of
 other consumer appliances.
 Administrator Hei/ly said
 that the EPA Energy Star logo
 would make its debut on PCs
 within one year, by which
 time the Agency hopes to
 have signed on the entire
 industry. "Our partners in
 the computer world see
 energy efficiency as an
 opportunity to serve their
 customers, as well as the
 environment. Once again,
 they're on the cutting  edge  of
 a national trend."
 The San Francisco Chronicle
 reported: "... Personal
 computer makers soon may
 get a star from the federal
 government—if their
 machines sip rather than
 guzzle electricity ....
 Participants in the program
 include such high-profile
 computer makers as Apple
 Computer, Hewlett-Packard,
 IBM, NCR, Compaq
 Computer, Zenith Data
 Systems, and Smith-Corona.
 Energy usage is a new issue
 in the PC world. Yet,
 according to studies cited by
 the EPA, PCs are the
 fastest-growing category of
 energy consumption, already
 accounting for about 5
 percent of the energy used by
 businesses. One 1988 study
 predicted that electricity
 consumption by computer
 and office equipment would
 grow from 25  billion
 kilowatt-hours per year to
 125 [billion] kilowatt-hours
 by 1996. Such figures mean
 that PCs could indirectly
 boost pollution caused by
 energy
 production—including the
 generation of carbon dioxide
 believed to contribute to a
 rise in the Earth's
 atmospheric temperature. But
 several energy-saving
 technologies have been
 developed by makers of
 laptop computers, and the
 EPA wants to encourage
 manufacturers to apply them
 to desktop models. One
promising feature is a
so-called 'sleep' mode,
which turns off the display
screen and reduces power to
other key components until a
user hits a key. There seem
to be really dramatic
possibilities here,'  said Jeff
Harris, a staff scientist at
Lawrence Berkeley
Laboratory that has studied
the  issue	The EPA
already has succeeded with a
similar labeling approach in
its so-called Green Light
program aimed at
encouraging use of
energy-efficient bulbs."
The San Jose Mercury News
commented: "...  You
probably shut off your office
lights when you're not
around.  But energy-hogging
personal computers are
hardly ever turned off, even
when they're not being used
 .... Starting next  year,
computers that automatically
power down, or 'sleep' when
unused for a period,  could
have an EPA 'Energy Star'
logo affixed to them, and
companies would be allowed
to use the logo in their
advertising. 'A lot  of
companies these days are
interested in being "green,"
                            and we're building on that,1
                            said Eileen Claussen, director
                            of EPA's Office of
                            Atmospheric Programs. If
                            that isn't leverage enough,
                            the EPA is hoping that the
                            federal government, one of
                            the nation's largest buyers of
                            personal computers,  will
                            require that most of the
                            machines it buys have the
                            energy-saving feature, she
                            said .... The 'power
                            management' technology
                            called for by the EPA
                            consists of special computer
                            chips and the software to
                            control them and is used
                            widely in portable notebook
                            computers to conserve their
                            batteries. But the technology
                            is used little in standard
                            desktop machines that run
                            off wall current  .... It is not
                            clear how much the
                            technology would add to the
                            price tag of a personal
                            computer, nor if consumers
                            would be able to  retrofit their
                            current desktop machines to
                            be more energy-efficient. But
                            Apple spokeswoman
                            Marianne Lettieri said, 'We
                            plan to make the  cost
                            invisible to the
                            customer' . . . ."
$4  Million Awarded  in Environmental  Education  Grants
The first grants to b«
awarded under the 1990
National Environmental
Education Act have been
announced by EPA. A
consortium of universities,
businesses, and nonprofit
organizations led by the
University of Michigan
received $1,6 million to
assemble existing
environmental education
curricula and to develop
additional  materials. Five
curriculum modules, each
focusing on a different topic,
will be assembled. They will
incorporate different
disciplinary approaches, so
that teachers can apply them
directly or integrate them
into existing lesson plans.
Smaller grants, totaling $2.4
million, were awarded to 219
schools, universities, and
other non-profit organizations
located in all 50 states and
the District of Columbia. The
purpose of these grants is to
help improve environmental
education teaching skills and
curricula, promote teamwork
to  improve methods, and
help the public in making
decisions about
environmental issues.
                                                                                                 EPA JOURNAL

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 Ongoing Enforcement Actions

 Mack Trucks Penalty for  Diesel  Engine       Chevron  to Pay $8 Million for
 Violations Valued at $323,872                   Violations of Clean  Water Act
 Mack Trucks, Inc., will pay a
 penalty valued at $323,872
 for selling 177 new diesel
 truck engines that were not
 manufactured to the
 specifications listed in an
 application to EPA. Sixty-one
 of the engines also failed to
 meet the federal standard for
 smoke emissions. Under the
 Clean Air Act, prototype
 engines representative of a
 particular model must be
 tested and shown to conform
 to federal emissions
 standards before the model
can be sold. The
manufacturer submits test
data to EPA to apply for a
certificate of conformity for
the model or models in
question. In this case, models
were sold that didn't match
those  listed on the
application. EPA discovered
the violations during an audit
of Mack's assembly plant in
Hagerstown, Maryland. Mack
will pay a $174,863 cash
penalty and will carry out an
engine rebuild test program
valued at $149,009.
Seven Indicted in Hazardous Waste  Export
 A grand jury in Charleston,
 South Carolina, has indicted
 four companies and three
 executives for conspiring to
 illegally treat, then export,
 more than 3,000 tons of
 hazardous waste to
 Bangladesh and Australia.
 According to the indictment,
 Gaston Copper Recycling of
 Gaston, South Carolina, paid
 Hy-Tex Marketing, located in
 Beaufort, South Carolina, to
 process baghouse dust from
 its smelting furnaces. The
 dust contained cadmium and
 lead. The processed dust was
 then shipped to a Stoller
 Chemical plant in Jericho,
 South Carolina, where it was
 mixed with other materials to
 make fertilizer. Stoller
 exported the fertilizer to
 Bangladesh and Australia
 without obtaining the
 consent of the governments
 of those countries.
   Gaston Copper's parent,
 Southwire Corp., of
 Carrollton, Georgia,  was also
 named in the indictment, as
 were three individuals: Bruce
 Bettenton, who participated
 in the management of
 baghouse dust at Gaston;
 Arthur Heinel, president of
Hy-Tex; and Robert Weaver,
general manager at the Stoller
plant in Jericho during the
period of the indictment. All
defendants were charged
with conspiring to violate the
Resource Conservation and
Recovery Act, as well as with
the actual transportation of
hazardous waste without a
manifest. Stoller Chemical
and Robert Weaver were also
charged with treating
hazardous waste without a
permit and exporting it
without consent of the
receiving country. Weaver
could face up to 20 years in
prison and a fine of $1.75
million; Heinel and
Betterton could face
seven years in prison and
$500,000 in fines. The
corporations could face up to
$500,000 in fines on each
count of the indictment.
  The case was investigated
by agents of the South
Carolina Department of
Health and Environmental
Control, the U.S. Customs
Service, the Ninth Circuit
Solicitor's Office, and the
Charleston County Sheriff's
Office, as well as by agents
from EPA.
Chevron U.S.A., Inc., has
agreed to plead guilty to 65
criminal violations of the
Clean Water Act and to pay
$6.5 million in criminal and
$1,5 million in civil
penalties. The crimes were
committed on Platform
Grace, an oil drilling rig in
the Santa Barbara Channel off
California. Chevron admitted
to several kinds of violation
of its permit issued under the
National Pollution Discharge
Elimination System.  Between
1982 and 1987, samples of
Platform Grace's wastewater,
which contained chemicals
toxic to marine life, were
shown to exceed the permit
limits approximately half the
time. The company could
have prevented the
exceedances by operating a
carbon filter system it had
tested earlier but chose,
instead, to use a less
expensive, inadequate
treatment method. The
company then diluted
samples of wastewater taken
for testing, concealed test
results, and, in certain
instances, bypassed treatment
altogether, allowing raw
wastewater to discharge to
the ocean. Additionally,
Chevron admitted to
dumping sandblast waste
directly into the ocean on
numerous occasions, rather
than barging it to shore, as
required. The waste
contained old paint and rust
removed from the platform
prior to repainting.
  The four-year investigation
was overseen by the
Department of Justice  and
carried out by special  agents
of EPA and the Inspector
General's Office of the
Department of Interior.
 Cold Temperature Limits on Carbon
 Monoxide  Set for Cars and Trucks
 A new rule issued by EPA
 requires that car and truck
 prototypes tested for
 compliance with federal
 emissions standards for
 carbon monoxide (CO) be
 subjected to startup
 temperatures of 20  degrees
 Fahrenheit. Currently, CO is
 measured at temperatures
 between 68 and 86  "F. The
 new rule goes into  effect with
 1994 model year vehicles.
    It is common knowledge
 that cars and trucks use more
 fuel and produce more CO
 during engine warm up.
 Further, a car started  at 20 °F
 may emit more  than 10 times
 as much CO as the  same  car
 started at 75 "F. In  winter,
 when temperature inversions
 push cold air down and trap
 pollutants at the ground,
 levels of CO in the air
 increase dramatically.
 Currently, 39 metropolitan
 areas in the United States
 experience CO levels that
 exceed the federal health
 standard. More than half the
 violations occur at
 temperatures below 45 "F.
 When the new EPA rule is
 completely phased in, startup
 emissions of CO measured at
 20 °F will be reduced 20 to
 29 percent. In  addition, the
 nation will conserve 43,000
 barrels of oil each day by
 way of improved fuel
 combustion.
 JULY/AUGUST 1992

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 Draft Report on Health  Effects of
 Passive  Smoking  Made  Available
  EPA has forwarded a revised
  draft report on passive
  smoking to its Scientific
  Advisory Board for review.
  At the same time, the Agency
  made the report available to
  the press and to the public.
  Entitled Respiratory Health
  Effects of Passive Smoking:
  Lung Cancer and Other
  Disorders, the report
  incorporates important
  revisions to a draft published
  two years ago. In publishing
  the new draft, the Agency
  emphasized that the
  independent scientific review
  by the Board could result in
  substantial additional
  changes. A final report
  should be available by the
  end  of the year.
      The Boston Globe
      commented: "... There is
      no longer a shadow of doubt
      that tobacco smoking is a
      major public health threat,
      worst for smokers but
      dangerous also for the family
      members, co-workers, and
      others with whom they share
      smoke-tainted space.  Last
      week three national health
      organizations—the American
      Heart Association, the
      American Lung Association,
      and the American Cancer
      Society—declared that
      'secondary smoke1 should be
      treated as an 'environmental
      toxin' and banned from the
      workplace and public spaces.
      This week the Environmental
      Protection Agency  issued a
      staff report concluding that
      each year, exposure to
      secondhand smoke causes
                            between 150,000 and 300,000
                            acute lower respiratory
                            infections, such as bronchitis
                            and pneumonia, in children
                            less than 18 months  of age.
                            These produce between 7,500
                            and 15,000 hospitalizations.
                            The report also found that
                            children who live with
                            smokers are more likely to
                            become asthmatic. Secondary
                            tobacco smoke exacerbates
                            asthmatic symptoms in
                            approximately 20 percent of
                            the country's 2 million to 5
                            million asthmatic children,
                            and is a risk factor in
                            triggering between 8,000 and
                            26,000 new cases of  asthma
                            per year.  More generally,
                            secondhand smoke increases
                            the prevalence of coughing,
                            wheezing, inner-ear infection,
                            and reduced lung function
                            among children. The report
                            also suggests a link between
                            secondary tobacco smoke and
                            sudden infant death
                            syndrome. Finally, it
                            estimates that secondary
                            smoke causes between 2,500
                            and 3,300 lung-cancer deaths
                            per year.  This report,  focused
                            solely on respiratory
                            problems, leaves out heart
                            disease, which other studies
                            have estimated causes about
                            half of the nation's
                            tobacco-related deaths and
                            37,000 deaths per year among
                            nonsmokers . . . . "
                            The Wall Street Journal
                            reported: "... The report
                            now goes to the agency's
                            science advisory board,
                            which can either accept it or
                            send it back for
                            modifications. Following the
                            board's approval, the  report
                            will be sent to EPA Chief
                            William Reilly, who may
                            order  further changes or
                            release it. Agency officials
                            predict the final report will
Acid Rain Emissions  Limits  Proposed
Proposed plant-by-plant
reductions in acid rain
emissions have been listed
EPA for most of the
electric-power generating
plants in the United  States.


Acid Rain Formation
     One hundred and ten of the     of the century, over 800
by
largest plants, mostly coal
burning utilities in 21 eastern
and midwestern states, will
have to make reductions
beginning in 1995; at the turn
smaller plants must also cut
back on their emissions, and
the larger plants must make
further reductions. Electric
power plants account for 70
                 Emissions are mixed with oxygen, ozone, and water to formV
                 sulfuric and nitric acids in the presence of sunlight
                                         Dry Deposition of Acidic Compounds
   Coal-fired electric utilities and other
   sources that burn fossil fuels emit
   sulfur dioxide and nitrogen oxides
  vehicles emit nitrogen oxides and hydrocarbons
percent of sulfur dioxide
(SO2) emissions in the United
States; SO2 is the chief
contributor to acid rain.
  Under the 1990 Clean Air
Act, each power plant is to
be issued emissions
allowances. Each allowance
equals one ton of SO2
emissions per year. The
number of allowances a plant
gets is determined by formula
and is based in large part on
the plant's past consumption
of fuel. As the program gets
underway in 1995, each plant
must hold enough allowances
to cover its annual emissions.
It can meet its requirement
either by reducing emissions
or by purchasing allowances
from other utilities. For every
ton of SO2 a plant emits in
excess of its allowances, it
                                                                                                  EPA JOURNAL

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 be issued by year end. The
 EPA is barred by law from
 regulating smoking, but the
 report is expected to spur the
, Labor Department's
 Occupational Health and
 Safety Administration to act
 to restrict smoking in the
 nation's workplaces. Many
 employers and localities
 across the country have
 already banned or restricted
 smoking in offices and
 factories. Action on Smoking
 and Health, an anti-smoking
 organization, predicts the
 report will make 'Americans
 justifiably fearful of being in
 any enclosed area where
 smoking is permitted.' The
 study provides new support
 for the agency's earlier
 decision io declare
 secondhand smoke a known
 human carcinogen, putting it
 in the same category with
 such pollutants as
 asbestos .   .  "
Sludge  Dumping Finally  Ends
  will pay a penalty of $2,000
  and will forfeit one
  allowance. This program of
  market-based trading in
  allowances, combined  with
  tough monitoring and
  enforcement, is believed to
  have significant advantages
  over traditional  "command
  and control" regulations. By
  allowing utilities that can
  reduce emissions cheaply to
  sell excess allowances to
  those whose control costs are
  high, total reductions can be
  achieved most cost
  effectively. As a safeguard,
  no utility—no matter how
  many allowances it
  holds—will be allowed to
  emit SO2 in amounts that
  exceed federal health
  standards.
New York City, the last of the
cities to dump sewage  sludge
in the ocean, has met a
court-ordered deadline to
end the practice.
Participating in  ceremonies
to mark the event,
Administrator Reilly said:
"The  main objective  of the
federal Ocean Dumping Ban
Act of 1988 has  been
realized—we have stopped
dumping sewage sludge into
the ocean. EPA vvj.Il continue
to enforce the consent
decrees which require the
establishment of Jong-term,
land-based disposal
aJternatives. We will also
continue to encourage
solutions that have beneficial
uses.  Through these efforts,
not only are we  preventing
pollution by protecting the
ocean from use as a dump,
we are now seeing sludge
recognized more and more as
a resource, not as a waste."

The New York Times
commented: "... Late this
afternoon the ocean barge
Spring Brook will slip quietly
into the East River and head
to sea, carrying for the  last
time one of America's least
loved cargoes: 400 tons of
New York City's processed
sewage. It has been four years
since  Congress voted to ban
the common practice of using
the ocean as a municipal
chamber pot, and with  the
Federal deadline set for
tomorrow, New York is the
only city that still does it.
For environmentalists and
many politicians, the final
barge  journey will be a
moment of triumph, one they
say will make the planet a
cleaner, healthier place. But
behind the public
celebrations lie a host of
anxieties. For New York, the
end of ocean dumping means
the beginning of a new  and
The Tibbetts Brook, one of (he barges used by New York City to
transport sewage sludge for off-shore dumping. The practice has
been stopped.
troubling era: a city that is
already struggling to recycle,
burn, export, sell, and bury
nearly  30,000 tons of garbage
every day will have to find
ways to handle some more.
And despite plans, promises,
and years of negotiations, it
won't be easy or cheap ....
'This ban has been portrayed
as an accomplishment that
has no  flaws,' said
Representative Thomas J.
Manton of Queens, whose
district will  be among those
that will be forced to process
the city's treated sewage,
called sludge. 'But I worry
whether this makes sense
economically or
environmentally. We rushed
into  this  for political  reasons
and now we will have to deal
with some harsh truths.'
Perhaps the most painful of
those truths is that while it
will  be nearly impossible to
export, bury, or burn most of
city's sludge, it is even
harder  to find a New Yorker
eager to live near a plant
designed to process it, either
by turning that waste into
useful  compost or by baking
it into  fertilizer pellets at
tremendous heat
The  Associated Press
reported: "... New York
and other cities began
ocean dumping of
sewage in the 1920s, and for
many years used a site 12
miles off the New Jersey
coast. In  1984, evidence  of
shoreline pollution and
damage to marine life
prompted a shift to the
'106-mile site,' where the
continental shelf drops from
600 feet deep to about 7,500
feet  .... The halt to
dumping compounds the
problem  of what to do with
the daily production of some
2,000 tons of sludge, a
byproduct of the 1.7 billion
gallons of wastewater
processed by 14 New York
sewage treatment plants.
Officials  said the immediate
solution  is to ship  it to
landfills  in other states.
Estimates have put the cost
of that at $250 million in the
next fiscal year, compared
with about $20 million a year
for ocean dumping. Mayor
David Dinkins, attending the
ceremony, said out-of-state
landfills  were only a
short-term answer while the
city builds five new
processing plants to turn it
into commercially marketable
fertilizer  and dry
compost  . . . . " a
   JULY/AUGUST 1992

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An  old  idea  with  enduring values
                  here is always the miracle of the by-products. Plane a board,
                  the shavings accumulate around your toes ready to be chucked
                  into the stove to kindle your fires (to warm your toes so that
            you can plane a board). Draw some milk from a creature to relieve
            her fullness, the milk goes to the little pig to relieve his emptiness.
                  Drain some oil from a crankcase, and you smear it on the roosts
                       to  control the mites. The worm fattens on the apple,
                            the young goose fattens on the wormy fruit, the man
                               fattens on the  young goose, the worm awaits
                                   the man. Clean up the barnyard, the
                                     pulverized dung from the sheep goes to
                                       improve the  lawn (before a  rain in
                                       autumn); mow the lawn next spring,
                                       the clippings go to the compost pile,
                                       with  a few thrown to the baby chickens
                                        on the way; spread the compost on
                                          the garden and in the fall the original
                                         dung, after many vicissitudes,
                                          returns to the sheep in the form of an
                                          old squash.  From the fireplace,
                                          at the end of a November afternoon,
                                         the ashes are carried to the feet of the
                                         lilac bush, guaranteeing the excellence
                                         of a June morning.
O  '
                                          From One Man's Meat
                                          by E.B. White, HarperCollins.
                                                                  EPA JOURNAL

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Putting  the  Crusade
into  Perspective
Recycling and waste generation both are on the rise
by William E. Franklin and
Marjorie A.  Franklin
   ust about everyone in the United
   Slates seems to think that there is
too much municipal solid waste
(MSW). Newspaper articles and
television programs bombard us with
images of discards heaped up and
overflowing. Schoolchildren are
probably more aware than most; just
visit  a school and view the children's
posters exhorting people to save the
Earth by recycling.
  There's no doubt that  the problem is
growing. EPA's most recent estimates
are that in 1990 the United States
generated over 195 million tons of
MSW. That's up from about 88 million
tons  in 1960, and 151 million tons in
1980. EPA defines MSW as wastes
(Bill FrankJin, chairman of Frank/in
Associates, Ltd., has been a municipal
solid waste consultant since 1968.
Marge Frank/in, president of Franklin
Associates, has been a municipaJ solid
waste consultant since 1975. Part of
this article was based on a  speech
delivered at EPA's Municipal Solid
Waste Source Reduction and Recycling
Conference, Hot Springs, Virginia,
March  1988. Most of the statistics in
the article are from Characterization of
Municipal Solid Waste in the United
States: 1992 Update, EPA Report No.
530-R-92-019.)
from residences (such as houses,
duplexes, apartments), from
commercial establishments (such as
office buildings, stores, hotels, airports,
warehouses), from institutions (such as
schools, prisons, hospitals), and from
industries (such as packaging and
office wastes from factories). MSW
does not include industrial process
wastes.
  Of course, as the population
increases, there are more people to
generate waste. But even without the
population increase, we would be
generating more waste per person both
at work and at home.  EPA estimates
the rate at 4.3 pounds of MSW per
person  per day in 1990, up from 2.7
pounds in 1960. These numbers are
expected to increase over the next 10
years.
  The approach that most government
officials agree should  be taken to the
problem of MSW is integrated waste
management. This means that, in most
cases, no single alternative should be
relied upon; each community should
tailor a combination of methods to
match its particular needs. However,
there is a generally accepted hierarchy
of waste management  alternatives that
goes like this:
•  Source reduction—reducing wastes
at their source and reusing
products—is the best alternative
because it means generating less waste
in the first place. Very simply, waste
that isn't generated never enters the
waste stream.
•  Recycling and composting are next
best. Recycling is a process that begins
with separation and collection of a
product that otherwise would become
waste and ends when the recovered
material is processed into a new
product. Closed loop recycling means
that a recovered product (such as an
aluminum can) is made into the same
product again. Open loop recycling
means that a product (such as a
recovered plastic soft drink bottle) is
made into a different product  (such as
fiber for carpeting). (See box on
composting on page 14.)
•  Incineration and hmdfilling are
least desirable.

  Unfortunately, endorsing this
hierarchy is a little  like saying you're
going to lose weight; it's easier said
than done. In the first place, no one
has devised an  acceptable way to
measure source reduction on a
nationwide basis, and it is difficult to
estimate the effect that current efforts
are having on the waste stream.
  Nevertheless, there are many
examples of source  reduction currently
in  practice: Many offices are reducing
waste by copying reports on both sides
JULY/AUGUST 1992

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Ih

                                                                                            By weight,
                                                                                            corrugated boxes
                                                                                            are 12 percent of
                                                                                            the municipal
                                                                                            solid waste
                                                                                            stream, the
                                                                                            second largest
                                                                                            component of
                                                                                            MSVV generation.
Mike lirjssim photo-
of the paper; many marketers of
consumer products are finding ways to
reduce packaging.
  Also, while efforts in recycling and
composting have increased
tremendously in the  past few years,
people wonder whether they're really
making a difference.  EPA's estimates of
how MSW was managed in 1960 and
in 1990 show that  recovery for
recycling and composting increased
from almost 6 million tons in 1960 to
over 33 million tons  in 1990. At the
same time, the amount of MSW burned
increased only slightly. On the other
hand, the United States  landfilled
about 130 million  tons of MSW in
1990 compared to  55 million tons in
1960, an increase of  137 percent.
  Looking at the recent past, the
picture is a little brighter. MSW
generation continued to  increase
steadily, but recovery for recycling and
composting made a big increase — from
more than 16 million tons (less than
10 percent  of generation) in 1985 to
over 33 million tons  (17 percent)  in
1990. This  is an increase of 104
percent, not bad for starters.
Incineration — also  termed
combustion — also increased in this
period, so the best  estimate is that less
total MSW was landfilled in 1990 than
in 1985.
  If recycling is to be used  as a
genuine MSW management alternative,
rather than just a "feel good" way to
conserve resources, then materials
must be recovered and made into new
products in large quantities.
Unfortunately, some of the products
that are relatively easy to identify and
recycle economically are not very big
factors in the waste stream. To cite two
examples:
•  Lead-acid automotive batteries were
recovered at a rate of over 96 percent
in 1990. This is an impressive number,
and keeping lead  out of landfills and
combustors is highly desirable from an
environmental standpoint. However,
these  batteries would be less than 1
percent of all MSW even if  they were
not recovered at all.
•  Recovery of aluminum beverage
cans is one of the great success stories
of recycling, perhaps the greatest.
Their recovery rate was well over 60
percent in 1990, and, since  they bring
a good price, aluminum cans are an
important economic factor in recycling
programs. On the other hand,
aluminum beverage cans would also be
less than 1 percent of total MSW even
if they were not recovered at all.

  So what can be recycled that will
have a real impact? By weight, the four
largest components of MSW generation
in 1990 were: yard trimmings (18
percent), corrugated boxes (12
percent), food wastes (7 percent), and
newspapers (7 percent).
  The yard trimmings and food wastes
can be composted; the corrugated
boxes and newspapers are highly
recyclable. By going after these
components, which really make a
difference in the waste stream,
communities can make some real
reductions in what has to be disposed
of. In fact, that  is exactly what
happened to achieve the 17  percent
recovery rate in 1990. Paper products
were nearly 63  percent of all recovery
in 1990, and recovery of yard
trimmings for composting made up
nearly  13 percent. Recovery  of glass,
metals,  plastics, rubber, and other
materials made up the  remaining 25
percent. What's been accomplished
gives some guidance as to what must
be done to  increase recycling and
composting in the future. That is,
8
                                                                                                        EPA JOURNAL

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concentrate first on the materials that
make up the largest part of the
municipal waste stream—paper and
yard trimmings—then add other
materials, such as plastics, metals,
glass, and wood.
 Behind all these numbers, what has
been going on in the country that has
affected attitudes toward the ways in
which wastes are managed? Source
reduction and recycling are certainly
not new. People have always fed food
scraps to livestock, made leftover
fabrics into quilts, and used metal
scraps to patch and reinforce
everything from the roof to machinery.
The use of recovered paper in paper
manufacture was at a higher
percentage 40 years ago than it is now.
In years past, many an immigrant
started a thriving family business as a
"junkman" or scavenger. The private
salvage industry has always recovered
materials for recycling: metals, glass,
paper, textiles, and rubber. This
traditional salvage industry
includes—in addition to junkmen or
scavengers—dealers, secondary
materials processors, brokers, and
refuse haulers. In addition, there is a
long tradition of recovered materials
collected by social service and civic
organizations, which earn money for
their projects in this way.
 In reviewing the subjects of source
reduction and recycling for the last 20
years, it became obvious to the authors
that the nation had been through
several cycles.
 The 1960s were an age of unrest,
both politically and environmentally.
Many people were influenced by
Rachel Carson's SiJent Spring. The
gathering public indignation over
environmental pollution became
focused on the view that the United
States was rapidly becoming a
"throwaway" society. Nevertheless,
most people loved the new products
and the convenience they provided,
     Overloaded landfills are a key factor
          in the nationwide interest in
     alternatives to traditional disposal of
             municipal solid waste.
and the decade set in motion a new
wave of prosperity. In the 1960s:
• Environmental pollution came into
focus as an issue
• Resource depletion also came into
focus
• The simple life was contrasted with
the throwaway society
• Packaging became the symbol of
waste

• Prosperity meant more
consumption and discards
• The marketplace rewarded
consumption.

 Outrage continued to mount over the
country's wastefulness, especially over
packaging. Material resource
conservation was reborn, along with
source reduction, as the way to get
there. The simple life became the
symbol of morality, and the throwaway
        LANDFILL
         CLOSED
  PERMANENTLY
JULY/AUGUST 1992

-------
beverage container became the symbol
of the wasteful society. This era
culminated in Earth Day 1970—the
symbolic rejection of a materialistic
society.
  The forces set  in motion in the
1960s continued into the 1970s. In
1970, EPA was established. In  the
waste arena, Congress passed the
Resource Recovery Act, which
amended the Solid Waste Disposal
Act. An early study of recycling
revealed that salvage markets were in
decline, and use of virgin raw
materials was on the rise. The  trend
was ominous. In combination with
increasing disposables and throwaways
and less recycling, the solid  waste
stream was a real growth item.
  EPA sponsored many studies and
initiatives to encourage recycling in
this period, with industry and
environmentalists usually at odds.
Beverage-container deposit  laws were
often a focus. It was argued that such
laws would save the refillable bottle,
reduce litter, and achieve reuse and
recycling. While a national  deposit law
was not enacted, 10 states did pass
some form of this law, with Oregon
leading the way in 1972,  closely
followed by Vermont. (The  others were
Michigan, Maine, Massachusetts,
Delaware, Iowa, New York,
Connecticut, and California.) In spite
of these efforts, refillable  bottles
declined in use and, in many places,
disappeared.
   Another focus of attention for EPA
 and others in this era was the
 reduction of discards of consumer
 products and packaging. Packaging of
 all  kinds, plus newsprint, tissue paper,
 and printing and writing paper,
 received most of the attention.
   Many waste reduction proposals
 were put forth in the early 1970s. A
 few were successful; some were never
 put into action; others died, to be
 revived only recently. Here's what
 happened to some of the proposals:
 •   The 100,000  mile tire.  Tire life
 increased to 40,000 miles, and tires got
 smaller. However, these developments
 were unrelated to source reduction
 efforts.
    State Your Claim
    On July 28th, the Federal Trade
    Commission (FTC) issued national
    guidelines for environmental
    claims on products. The
    guidelines,  based on FTC
    investigations, hearings, and more
    than 100 written public comments,
    provide operating definitions of
    what is "recyclable" and what  is
    not, as well as other environmental
    terms.
      The following summary
    definitions  are paraphrased from
    the new FTC guidelines:
    Recyclable  products or packaging
    must be able to be collected,
    separated, or otherwise recovered
    from the solid waste stream for use
    in the form of raw materials in the
    manufacture or assembly of a new
    product.
    Recycled Content refers only to
    products made from materials that
    have been recovered or otherwise
    diverted from the solid waste
    stream, either during the
    manufacturing process
 (pre-consumer) or after consumer
 use (post-consumer).
 Refillable packages should be
 labeled as such only if a system is
 provided for either the collection
 and return of the package for refill
 or the later refill  of the package by
 consumers with product
 subsequently sold in another
 package. If it is up to the consumer
 to find new ways to refill the
 package, it should not carry a
 "refillable" claim.
 CompostabJe products or
 packaging are comprised only of
 materials that will break down
 into,  or otherwise become part of,
 usable compost (e.g.,
 soil-conditioning material, mulch)
 in  a safe and timely manner in an
 appropriate composting program or
 facility, or in a home compost pile
 or  device.
 DegradabJe/Biodegradable/Photo-
 degradable product label claims
 should be substantiated by
 competent and reliable scientific
evidence that the entire product or
package will completely break
down and return to nature—i.e.,
decompose into  elements found in
nature within a reasonable amount
of time after customary  disposal.
Ozone Safe and  Ozone Friendly
products cannot contain an
ozone-depleting  substance.
Source Reduction claims should be
clear about the amount of waste
reduction and the basis  for any
comparison asserted.

  In general, the guidelines stress
that: labeling should be  clear and
not deceptive; companies should
delineate clearly whether claims
apply to products, packaging, or
just a portion of either; claims
should not overstate
environmental benefits of
products, expressly or by
implication; and if comparisons
are used, they should be clear and
the maker should be able to
substantiate the comparison.
It!
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                                                                                          EPA estimates that in
                                                                                          1990 the United Stales
                                                                                          generated more than
                                                                                          795 million tons of
                                                                                          municipal solid waste,
                                                                                          up from 151 million
                                                                                          tons in 1980.
                                                                              Waste Age photo.
•  Elimination of excess packaging.
Packaging proliferated but shifted to
lighter materials.
•  Package design to  reduce waste.
Efficiency in packaging  is still
increasing.
•  Generic bottles and cans to
encourage reuse. Brands and sizes of
packaging proliferated.
•  Buying in bulk. Smaller
households, more working women led
to more packaging and convenience
foods.
•  Backyard composting of yard
wastes. Relatively little took place
until recently.

   The stage was set for a new era
when the Middle Eastern nations
embargoed oil exports to the United
States for six months. Long lines at the
filling station and  instructions to  turn
down thermostats focused everyone's
attention on energy.
   In 1976, Congress passed the
Resource Conservation and Recovery
Act, better known  as RCRA. This
provided the seeds of what is now
recognized as integrated solid waste
management. RCRA addressed
hazardous waste management, solid
waste management, and procurement
of products made from recovered
materials. However, the overriding
concern became safe disposal of
hazardous wastes. The federal budget
for nonhazardous wastes, including
MSW, dried up, and MSW became
firmly established as a local  problem.
Procurement guidelines, intended by
the Act to encourage development of
markets for recovered materials, were
not forthcoming from EP~A.
  The limited waste reduction research
that was sponsored by EPA was cast in
terms of energy conservation. Most
EPA  grants to communities focused on
recovery  of energy from wastes
through combustion, with recycling
receiving secondary attention.
  One reason why MSW took a back
seat during this period was that
landfill costs were still relatively low,
and recycling programs were simply
not cost effective at the community
level. On the other hand, energy prices
were escalating, and waste-to-energy
projects could be shown to be cost
effective within a few years of a plant's
being put in operation.
  Another important factor was that
solid waste officials were facing
increasing volumes of MSW, as urban
areas grew and as material prosperity
continued. It became expedient for
these officials to seek "one  step"
solutions. Energy recovery, especially
by burning, fit their criterion perfectly.
  Recycling got some push in this era,
but with no  significant support from
industry, except in the case of
beverage containers, which were still
under siege by bottle bills at the state
level. Some faithful individuals and
organizations kept their recycling goals
alive, and the private recycling sector
continued to  function, but the  white
hat was hung up at EPA.
  The early 1980s were quiet years for
those interested in MSW management.
Appropriations by Congress were all
going to hazardous wastes, and EPA,
along with most of the consultants that
had been working on MSW, geared up
accordingly. It is reported that  EPA's
technical nonhazardous waste  staff
declined from more than 150
employees in 1980 to fewer than 10  at
one point. "Love Canal," "Times
Beach," and dioxins were the
buzzwords of the day. The missing
JULY/AUGUST 1992
                                                                                                                 11

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 Recovery of Materials from the
 Municipal Solid Waste Stream,
 1990 (By Weight)
     All Others
        4.8%
Plastics
        Yard
    Trimmings
  Recovered for
Compost 12.6%
              1.1%

                 Source Franklin Associates (1992)
ingredient was building but had not
surfaced in a big way yet—an
honest-to-goodness crisis in solid
waste disposal at landfills.
  In November 1984, Congress enacted
the Hazardous and Solid Waste
Amendments  (HSWA). These helped
to revitalize MSW management by
requiring EPA to revise solid-waste
disposal criteria for facilities that
received ha/ardous household waste or
hazardous waste from small quantity
generators. In  other words, the criteria
were to apply to nearly all landfills.
States were given responsibility for
permitting these facilities. The next era
had  begun.
  Enter, then, some real landfill crises,
and  a new infrastructure to  do
something about it, especially in the
Northeast, where states facing urgent
disposal problems led the way.
Integrated solid waste management
was  bom in 1985 and is now a reality
in many parts of the country. In large
part, it is the extreme difficulty of
siting new  landfills and combustion
units that now drives the need to
reduce and recycle.
  During this  period, when  EFA's
MSW resources have been limited, a
great many states have required local
governments to prepare integrated
solid-waste management plans, often
with goals or requirements for
reduction and recycling as part of the
plans. The northeastern states have
been particularly active, with the
Coalition of Northeastern Governors
(CONEG) taking the lead on many
source reduction and recycling
initiatives. Organizations such as the
U.S. Conference of Mayors have also
taken leadership roles.
  While increased recycling and
composting have made a big
difference, most of the country is still
relying  mainly on the combustion and
landfill alternatives at the lower end of
the hierarchy. Recycling experiences
have shown that there are still some
problems to be overcome,  such as:
•   Separating and collecting
recyclables is proving to be quite
expensive in many locations.
•   Collected recyclables often need
further  processing to make them
acceptable to those who manufacture a
new product from them. This adds
another layer of expense.
•   There have been disparities
between the amounts of recyclables
collected and the amounts  that can  be
used. There are reports of  collected
materials being landfilled  or
combusted,  instead of recycled.
•   The  complete recycling and
composting loop creates some
unrecyclable residues that must
themselves be disposed of. For
example, deinking old newspapers to
produce recycled newsprint creates a
sludge.
•   There has been some resistance to
purchasing products containing
recycled materials. Some people have
the perception that recycled products
are somehow inferior to products made
of virgin materials. There have also
been some real problems with recycled
products. For example, many copy
machines malfunctioned while using
recycled paper, but these problems are
now largely solved. Education of
consumers is also beginning to
overcome some of the image problems:
For example, manufacturers that have
avoided labeling their packaging as
"recycled" now often display that
information prominently.

  What of the future? A number of
trends are developing.
  The rate of growth of municipal
solid  waste generation  is slowing.
Between 1960 and 1970, MSW grew at
a rate of 3.5 percent per year, while
population grew at a rate of 1.2
percent per year. Between 1980 and
1990, MSW grew at a rate of 2.8
percent per year, while population
grew only 1.0 percent per year.  While
the reasons for this decline are not
fully understood, use of lighter
materials, such as plastics instead of
glass, is almost certainly a factor. The
decline in growth may stem from a
sluggish economy, from people
perhaps becoming less  materialistic, or
from serious public and private efforts
to reduce materials at the  source
(especially in  packaging, but also in
some products). It is expected that this
decline in rate of growth will
continue, but growth will  still exceed
population increase.

Municipal Solid Waste
Management, 1960 to 2000
(Projected)
                                                                  I960  1965  1970 1975 1980  1985  1990  1995 2000

                                                                  Source: Franklin Associates (1992)
12
                                                                                                       EPA JOURNAL

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                                                                                                         __ "~,r-"^-nH
                                                                                            Ig^v^•:.-,,-.• J  ..
                                                                                           W^^f^-^f- J"^» — '  JMIlfcl  ~. -' -. -'~:~
Despite the increased focus on recycling and composting, most of the
country still relies on combustion and landfills.
  The emphasis on recycling and
composting is strong and will
continue. Industry has gotten the
word; the new capacity to absorb
recovered materials is coming on-line.
In particular, the paper  industry has
responded to increased  collection oi
paper and to increased demand for
paper with recycled  content by
committing the resources to build
many new and expanded recycling
paper mills. Some grades of recovered
paper may actually be in short  supply
by 1995 or 1996. Industries using other
recovered materials—plastics, glass,
metals, and wood—have also stepped
up their efforts to recycle more. An
overall recovery rate of 30 percent of
MSW generation seems  within  reach
by the year 2000.
  Finally, combustion with energy
recovery struggles along, increasing
slowly. This management alternative
has been plagued with a legacy
inherited from the earlier years of this
century, when old fashioned
incinerators belching smoke were a
feature in many  communities. New
facilities are required to meet stringent
air pollution regulations and to
dispose of their ash properly, but this
increases the cost of combustion.
Further, the public often strenuously
resists siting new facilities.
  The picture that emerges is this. The
country's generation of MSW
continues to increase, although at a
slower rate. Recovery for recycling and
composting, which began to increase
in the late 1980s, continues to grow.
At the same time, combustion of MSW,
which declined greatly when pollution
controls became mandatory, is again
on the increase. As a result of these
changes, less MSW is projected to be
landfilled in the year 2000 (about 109
million tons, or less than half of total
generation) than was landfilled in 1980
(about 123 million tons, or 81 percent
of total generation). Thus, changes in
the way we manage our wastes—like
increasing recycling—can make a
dramatic difference over time.
  The problems will not end—landfills
will still  fill up. But the country is
already into a new era; the new
landfills that are sited tend to be large,
but there is a decreasing need for
landfill capacity—thanks to all those
efforts to reduce and recycle. D
JULY/AUGUST 1992
                                                                                                                   13

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Thi


      Speaking   of   Composting
      The heat builds: 100 degrees
      Fahrenheit; 110 "F; 120 "F.
      Oxygen molecules begin to break
      down, water molecules gather, and
      bacteria begin to multiply.
      Millions of
      microorganisms—mostly bacteria
      and fungi—metabolize grass
      clippings,  dead leaves, and orange
      peels. More heat is released. The
      temperature climbs above  130 "F.
      Matter changes form. What was
      once tossed out as trash is turned
      into a rich, nutrient-laden mix
      called humus or compost.
        This is not a description of a
      new technology developed to
      combat the United  States'  growing
      municipal solid waste problems. It
      is instead  the eons-old process of
      composting: returning nutrients
      from yard  waste and food  scraps to
      the environment.
        According to EPA data,  nearly 18
      percent (by weight) of the
      municipal solid waste stream is
      yard waste—grass clippings,
      leaves, tree trimmings, etc. During
      peak summer and fall months,
      yard waste can amount to between
      25 and 50 percent of the solid
      waste stream. Collected and
      dumped into landfills, it adds up
      to some 35 million tons of
      material. That's second only to
      paper in landfill tonnage.
      The composting process can
      include food scraps (nearly 7
      percent of the solid waste stream
      by weight) and even waste paper
      (weighing in at a whopping 38
      percent); however,  most municipal
      composting projects treat only yard
      waste. (One reason for this: Health
      laws governing food scraps and
      concerns about hazardous inks and
      other materials in paper
      complicate the process for
      municipalities.) EPA estimates that
      about one-third of yard waste can
      be diverted from landfills  by  1995
if composting projects keep
expanding at current rates.
  Backyard composting piles have
always been a boon to home
gardeners. The rich humus
generated from the piles of grass,
carrot shavings, egg shells, and
leaves helped many a garden grow.
Composting has other benefits, too.
Individual and community
composting provides an alternative
to leaf burning, a practice many
areas have banned in the past
decade due to air pollution,  health,
and fire safety concerns. Recent
studies have shown that leaf and
brush burning releases toxic,
irritant, and carcinogenic
compounds including carbon
monoxide, hydrocarbons, and
particulate matter—the "smoke"
that's visible when leaves burn.
These airborne particles are small
enough to be breathed deep into
the lungs and can  remain there for
months or even years, causing
chronic irritation and  other effects.
  Composting also offers a partial
solution to the problems of landfill
closings and increased dumping
fees, and the banning of yard
wastes from many landfills
beginning in the 1980s. Many local
decision makers have opted  for
community composting programs.
According to Resource Recycling
magazine, at least  2,000 new
yard-waste composting facilities
will have begun operating between
1990 and 1995.
  There are hurdles, though. Siting
composting projects can be a
problem due to  the smell—which
can range from disagreeable  to
downright intolerable—generated
by some of the composting
methods. Money is a problem as
counties, cities, and towns cut
back on services as budgets
tighten. Many composting methods
require investments for machinery
and land and, at the very least, for
a collection program. Finally,
composting creates a product that
needs to be used or sold. Many
communities use the compost
themselves for local
groundskeeping or offer it free to
residents. Savvy local officials
have been able to  sell the compost
to nurseries or others. But that
requires market knowledge and
quality control—which can be
difficult. (Bits of plastic from
collection bags or  bits of wood can
result in unusable or unsaleable
compost.)
  Local planners can choose
among many options for
composting. For most methods, the
material to be composted is formed
into windrows—elongated piles or
rows—up to 12 feet high and 24
feet wide. The piles are then left to
decompose. The time required to
effectively compost the material is
anywhere from 4 to 18 months,
depending upon the frequency of
turning the material. Turning
aerates the pile—a crucial element
in composting. Forcing air through
the piles using a blower and a
network of pipes underneath the
piles hastens the composting
process: The compost is ready after
only 2 to 10 weeks. Forced
aeration methods require more
energy, but also create less odor
and can be done on a smaller scale
than  less-intensive windrow
composting.
  Composting can also be done
"in-vessel." The material is
composted within a chamber or
vessel in which temperature,
moisture, etc., can be carefully
controlled. In-vessel composting
requires little space, but is quite
expensive to start-up  and power.
The compost, though, is ready in
one to two weeks.
 —Gregg Sekscienski,
 Assistant Editor
   14
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A  Tale   of  One   City
Making recycling a top priority in
Charlotte,  North Carolina
             by Liz Chandler
Mecklenburg CminJy pho[,
 /989's Hurricane Hugo created
more waste in a night than
Mecklenburg County, North
Caro//na, normally generates /n a
year, As part of (he clean-up
effort, the county ground
300,000  tons of trees into mulch.
(Chandler is a reporter for the
Charlotte Observer.)

JULY/AUGUST 1992
    n a fall night in 1989, Hurricane
    Hugo roared into Charlotte, North
Carolina, turning this so-called "City of
Trees" into a city of trash. The 90 mile
per hour winds snapped trees and
downed power lines to create more
waste overnight than all of
Mecklenburg County's 511,000 people
generate in a year. By dawn, the city
and county had launched a cleanup
that would last 18 months, cost more
than $27 million, and become the
biggest test ever for the community's
commitment to recycling.
  To preserve landfill space,
government officials decided to collect
and grind 300,000 tons of trees into
mulch. "The hurricane inundated us
with waste—particularly yard waste,"
says Charlie Willis, chairman of the
county's solid waste advisory board.
                                                                                                         x-
"We couldn't bury it. We didn't have a
place for it all. And we thought it
would be a step backward from our
commitment to recycling. So we had to
go out and find places to stack
thousands of tons of trees until we
converted them to mulch."
  The nation's 35th most populous
city, Charlotte has become accustomed
to adversity in waste disposal. The
city, which spreads over 80 percent of
Mecklenburg County, boomed during
the 1980s, growing to the nation's
third largest banking center, reaching
the final cut for a new National
Football League team, and landing on
Newsweek's Top 10 "hottest" cities
list. And along with a 10-year growth
spurt that added 25 percent more
people, came tons more trash. Today,
residents and businesses generate
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Tl      /V

about 600,000 tons of garbage a year,
and now the community is without a
public: landfill.
  The 300-acre dump that served for
20 years hit capacity in April. Citizen
lawsuits have blocked attempts to
open  a new one. Neighboring South
Carolina, which borders Mecklenburg
County, recently joined the fight to
stop a planned 574-acre landfill on the
South Carolina state line. The South
Carolina legislature passed a law in
June that would make that state's
low-level radioactive waste dump
off-limits to North Carolina if any
North Carolina county builds a landfill
within a mile of the South Carolina
border. Lacking its own landfill,
Mecklenburg County has contracted for
space in a private dump—a move that
has pushed up  dump fees  and sparked
a new round of legal battles.
  It is the constant struggle of siting
new landfills that has propelled
recycling from a modest experiment to
a top  priority in this community.
Citizens have embraced recycling with
75 percent of eligible households
participating at least once  a month in
Charlotte's voluntary curbside
program. Seven local governments in
Mecklenburg County, including
Charlotte, have joined in a waste
management plan that makes recycling
the most favored disposal  method.
  The plan calls for reducing the
amount of trash buried  or  burned by
25 percent per capita by next July. The
goal jumps to 40 percent reduction by
2001. So far, the community has
reduced disposal by Kt percent .since
1990—a long  way from next year's
target.
  To meet the goals, the city and
county have set up aggressive
recycling programs. This year, the two
governments will spend $6.2 million
on recycling collection and processing,
up from $1.8  million three years ago.
They also plan a $10 million recycling
center for business waste. In January,
curbside collection will be extended to
84,000 apartments and condominiums.
And a new law requires al! private
haulers who serve businesses and
citizens outside Charlotte to provide
recycling to residential customers.
  There's already an array of recycling
programs in Charlotte: residential
curbside pickup, yard waste pickup,
dropoff centers, and a
remove-and-resell operation for bulky
appliances left at the landfill. The
county mines and sells metals from
ash at its incinerator. It also runs small
recycling programs for cardboard, car
batteries, and motor oil.
  Curbside collection in Charlotte
reaches 110,000 single family homes
Recycling coordinators won't
accept new materials until
they are certain they have
buyers.
and is nationally recognized for its
high participation. Residents toss glass
bottles, aluminum and steel cans,
newspapers, and milk containers and
other plastics into bright red "Curb it"
bins and place the bins at the curb.
City collectors carry the material to
recycling headquarters, where glass is
smashed, cans are crushed, and plastic
and newspaper are baled for sale.
  Recycling headquarters is a
converted warehouse about twice the
size of a high school gym.  Recyclables
are dumped on the floor, pushed by
tractors onto conveyor belts, and
separated by workers into bins. Loads
are then baled for sale to buyers. A
private company runs the processing
center at no cost to the county. In
return, the company keeps whatever
profits it makes.
  Charlotte took a big step in recycling
in 1991 when it cranked up yard waste
collection. Residents place tree limbs
and brush at the curb. Grass clippings
and leaves must go in clear plastic
bags, so workers can see what's inside.
City haulers drop the materials at two
sites, where county workers take over.
  With a shredder and three giant
machines called tub  grinders, county
workers grind scrap wood and limbs
into mulch. Other yard waste is
composted: It's  laid out in long rows,
watered, turned frequently to aerate,
and sometimes  has nitrogen added to
it. Within six months, the waste
becomes a black humus, which is used
to enhance soil.
  Both products are sold to residents
and landscapers. The county last year
made $100,000, an amount expected to
jump this year because of a new state
law that prohibits putting yard waste
in landfills. Mulch goes for about $1
for a 20-pound  bag; compost sells for
$3.50 for a 40-pound bag. The county
has a revenue sharing deal with a
private company to sell compost at
local retail stores.
  Recycling coordinators won't accept
new materials until they are certain
they have buyers. Charlotte, for
example, claims to be the first city to
accept spiral paper cans—from
products like frozen juice—for
recycling. Officials added the
cylindrical cardboard cans only
because they struck a deal with a
nearby company that converts the cans
into low-grade paper for cones that are
used for textile  yarn, carpet, and  tape.
"We would never have picked up
spiral cans unless the market  had
approached us," says Gary Saul, the
county's deputy engineering director.
"We know markets have been a
problem. We're cautious. You have to
know your market before you get into
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                                                                               Charlotte recycling organizers say they
                                                                               have strong markets tor their recyclables
                                                                               because their supply is clean and
                                                                               thoroughly sorted.
something."
  As competition for buyers heats up
across the country, Charlotte recycling
organizers say they've maintained
strong markets  because they supply a
clean,  thoroughly sorted  product.
"We're going after the best quality
paper we can get to supply our
plants," says Kenny  King, a buyer who
has a contract for Charlotte's
newspaper.  "We've got to have a  large
quantity. We want it
source-separated .... They do an
excellent job at it."
  Says the county's Saul: "When
things get tight, buyers are going  to
want the best material. They don't
want a bunch of newspaper with
broken glass mixed in."
  Despite everything that Charlotte is
doing, city and county leaders admit
they probably won't make the
25-percent reduction goal next July.
More likely, it will be 1994, after  a
new commercial recycling center
opens. The center is the  city's first
significant venture into attacking  the
business waste stream, which accounts
for 55  percent of all  trash.
  The  success of the center is not
guaranteed.  County leaders last year
took steps to ensure a steady supply of
recyclables with a "flow  control"
ordinance. It required that all waste
generated in Mecklenburg County be
dumped at a county disposal facility,
and it  gave county officials power to
dictate which facility haulers used.
The plan was to direct commercial
waste rich with paper, cardboard, and
other recyclables to the new recycling
center. But one Mecklenburg County
company, wanting to use its own
landfill outside the county, sued and
blocked the new law.
  Now the county has turned to
old-fashioned competition to lure
haulers. Officials are devising
strategies, such as  cut-rate dump fees
and tax incentives, to lure haulers to
use county facilities. "We can't go too
far, because it could backfire," says
Saul. "If we make  disposal  too cheap,
there's no incentive for companies to
cut the amount they produce."
  Despite recycling's popularity,
nobody believes it's a cure-all. The
county's waste management strategy
also relies heavily on incineration.
Landfilling is the least-favored option.
  "Recycling is one of the options
we've chosen to manage a portion of
our waste," says Saul. "It's  part of the
answer .... We want to recycle
everything we can, then incinerate the
rest. We only want to put things that
won't burn in the  landfill."
  Mecklenburg County's  incinerator
opened in 1989; it burns 200 tons of
refuse  daily. Steam generated from
incineration heats  buildings at the
University of North Carolina-Charlotte
in the winter. And the electricity
produced  is sold to the Duke Power
Company. The plant burns about 11
percent of the county's waste; energy-
sales help defray about half the $2
million annual operating costs. The
rest of the money comes from dump
fees charged at county disposal sites.
  The  county  plans a second
incinerator that will  burn  600 tons
daily. Set to open in 1996, the $90
million burner is to be paid for
through revenue bonds and energy
sales. All told, the two incinerators are
projected to burn 26 percent of the
county's waste in 1996.
  So far, the incinerators have dodged
the kind of citizen's  legal  challenges
that stalled a new landfill. Officials
have calmed neighbors' fears by
monitoring air quality around its
current burner and publicizing the
results. The county pledges similar
tests around the new incinerator and
will build in anti-pollution devices,
such as stack scrubbers and a bag
house.
  Mecklenburg County has spent more
than $100,000 to study a myriad of
waste disposal options, including such
obscure methods as refuse-derived fuel
and bioconversion. Officials say
they're confident the recycle-burn-bury
combination is best.  Still,  it's going to
take more than a disposal  plan to
reach the 40-percent reduction goal by
2001. "The real key is reducing waste
at the source," says Saul. "That takes
time. That means plants have to
change processes, and people have to
change habits."
  Board chairman Willis says people
are beginning  to do that. "There's a
tremendous intangible benefit derived
from curbside recycling. Those red
boxes are like  advertisements. Public
awareness is so great that  it filters into
everything people do. They buy
smarter. They  think greener. They are
more aware of their impact on the
environment." n
JULY/AUGUST 1992
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Into th
                                                            VV(js(*; Management photo.
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Collection:
The   First  Step
 Recovery rates have been a  success
by Bruce R. Weddle
 In 1990, the United States generated
 lover 195 million tons of municipal
solid waste, approximately 4.3 pounds
per person per day.  This exceeds the
generation rate in every other
industrialized nation. The good news
is that Americans recognize the
problems associated with municipal
solid waste and are  responding by
separating and collecting many types
of material for recycling.
  Just take a look around.
Supermarkets are accepting used
plastic grocery bags  for recycling,
employees are collecting office paper
at the workplace, local  gas stations are
taking used oil back from their
customers, and schools are recycling
everything from notebook paper to
plastic food trays. Where once we may
have been content to return aluminum
cans to central collection centers, or
contribute the occasional stack of
newspapers to a  paper drive, materials
of all kinds are finding their way into
a variety of public and  private
collection programs.
  Of course, separating and collecting
recyclable goods is just the beginning;
recycling isn't complete until  the
materials have been  reprocessed,
marketed, and reused. Nonetheless,
progress has been substantial over the
(Weddle is Director of EPA's
Municipal and Industrial Solid Waste
Division.)
last several years as the foundations of
a comprehensive, nationwide recycling
system are being laid. In 1990, we
recovered 17 percent of our waste
stream for recycling and composting,
compared to just 10 percent in 1985.
This means that in 1990, because of
our higher generation rate, we
recovered over 33 million tons of
materials, which is more than twice
the 16 million tons recovered in 1986.
  While federal, state, and local
governments, industry, and private
organizations have all contributed to
the rapid growth in the collection of
recyclable materials, the real heroes
are ordinary citizens. Individuals of all
ages are not only collecting more
materials for recycling, but they're
volunteering at collection sites,
promoting programs, and more.
Perhaps we as a nation have embraced
recycling because it allows us as
individuals to do something that has
an immediate and measurable impact
on a problem to which we all
contribute. Considering the diversity
and complexity of today's
environmental challenges, separating
recyclables from our trash reminds us
that we really can make a difference.
  In many areas of the country,
municipal governments have led the
way. Encouraged by the support of
local civic groups, volunteer recycling
committees, and other concerned
citizens, these communities have
designed and implemented recycling
programs that reduced  their reliance
on landfills and incinerators and
provided considerable savings in
tipping—or dumping—fees. These
 communities also earned revenues
 from the sale of recyclable materials
 that helped offset the cost of the
 recycling program.
  Community recycling programs are
 typically organized around curbside or
 dropoff collections. In a curbside
 program, local haulers or recycling
 companies pick up sorted or mixed
 recyclable materials directly from
 residents. Characteristically, curbside
 programs result in a high participation
 rate, successfully diverting a
 significant percentage of the waste
 stream. The number of curbside
 collection programs has quadrupled
 since 1988; today, some 65 million
 Americans are served by these
 programs. Lexington, Massachusetts,
 for example, established its curbside
 recycling program in 1988, distributing
 recycling bins to area residents to be
 filled with mixed recyclables and
 placed at the  curb for collection by a
 private contractor. The city reported  in
 1991 that over 80 percent of its
 residents participated, diverting 30
 percent of the city's waste stream.
  Dropoff collection programs require
 the individuals to bring their separated
 materials to a central site. These
 programs range in scope from
 newspaper collections sponsored by
 scouting organizations to
 industry-sponsored buy-back projects
 to fully staffed multi-material
 collection centers. Operating dropoff
 sites is less expensive than managing
 curbside collection programs, though
 lower participation and collection rates
usually result. In some communities,
vending machines are being used for
JULY/AUGUST 1992
                                                                                                             19

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                                                                  PAPERS
Seventeen percent of municipal solid waste /'s now recovered for recycling,
up from 10 percent m /985.
 consumer convenience;. Individuals
 simply deposit their aluminum and
 plastic beverage containers into the
 machines and receive cash in return.
  To encourage recycling by residents,
 some communities are using economic
 incentives, such as "variable rate"
 programs in which residents are billed
 (or waste collection based on the
 weight or volume of waste they place
 at the curb for disposal. Material set
 out for recycling is collected without
 charge. One of  the most successful
 programs began in Seattle,
 Washington, in the early 1980s. The
 program significantly increased the
 amount of material diverted from the
 waste stream. In 1991, approximately
 40 percent of the city's waste (about
 50,000 tons of material) was collected
 for recycling.
  To learn more about such successful
coilection efforts, EPA is funding a
study by the Institute for Local
Self-Reliance, a nonprofit research and
educational group dedicated to
supporting independent communities.
The institute is developing case
studies on 30 community-based
recycling programs. It is compiling and
comparing such data as costs,
participation levels, and recovery rates.
The idea is to provide reliable
information that other communities
can use to plan for and evaluate their
own programs.  The information will be
made available  in a three-volume
report this fall.
  Regional approaches are also being
undertaken. A coalition of 20
southwestern cities created the
Southwest Public  Recycling
Association, which is examining
collection and  marketing issues. The
cities discovered in 1991 that each
used different methods to compile and
calculate recycling and participation
rates. They are now working to
develop uniform measurement
methods to enable them to gauge the
success of their efforts more
accurately. Because of low landfill
costs and high transportation costs,
caused by long distances to markets for
their collected recyclables, these cities
also face special recycling challenges,
which they are working to overcome.
Additionally, the coalition is working
cooperatively to  market recyclables,
thereby ensuring a steady supply of
materials on which recycling
industries can rely. This will make the
recovered materials more valuable and
easier to sell.
  State governments have been
instrumental  in providing a boost for
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 recycling; today, virtually every state
 in the country has enacted some type
 of recycling legislation. In  1986, Rhode
 Island instituted the country's first
 state-wide regulations mandating
 recycling, requiring the participation of
 both households and businesses. The
 state initially concentrated on
 residential collection. A list of
 materials to be collected from the  curb
 was compiled, and residents were
 asked to separate these materials from
 their household waste. The
 participation rate by households
 reached  80 percent this year.
 Businesses were asked to prepare
 recycling plans, focusing their efforts
 on those materials that appear in the
 largest quantities in their waste  stream.
 To date, over 90 percent of the
 companies have submitted their plans
 and report an average reduction in the
 amount of waste requiring  disposal of
 20 percent. In Pennsylvania, where
 over two million residents  in 200
communities are participating in
community recycling programs, a state
recycling program is being developed
that will eventually involve  over eight
million of its citizens.
  The federal government has
introduced a large-scale recycling
effort, In 1991, President Bush signed
an Executive Order requiring, among
other things, that every federal agency
and department formulate a  plan to
recycle  usable materials, from paper
and plastic to used oil and automobile
tires. Through this effort, the federal
government will soon become one of
the largest recyclers in the world. The
General Services Administration is
helping many federal agencies get their
programs off the ground and has
established collection programs in
federally owned  office buildings.
  EPA launched its own recycling
program in 1975. Program organizers
educate employees about recycling,
track the amounts and types of waste
  Many community groups, such as these Virginia scouts, recycle
  aluminum cans for fundraising.
$
diverted, and direct purchasing
decisions toward products with
recycled content. While collection
efforts were initially focused on
high-grade  white office paper,  the
program now includes newsprint,
mixed waste paper, aluminum cans,
and glass bottles. Last year, EPA
diverted over 2,400 tons of recyclables
from its waste stream.
  Numerous interagency recycling
partnerships have been established as
well. Just this  year the U.S. Postal
Service  joined forces with EPA to
design an educational poster on
recycling that  will  be  displayed in post
offices across the nation. The Postal
Service  itself has implemented its own
comprehensive recycling program,
collecting such diverse materials as
paper and cardboard from its offices
and waste oil,  lead-acid batteries, and
antifreeze from its  vehicle maintenance
operations. In  1990, the Department of
the Interior, along with Dow Chemical
and Huntsman Chemical, formed a
partnership to sponsor major recycling
programs for glass, aluminum, and
plastics in  several national  parks.
  Another  cross-agency effort is
helping to  provide guidance to
manufacturers and consumers  on the
use of marketing claims like "recycled"
and "recyclable." Many consumers
want to  purchase products that have
recycled content or other
environmental attributes but have been
confused by the inconsistent and
sometimes  misleading use of
environmental marketing claims.
  To address these issues, EPA
initiated an Interagency  Task Force
with the Federal Trade Commission
(FTC) and the  U.S. Office of Consumer
Affairs to develop a comprehensive
national response to the problems
posed by the inconsistent use of
claims. A major  goal of the task force
is to prepare consistent national
guidelines  for  the use of environmental
claims. On  July 28, the FTC made a
 JULY/AUGUST 1992
                                                                                                                  21

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major contribution to this goal by
announcing the release of voluntary
industry guidelines. EPA was pleased
to assist the FTC by providing
technical input to the guidelines. They
will help provide consumers with
reliable information, discouraging the
use of vague claims like "recyclable
where facilities exist" and encouraging
specific claims like "contains 50
percent recycled material." (See box on
page 10.)
  Private groups, from national
environmental organizations to local
civic groups, have  also done their part
to mobilize recycling in the nation.
The Environmental Defense Fund
(EDF), working with the Advertising
Council, launched  a pair of nationwide
advertising campaigns in 1988 and
1990 to stimulate people's interest in
recycling.  The first recycling
campaign, using the slogan "If you're
not recycling, you're throwing it all
away," generated over 120,000 calls
from people requesting more
information. The follow-up campaign
targeted nonrecyclers, conveying a
message that recycling not only lets
individuals make a difference, but that
it's easy. Other groups, such as the
The foundations of a
comprehensive, nationwide
recycling system  are being
laid.
Natural Resources Defense Council,
have initiated research projects to
quantify the effectiveness of recycling,
and many community organizations,
such as the League of Women Voters
and Keep America Beautiful, are
Regional Refuse Breakdown
Number of curbside recycling programs vs. number of landfills by U.S. region
                                                                     New England
 • Also includes
 Alaska and Hawa

   1 Curbside Recycling Programs

 | Landfills


 Source: BioCycle Magazine
working to increase participation by
residents in local recycling programs.
  Partnerships between industry and
environmental groups have been
especially successful at increasing the
amount of waste being collected for
recycling. In 1990, EDF and the
McDonald's Corporation formed a task
force to study how waste could be
effectively reduced and recycled in the
company's franchises. Among the
actions McDonald's decided to
implement was collecting corrugated
boxes (which comprise over one-third
of its waste) for recycling. Facts about
the company's efforts also are printed
on bags and posters to help promote
recycling among the  restaurant's many
customers.
  Schools also have been active in the
recycling arena. From kindergarten to
college, students are  championing
recycling—and taking the message
home to their friends and families. In
Newark, New Jersey, for example,
hundreds of children from
kindergarten through the sixth grade
have been sworn in as "Recycling
Rangers." Their job: to "tell my family
and friends why recycling is a good
thing to do and help them to recycle."
At the University of Wisconsin-Stevens
Point, students and faculty  instituted a
collection program for paper,
aluminum and other metals, and yard
trimmings. The program recovered
almost 45 percent of the university's
waste stream in the first full year of
operation.
  The tremendous surge in collection
programs in recent years reflects a
growing concern with solid waste
management in the United  States. It
also demonstrates a concerted effort by
numerous individuals to take
responsibility for the waste they
generate. This willingness to make
changes in our lifestyles is a necessary
first step toward developing even more
innovative solutions  in the  years to
come, a
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Processing:
The   Unheralded   Middleman
 by Jerry Powell
In 199), recycling processors handled more than 75 mil/ion tons of post-consumer
scrap materials.
JULY/AUGUST 1992
    ecycling's universally recognized
    symbol is truly representative of
 this thriving environmental industry.
 The symbol's chasing arrows perfectly
 connote the sequential, full circle
 nature of materials recovery and use.
  As a beginning, residents,
 businesses, and institutions must
 prepare discards for recycling
 collection. These materials must then
 be sorted, processed, and transported.
 Mills  and factories must convert these
 recovered commodities into new goods
 and products for sale to and use by
 consumers, thus rounding out the
 circle. It is important to note that the
 recycling logo has three equally sized
 arrows.  Should any of the activities
 involved fall behind their counterparts,
 the resulting imbalance will cause the
 system to falter.
  This article outlines the activities
 involved under the second arrow: the
 conversion of collected materials into
 commodities desired by industry here
 and abroad. In a sense, this article is
 about that quiet and unknown element
 of recycling—the processor.
  As well, this article describes a
 growing industry, an industry that
 operates in nearly every American
 town and city. In the United States,
 there are nearly 2,000 sites where
 recovered paper is received, sorted,
 and packed for shipment to paper and
 paperboard mills. Last year, these
 processors handled over 30 million
 tons of recyclable fiber.
  More than  5,000 facilities in the
 United States process scrap metals
 before the material is sent to mills and
 foundries. Over 100 processing
 locations turn glass bottles into
 cullet—small bits of glass that can be
 easily melted—for use by container
 manufacturers. Similarly, some 300
 scrap plastic  processors now operate in

fPoweJI is Editor-in-Chie/ of Resource
Recycling Magazine based in Portland,
Oregon.)

                                23

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I    I     11
i I  llv  I!
                                                                                          The processor turns "trash" into
                                                                                          commodities that are ready for
                                                                                                                sale.
the United States. In total, recycling
processors in 1991 handled more than
75 million tons of post-consumer scrap
materials and sold these commodities
to end users at  a  combined value of
$14 billion.
  This is an historic industry, for
recycling processing has occurred  ever
since we began to use paper and
metals. Much of the paper made in the
1700s and  1800s  in the United States
contained high levels of post-consumer
fiber, primarily old paper and rags.
Similarly, we've always collected scrap
metals for recycling. P"or example,
George Washington owned several
scrap metal processing sites.
  To portray how collected materials
are converted into industrial
commodities by the recycling industry,
let me summarize how some specific
materials are handled.
• Paper. As with other recyclables,
there is little demand for a mixture of
all types of used  paper and
paperboard, Recycling mills want
specific; grades  of paper, not a
combined mess. In fact, recovered
paper is sold in more than 50 different
grades. Thus, the paper processor's
principal role is to make sure the mill
receives the grade of paper desired.
This entails assuring that a bale of
paper doesn't include other types of
paper or nonpaper items, such as
plastic or metal. For instance, a bale of
computer paper cannot include a
significant amount of newspaper.
  The second principal function of the
paper processor,  as with processors of
other recyclables, is to package
recovered paper in a manner desired
by the paper mill. This  generally
entails the production of a dense,
wire-bound bale, which  is the easiest
package to store and ship.
• Metals. The scrap metal processor
performs similar  tasks. For example,
loads of post-consumer aluminum cans
are sorted magnetically and manually
to assure that other metals and other
materials are eliminated. The cans are
then packaged, commonly into a dense
briquette.
• Plastics. Just as there are many
kinds of paper, plastic products are
made from numerous resins.  Each has
unique  features in terms of rigidity,
density, strength, etc. Thus, a mixed
lot of scrap plastics is relatively
useless. The scrap plastic processor
employs mechanical and manual
techniques to assure that a load of old
milk jugs, for instance, contains only
these containers and no other plastics
or other materials. Sorted plastics are
then shredded, washed, and pelletized
before shipment to a recycled plastic
user.
o Glass. Glass containers are
commonly sorted by color before
shipment  to a processor. The processor
uses mechanical techniques to remove
metal lids and caps and to remove
paper labels. The glass is then crushed
before it is introduced into the
glassmaker's furnace.

  The only constant element  of today's
recycling industry is change.  The
domestic processing industry in 1992
is far different from that of just 10
years ago.
  Considerable investment has  been
made in new recycling processing
systems. A few examples are  offered:
•  In recent months a number of
firms, with financial assistance from
the plastics industry, have developed
highly automated machines that use
x-ray and  infra-red detection  systems
to sort plastic containers by resin type
and color.
•  Researchers at several universities,
including Carnegie Mellon and the
University of Illinois, are developing
techniques to automatically sort glass
containers by color.
•  In the  last decade, new scrap metal
and paper processing systems have
been introduced to the market.
•  Major  European and American
manufacturers have developed  highly
sophisticated plastics processing lines.

  A second trend is the entry into the
processing industry of "Fortune 500"
firms. Processing of recyclables is no
longer dominated by small
entrepreneurs.  Major makers of
recycled products have integrated
downward to acquire recycling
processing operations. For instance,
Wellman,  the nation's largest plastics
recycler, acquired CRInc, an operator
of processing plants nationwide. This
gives the recycled product maker access
to an adequate  supply of material at
the lowest cost and highest quality. This
trend also includes the involvement of
all the major publicly traded waste
management firms, such as
Browning-Ferris, Waste Management,
Laidlaw Waste Systems, and  others.
These firms have invested substantially
in establishing and operating
processing plants.
  A third  trend is the entry  in recent
years of local government. Cities and
counties face rising costs for solid waste
collection  and disposal and are now,
more  than ever, looking to recycling
and composting to reduce the burden
on landfills.  In  addition, nearly every
state has adopted a waste management
law that places recycling collection
requirements on local governments. In
order to market the recyclables now
being collected  in their communities,
many local governments have
established new processing centers.
  Many of these centers are  owned by
the city or county and operated by a
private contractor.  Many are called
MRFs, or  materials recovery facilities.
In these plants, source-separated paper
and commingled bottles and cans are
sorted and processed, much  in the
manner described earlier.
  Processors of mixed waste often call
their plants  "dirty" MRFs.  These
facilities take loads of mixed solid waste
and use mechanical and manual
techniques, such as magnetic separation
and hand  picking, to remove selected
types oi paper,  metals, glass, and
plastics.
  According to Governmental Advisory
Associates of New York City, the
number of these commingled recyclable
and mixed waste sorting plants nearly
doubled in just the last two years.
 24
                                                                                                         EPA JOURNAL

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Mike Hri.s.smi pho!
Currently, sonic lib of these facilities
operate in the United States and have
these features:
•   More MRFs are in the Northeast
than any other region.
•   MRKs are becoming far more
mechanized than in past years.
•   New plants are about twice as large
as the average MRF now operating.
•   The average MRF processes about
130 tons of  material per day and costs
about $3 million to construct and
startup.

   A fourth  trend is the increasing
emphasis on material quality. This
means that  manufacturers can
accommodate higher percentages of
recycled materials in their feedstock
(see article on Rhode Island's
experience on page 26).
   A fifth trend is the growing number
of new recycling grades handled by
processors.  With consumers demanding
recycled products and with  industry
responding, processors are being asked
to supply many new types of
recyclables.
  Hundreds of communities now
collect magazines separately in curbside
recycling collection programs. This
fiber is used, along with old
newspapers, to make deinked
newsprint. Several market analysts
predict that a shortage of old
magazines will occur before 1995 unless
collections grow as fast as the number
of new deinking systems coming on-line
in the United States and Canada.
  Another recyclable that is being
handled by more and more processors
is plastic film—items like plastic
shopping  bags, trash bags, and plastic
wrap for food. The United States uses
three times as much plastic film as soft
drink bottles, milk jugs, and water
bottles combined. There are a number
of high volume uses for reclaimed film,
including  the manufacture  of trash
bags.
  And there is considerable attention
nationwide on recovering and using
construction and demolition wastes.
New facilities are opening daily that
sort and crush these wastes to produce
new  materials for use in construction
and other applications. Of particular
note are the growing number of wood
waste processing plants and facilities
that process scrap  gypsum wallboard.
  Some emerging  trends for processing
recyclables bear watching.
Transportation of recyclables, especially
paper, by railroads is becoming
increasingly common. For example,
state legislation requiring recycled
newsprint has caused many Canadian
newsprint mills to  bring back old
newspapers from the United States in
the empty box cars returning to the
mill.
  Another issue is the health and safety
concerns from processing recyclable
materials, especially manual sorting of
these materials from mixed waste.
Worker exposure to high levels of
microorganisms and the poor design of
the working environment  in many
processing facilities have been
documented in Denmark.
  Recycling cannot occur without
collected materials being processed.
The processing industry—the quiet
giant of recycling—has undergone
significant changes in the past decade.
Even so,  tomorrow's processor will be
different from the processor of
today,  a
JULY/AUGUST 1992
                                                                                                                   25

-------
  I     ll
  IIU  II iu  LUUU
Too much broken glass makes ;t hard to .sort ou( glass by
color, as [he market demands.
,'ti
                                                                  When   It
                                                                  Doesn't  Make
                                                                 the  Grade
                                                                 Quality control is crucial
                                                                 by Edward F. Connelly
                                                                        arbage in; garbage out." The
                                                                        expression wasn't meant to
                                                                 describe the solid waste industry, but
                                                                 it is very applicable to the collection
                                                                 and processing of recyclables.
                                                                 Recycling programs are businesses that
                                                                 market commodities. If the
                                                                 commodities are being treated like
                                                                 trash, that is what they become.
                                                                   Quality control is essential to ensure
                                                                 that recyclables can be marketed. This
                                                                 does not mean producing the cleanest
                                                                 stream of recyclables no matter what
                                                                 the cost, but striking a balance
                                                                 between the needs of the market and
                                                                 the cost of producing recyclables to
                                                                 meet those needs. To achieve this
                                                                 balance, recyclers must combine a
                                                                 clear understanding of the market, the
                                                                 nature of the waste that  is to be
                                                                  (Connelly is the Recycling Program
                                                                  Manager for the Rhode Island Solid
                                                                  Waste Management Corporation.]

                                                                                      EPA JOURNAL

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 recycled, and the capabilities and
 operating cost of the collection and
 processing system.
   Markets for recyclable materials  are
 constantly changing in response to
 traditional market forces and to the
 expansion of recycling programs.
 Recycling managers must regularly
 review and adjust their collection and
 processing operations to account for
 increases or decreases in the amount
 the markets pay for material, changes
 in minimum quality, or technological
 advances in manufacturing. Several
 years ago, when the economy was
 booming and there were fewer
 recycling programs, it was  relatively
 easy to market newspaper that
 contained up to 5  percent other paper.
 Today, markets demand 100 percent
 newsprint.
   Similarly, in the past, it was  not
 difficult  to sell mixed plastic bottles.
 Today, however, manufacturers take
 only sorted material, and they pay less
 for it. Recycling programs that collect
 and market glass must now ensure that
 the product is free of ceramics, like
 coffee mugs and dishes, because
 ceramics can explode in glass furnaces.
 Programs that cannot deliver
 ceramic-free glass  will lose their
 markets. On the positive side, new
 markets  are developing for material
 such as magazines and textiles, and
 technological advances  in plastics
 manufacturing promise to allow
 recycling programs to market mixed
 materials.
  The key to success is understanding
 what  the recycling program has to
 produce  in order to sell products every
 day. Knowledge of the market tells the
 manager what has to be produced,  but
 it does not tell him or her how  to
 consistently produce quality products.
 This requires monitoring at all  three
 major steps: at the source, during
 collection, and during processing.
 Quality control at  these points is
 necessary whether the program is
 designed, to collect industrial scrap or
 paper from classrooms.
  As the source of the material to be
 recycled, generators—residents,
businesses, etc.—must understand
exactly what materials are to be
separated from the waste stream, the
condition they must be in, and the
contaminants that are not allowed. A
thorough, initial training must be
followed up with reference materials
and periodic reminders.
  In Rhode Island's municipal
collection program, residents are
informed of a program start by
postcard. They are invited to attend
public meetings  or call special phone
lines to get answers to questions about
recycling. Newspaper advertisements
also explain the  program. A flier with
a list of materials to be recycled is
delivered to each residence. All this is
done so that participants will know
exactly what can be collected for
recycling and what  can not.  The
approach applies to any type of
recycling; time and  money are well
spent on education because education
results in a cleaner stream of
recyclables and thereby reduces the
cost of removing contaminants before
marketing.
  The collector is the only regular link
between  market  and source and plays
a major role in maintaining quality. All
collectors must understand the nature
of materials that are acceptable and
should be instructed to reject materials
that do not meet specifications. There
is no better way  to convince a
generator to improve quality than to
reject an unacceptable load. Warnings
are useful, but they  must contain
instructions on how to improve. If a
generator needs help, the collector can
provide educational material or can
arrange for a site visit by his home
office.
  In Rhode Island's residential
recycling program, truck drivers play a
major role in reducing contamination
by monitoring the materials they
collect. When the drivers spot
unacceptable material, they place
brightly colored  stickers on the
contaminant to notify the resident.
This system has  proved effective in
reducing contamination and improving
quality.
  After collection, most recyclables are
processed before they are marketed.
The processor's knowledge of the
market tells him how much processing
is necessary, but worker training
determines how effective the process
will be. Some processing facilities use
bonuses as a means of encouraging
workers to improve quality and keep
vigilant for contamination.
  The importance of the worker's
contribution to  quality control can  be
illustrated in the following anecdote.
Rhode  Island's material recovery
facility operator learned that the
processing and  sorting equipment was
breaking  significant amounts of glass,
making it difficult  to separate by color
and causing a large percentage of it to
be lost because  the pieces were too
small to sort. By cushioning the fall of
the glass, the operator reduced
breakage; more  material  was recovered;
and contamination by small pieces  of
glass was reduced.
  Recycling programs must be
prepared to pass up markets if the
needs of  the market cannot be met
efficiently by the program. Rhode
Island's residential recycling program
produces large amounts  of high-quality
newsprint. Metal, glass, and plastic are
collected with the newspaper, and
some metal cans get mixed  in with the
paper. Not all the cans are removed,
because the cost of removing them  is
high, and most  markets can live with a
small percentage of the combination.
An offer  from a local building-
products  manufacturer to purchase
large amounts of metal-free newsprint
had to  be rejected, because  the price
the company was  willing to pay would
not have  justified  the cost of the
equipment and  labor to remove the
metal.
  Even the best quality control system
cannot protect against every mishap
when the raw material of the business
is trash. Early in Rhode Island's
municipal collection program, an
entire load of newspapers was
contaminated because of a promotional
vinyl record that was included in a
Sunday newspaper. That time, it was
recyclables in, garbage out.  a
JULY/AUGUST 1992
                                                                                                                27

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            I  III  I
rrlp
  VI V
                                                                                                    At least seven
                                                                                                  J different types of
                                                                                                  I plastic resins are
                                                                                                  | found in the
                                                                                                    municipal solid
                                                                                                    waste stream,
                                                                                                    making it difficult
                                                                                                    to process the
                                                                                                    plastics to
                                                                                                    specifications.
28
                                                                                                     EPA JOURNAL

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The  Challenge  of  Maifcets
The supply of recydabies is larger than the demand
by Michael Alexander
   |i/|arkets, markets, markets,"
   B w u the recycling buzzword for
the 1990s, has become all too familiar
to those responsible for  moving
materials through the recycling
process. Why are markets so vital to
the success of recycling? How do they
behave under the current recycling
fervor? What forces lie behind their
development?
  Traditionally, a market is created
when the available  supply of a product
is matched by a corresponding
demand. Usually, supply and demand
follow each other closely, as markets
evolve over time. In the rush to
recycle, however, the demand for
recyclable material  has not always kept
pace with burgeoning supplies. While
state and local governments  have
proved effective in  implementing
programs to recover materials, they
have had less success in finding
markets for them.
  Several factors contribute to this
problem. The lag time between the
availability of large quantities of
recyclable materials and the
development of  manufacturing
capacity to convert  these materials into
finished products creates supply and
demand imbalances. This is  especially
true during the current economic


(Alexander is a  Policy Analyst with
the Northeast Recycling Council.)

JULY/AUGUST 1992
recession. Also, geographic distances
between the sources of recovered
material and industrial consumers
frequently fuel regional marketing
problems, and hard-to-anticipate
international economic forces further
impact domestic markets. Finally,
policies originally intended to aid in
the development of this country's
natural resources, such as energy
subsidies, timber supports, and certain
federal tax codes, encourage
manufacturers to use raw, virgin
materials rather than material
recovered from the waste stream. To
illustrate how these forces affect the
recyclables  marketplace, three
materials that are currently
experiencing marketing problems are
examined here.

Green Glass
Generally speaking, recovered glass is
used to produce new glass containers
of the same color:  Brown glass goes
into new brown containers, green glass
into new green containers, and so on.
A number of furnaces in the United
States are dedicated to clear and
brown glass production, and recyclers
enjoy a relatively stable market for
these colors. However, only a few
furnaces are dedicated to green glass
production, and recyclers throughout
the country report difficulty in finding
markets for green cullet.
  The imbalance is created largely by
the import of green bottles from
sources outside the United States.
While only a few domestic beverage
companies choose to package their
products in green bottles, several
foreign companies do. As a result, the
amount of green glass  collected by
recyclers exceeds the capacity of
domestic bottlers to use it.
Domestically, green glass bottle
production represents  about 13 percent
of dedicated furnace capacity, while
green containers average 23 percent of
the glass-container  waste stream. This
difference is estimated to translate into
a production capacity shortfall for
green bottles of one million tons per
year.
  This imbalance is exacerbated in
some regions of the country by market
dislocation: For instance, while
recyclers in the Midwest may not  have
difficulty securing markets because of
their proximity to green glass furnaces,
others, particularly  in the Northeast
and Northwest, are  forced to either
landfill or stockpile the material
because of the costs associated with
shipping to distant markets.

Post-Consumer Plastic Resins
Similar marketing problems currently
face those recovering various
post-consumer plastic resins  (PCR).
             Continued on next page
                                                                      29

-------


PCR includes items such as shampoo
and laundry detergent bottles and milk
jugs. The price paid to processors of
these materials has been steadily
declining over the past few years; a
number of factors have contributed.
  At least seven  different plastic resins
are found in the  residential waste
stream. Collecting, separating, bailing,
and processing these resins to meet
market specifications is difficult
because of cross  contamination of
resins and the consequent
contamination of the end product.
Once processed, the recovered plastics
have limited applications. Yet, these
problems can be managed through
improved public education programs,
more efficient handling and processing
systems, and advances in technology.
The most pressing problem facing
plastic recyclers  is a decline in the
price of virgin resin, the material that
PCR must compete with for market
share.
  Since 1989,  the price of virgin
polyethylene resin,  which is used to
package a range of consumer products,
has been decreasing, and many
analysts predict that the trend will
continue for several more years. Even
as the recession dampened demand for
plastic: resins, production  capacity
expanded significantly in  the United
States. A tremendous amount of
additional capacity  is also planned, or
under development, around the world,
most notably in Saudi Arabia, the Far
East, and Indonesia.
  These foreign capacity expansions
are hurting U.S.  resin producers who
have traditionally relied on overseas
markets to absorb their excess
supplies. In the absence of these
markets, U.S. producers must either
reduce production or sell  their resins
in the already saturated North
American market. This has resulted in
lower virgin resin prices and has led to
Markets for scrap aluminum are strong. Here shredded
aluminum cans arrive by rail at a Reynolds Aluminum
reclamation plant. The cans will be off-loaded and fed into a
furnace for melting.
the inability of PCR to compete in a
number of plastics markets.
  Over time, virgin resin capacity may
diminish. Low prices may force some
producers out  of business, leading to a
balance of supply and demand and to
higher and more stable prices for
virgin polyethylene. However, this
cannot come soon enough for recycling
programs that  are recovering PCR.
Weak PCR markets are straining
municipal recycling budgets and
challenging  officials to find more
cost-effective collection and processing
systems. Some industry analysts
predict that it could be several years
before the price cycles of PCR and
virgin plastic reverse themselves.

Old Newspapers
Despite being a principal target of
market development efforts, even old
newspapers cannot seem to clear their
market impasse. There has been a
notable time lag in some regions of the
country between market demand and
the growing supply of recovered
newspapers.
  Since 1988, when recycling began to
take hold as a primary solid waste
30
                                                                                                       EPA JOURNAL

-------
management strategy, the recovery rate
for newspapers has increased by nearly
50 percent nationally. Although some
markets, such as recycled newsprint
mills, exports, and animal bedding,
did emerge in response to this
additional supply, the price of
recyclable newspapers bottomed out in
1989. As is common in the recyclables
marketplace, some regions have fared
better than others. (See graph.)
  West Coast processors of recovered
newspaper receive, on average, $30 to
$40 per ton more for their material
than their counterparts in the
Northeast. Due to their shipping
proximity to markets in the Far East,
where fiber supplies are sometimes
short, West Coast suppliers benefit
from a relatively stable export market.
More importantly, newsprint  mills in
the Northwestern United  States and in
Western Canada have recently added
significant processing capacity for old
newspapers, creating a  strong market
for wastepaper. Eight deinking
facilities, capable of removing ink and
other contaminants and converting the
paper to pulp for use in making new
newsprint, are now operating in the
region.
  These investments in recycling
capacity were spurred by two factors.
First, federal regulations protecting
spotted owl habitat in the Northwest
restricted logging and increased the
price of wood chips, causing  paper
mills to consider recycled production
inputs as a way to contain raw
material costs. Second, in 1989,
California enacted legislation requiring
all state newspapers to incorporate
increasing levels of recycled  content;
newsprint producers who wanted  to
sell their product in the biggest market
in the region had to have access to
deinking capability.
  Similar laws and voluntary
agreements encouraging the purchase
of recycled newsprint are in existence
in 21 other states and the District of
Columbia. Nevertheless, while these
policies are having a significant impact
on recycled newsprint investment
decisions, regional market gaps
continue to exist between deinking
facilities coming on-line and the
growing supply  of recovered
newspapers.
   State governments in the Northeast
and  Midwest, for example,  facing a
possible shortage of disposal capacity,

In order for  a market to exist
for  recyclables,  a number of
ingredients must be
present....

used aggressive  solid waste legislation
to stimulate the  recovery of old
newspapers.  However, the  majority of
this  originated from Canadian  sources,
and  the Canadian companies are just
now beginning to bring the capacity
on-line that will allow them to take
back their used product. As a result,
the market is currently so saturated
with recovered newspapers in  some
parts of the Northeast that suppliers
are having to pay to move their
material. On  the bright side, the
market for old newspapers  seems
poised to turn around even in  these
troubled regions.
   Over the next  four years, significant
growth is  projected in the capacity of
newsprint manufacturers to consume
old newspapers. Seven new deinking
facilities that could potentially take
recovered newspapers from the
Midwest and Northeast are scheduled
to be in operation by 1996,  bringing
the total number in Eastern North
America to 20. If all these planned
facilities begin operation, they will
increase the current demand by over
one  million tons. Some analysts
 predict that this new demand will
 drive up the price of high quality
 recovered newspapers to as much as
 $60 a ton by 1994.

 Ingredients for a Recyclables Market
 These three examples illustrate the
 interaction of a number of forces that
 shape the market for recyclables. One
 obvious commonality is the impact of
 international market dynamics on the
 demand for domestically generated
 recyclables. Developments abroad,
 such as low prices for materials  that
 recyclables compete with (virgin
 plastics) and the packaging choices of
 foreign importers (green bottles),
 influence domestic markets.
 Reciprocally, large increases  in the
  Pricing for Old Newspapers
  1988 -  1992
  1988
          1989
                  1990
                          1991
                                  1992
Source: Northeast Recycling Council Prices for 1992 represem
first quarter prices only.
JULY/AUGUST 1992
                                                                                                               31

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 supply of recovered material in this
 country, often exceeding domestic
 demand, fuel increases in the export of
 recyclables, as seen by the growth of
 recovered newspaper shipments from
 the West Coast to markets in the Far
 East.
  Also common to the examples cited
 above are supply and demand
 dislocations that lead to notable
 differences in the market status for
 some recyclables in  different
 geographic areas of the country. Each
 region has a unique demographic and
 industrial makeup.  For some, large
 markets exist virtually in the backyard
 (recycled newsprint mills in the
 Northwest); for others, supply
 consistently outstrips demand.
 Frequently, shipping materials to
 where they are needed is the biggest
 obstacle  facing recyclable suppliers.
  These  examples provide a useful
 framework for understanding how
 markets are created. In order for a
 market to exist for recyclables, a
 number of ingredients must be present;
 however, there is no prescribed
 sequence for blending these
 ingredients. For one thing, there needs
 to be an  identifiable source and supply
 of material. Then, systems to extract
 materials from the waste stream and
 deliver them in a specified quantity
 and quality will be  required. A facility
 that is able to accept and
 re-manufacture the  recovered material
 into a saleable form  is also necessary.
 And, there must be an existing or
 potential demand for the finished
 product.
  For some recyclables, markets
 emerge because of signals from the
 pricing system. Companies benefit
 directly from reduced production costs
 by recycling used materials into new
 products. The supply of material is
 pulled from the waste stream and
 delivered to production facilities
Experts predict that the next four years will bring significant growth in
the capacity of newsprint manufacturers to consume old newspapers.
through an existing pricing structure
that provides an economic incentive to
do so. For instance, using recovered
glass to make new containers saves
glass manufacturers in raw material,
energy, and equipment replacement
costs.
  Similar market forces are set into
motion by consumer demand for
products manufactured with recovered
materials. Ey exercising a preference
for recycled goods, consumers can
provide the economic impetus for
companies to seek supplies of
recyclable material. In response to
consumer demand for recycled
packaging,  two major soft drink
companies are now using recovered
plastic in the production of their
bottles.
  The creation of other markets is
supply driven. Significant financial
and policy  commitment to the
development of infrastructures with
the capability to recover materials from
the waste stream is often matched by
capital investment in the
manufacturing capacity needed to
convert those materials into new
products. One element that stimulated
growth in the market for recovered
newspapers in many areas was the
existence of a well-developed
collection and processing system.
Manufacturers are more willing to
invest in recycling capabilities once
recovery programs have developed a
track record for meeting quantity and
quality requirements.
  In the absence of traditional
marketplace incentives, government
can intervene to encourage firms to use
more recovered materials in their
production processes. The California
recycled content law for newsprint
was a significant force behind the
32
                                                                                                        EPA JOURNAL

-------
               Mik<;
                      i photo.
development of strong markets for old
newspapers in the region.

Current Marketplace Distortions
Clearly, recycling has had many
success stories. Genuine long-term
commitments are being made by
governments and businesses  alike.
Unprecedented quantities of  materials
are completing the recycling  "loop,"
conserving valuable resources, and
enhancing the quality of the
environment. Given the relative
inexperience of many markets for
recyclables, especially in handling the
tremendous supply of materials now
being generated, volatilities are to be
expected. Evolution takes time. Yet,
despite the concerted efforts  of both
public and private sectors, there
remain some basic distortions that
need to be addressed by policy makers.
  The  way in which costs are allocated
in the current economic system makes
it difficult for most firms to realize
monetary benefits by using recyclable
(instead of virgin) materials, or by
ensuring that their products can be
recovered and recycled at high rates. A
number of factors contribute to these
inconsistent signals from the
marketplace; they include a set of
market flaws and policies that, in
effect, fail to hold companies and
consumers accountable for the
financial and social costs of packaging
and products once they have been
discarded as waste.
  Two primary factors lead to these
distortions. First, the current price
system fails to internalize waste
management costs in a product's price,
thus passing the costs to society as a
whole. Second, public finance
practices consistently undervalue the
price of waste disposal, limiting the
ability of recycling programs to realize
the full savings associated with
diverting waste from disposal.
  One approach currently being
explored by a number of state
legislatures to internalize solid waste
management costs is to attach
advanced disposal fees to  packages
and products based on their impact on
the environment and on the cost of
managing them after they have been
discarded. Volume-based garbage
collection fees and virgin material fees
are two other methods being suggested.
The former attempts to charge
individuals on the basis of the amount
of garbage they set out for collection.
By making individuals directly
responsible for the amount of garbage
they generate, these fees encourage
recycling and source reduction.
Conversely, the latter is a fee imposed
on all materials at the level of primary
processing.
  Under one approach being
considered, the fee would  be paid
directly by the processor on the basis
of tons of virgin materials used as a
percentage of finished products
shipped. Products imported into the
United States would be charged a
similar fee at the point of introduction
into the economy. Monies generated
from the fee could be reallocated to
states for their use in developing
solid-waste-management infrastructure,
including recycling facilities.
  Addressing the second market
distortion, the underpricing of waste
disposal, will necessitate a similar
reflection of costs in public finance
decisions. One possible way of
adjusting  disposal charges to more
accurately reflect their true costs to
society is  to levy a tipping fee
surcharge on the amount of waste
disposed of at a landfill, transfer
station, mass burn incinerator (where
undifferentiated, unprocessed garbage
is burned), or other waste management
facility. This fee could be assessed not
only to generate revenue for operating
recycling and source reduction
programs, but  also to increase the cost
of least preferred methods of waste
management, thereby encouraging the
use of preferred methods.
  Some forces that are creating
bottlenecks in the recycling loop
cannot be easily controlled using
traditional policy tools.  Influencing the
international marketplace and altering
the regional industrial makeup  of this
country are, for the most part,
unrealistic options. But  recycling can
succeed on the grand scale envisioned
by many if the two market distortions
addressed above are corrected. The
playing field on which recyclable
materials vie for market share with
virgin materials  must be leveled.
Recycling must be allowed to compete
on equal footing with other solid waste
management options. Only then will
recycling reach its full potential.  D
JULY/AUGUST 1992
                                                                                                                 33

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     Recyclables  Market  Basket


     Fifty-four percent of all
     aluminum containers and
     packaging are recovered
     for recycling. The overall
     recovery rate for
     aluminum is 38.1
     percent. The markets For
     scrap aluminum are
     strong. Almost alt the aluminum collected is used to
     make new cans.

     About 96 percent of
     automotive batteries are
     recovered each year.
     Although these lead-acid
     batteries constitute a
     small  portion of the
     MSW stream, they
     contain metals that may
     be a concern when disposed of in landfills and
     combustors. All three components of automotive
     batteries are recyclable: the lead, the acid, and the
     plastic casing.

     About 22 percent of all
     glass beverage containers
     are recovered. Glass has
     an overall recovery rate
     of 19.9 percent. Glass
     manufacturers typically
     use 30 percent of crushed
     glass (known as "cullet")
     along with  raw materials to make new glass. Cullet also
     can be used as an aggregate in road building.

     Paper has an overall
     recovery  rate of 28.6
     percent. About 48
     percent of corrugated
     boxes, 42.5 percent of
     newspapers, 10.3 percent
     of books, 10.7  percent of
     magazines, and 26.5
     percent of office papers are currently recovered for
     recycling. At times, market supply for some recovered
     paper products, such as newsprint, has exceeded  the
     capacity of mills to use the materials. Markets for
     recycled paper products, however, are generally stable
     and expanding as more mills build new deinking
     facilities  to process waste paper and as the demand for
     recycled paper products grows. Significant new capacity
     will be on line by 1994. Paper is recycled into paper
     products, paperboard products, and construction
     products.
About 2.2 percent of all
plastics are currently
recovered for recycling.
Plastics' share of the
waste stream is growing
by weight and volume.
Most plastics that end up
in the waste stream are
from packaging and containers. Plastics recycling has
increased dramatically over the past two years. Products
made from recycled plastic include drainage pipes, toys,
carpet, filler for pillows and sleeping bags, and cassette
casings.

Annually, 11.6 percent of
scrap tires are recovered.
Scrap used tires are
difficult to dispose of in
landfills and waste
combustors. An
estimated 2  billion to  3
billion are currently
stockpiled. These stockpiles can provide convenient
habitats for rodents, serve  as breeding grounds for
mosquitos, and pose fire hazards. Of the scrap tires that
are used, most are burned  for energy. Scrap tires also are
used for rubberized asphalt paving, molded rubber
products, and athletic surfaces.

Sixty-seven  percent of all
used oil is recovered (900
million gallons). Only 10
percent of the amount
generated by people who
change their own motor
oil is returned to
collection programs. If
disposed of improperly (i.e., poured down sewage
drains), used oil can contaminate soil, ground water, and
surface water. In some communities, used motor oil is
collected at service stations, corporate or municipal
collection sites, or at the curbside.

Each year, 4.2 percent of
yard trimmings are
composted.  Yard
trimmings can be
transformed  into compost
for homeowners, farmers,
public agencies,
landscapers, and
nurseries. Grass clippings  can be beneficial when left on
the lawn.
     Source: U.S. fc'PA's Characterization of Municipal Solid
     Waste in the United States: 1992 Update.  Office of Solid
     Waste and Emergency Response. Data are from 1990.
34
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A  "Cradle  to  Cradle"  Debate
in  Congress
Recycling is high on the agenda
by Julie C. Becker
     fhen the Resource Conservation
      and Recovery Act (RCRA) was
first enacted in 1976, it was hailed as a
"cradle to grave" program—a means of
controlling wastes from generation to
disposal. The Act prohibited
indiscriminate dumping of hazardous
wastes and directed EPA to regulate
their generation, transportation, and
disposal. Eight years later, recognizing
that there were gaps in this "cradle to
grave" scheme, Congress  returned to
the drawing board. The Hazardous and
Solid Waste Amendments of 1984
added new programs to the RCRA
agenda: underground storage tanks,
"corrective action" to clean up
RCRA-regulated facilities, tighter
control of small quantity  generators,
and a ban on land disposal of certain
wastes, to name a few.
  Now RCRA is due to be
reauthorized, giving Congress yet
another bite at the apple. This time
recycling is high on the agenda, as
(Becker is a principal at Dickstein,
Shapiro &• Morin in Washington, DC,
where her practice includes
representation of clients dealing with
RCRA issues. She previously served in
EPA's Office of Enforcement,
specializing in Superfund and RCRA
matters.)
Congress strives to shift the focus of
RCRA from disposal to recycling and
waste reduction. On the floor of the
House and Senate, recycling has been
discussed over 600 times since the
beginning of 1991. The issues are
simple, yet challenging.

Making Space In Local Landfills
Currently, only 17 percent of
municipal solid waste is recovered for
recycling. Most of the remaining waste
is sent to landfills. However, landfills
in many communities are closing
down because they cannot meet
federal or state environmental
standards. In most cases this means
sending wastes to a larger regional
landfill at another location, often in
the face of opposition from the
receiving community (recall the
"garbage barge" fiasco and the more
recent story of the "poo-poo
choo-choo"). In turn, sanitation costs
rise as local governments strive to pay
for shipping municipal wastes to
regional disposal facilities.
  One proposal aimed at preserving
landfill space and reducing sanitation
fees is a nationwide "bottle bill"
requiring bottlers to establish
deposit-refund systems for bottles and
cans, which make up about 4 percent
of household waste. The plan would
be similar to  the deposit-refund
programs now in effect in New
Hampshire, Vermont, and eight other
states. Also up for discussion is a bill
that would put states, rather than
bottlers, in charge: Each state would be
required to assure, through any means
it selected, that a set percentage of its
beverage containers were recycled.
States failing to meet the recycling goal
would then be required to impose a
10-cents-per-bottle deposit.
  Bottle bill proponents,  including the
National Association of Counties and
the National League of Cities, argue
that a bottle bill would substantially
reduce the cost of waste management
to municipalities. Opponents, led by
the bottling industry, claim that a
national bottle bill would harm local
curbside recycling programs  while
addressing only a small fraction of the
problem.

Creating Markets
It doesn't do any good to collect
newspapers, glass, plastic, and
aluminum for recycling unless
someone is willing to purchase these
materials.  Today's lack of demand for
recycled products is clearly a problem.
  In Congressional hearings,  recycling
industry representatives have warned
that the market for recycled products
will hit a "brick wall" unless demand
improves and prices rise.  They have
JULY/AUGUST 1992
                                                                                                          35

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                       Pi!
urged Congress to "close the loop" by
taking action to boost the market for
these products. Proposals include:
• Requiring the manufacturers of
paper, glass,  plastic, and aluminum to
replace a portion of the virgin
materials they use with recycled
materials. This would shift some of
the burden of recycling from the
municipalities, which claim to have
been saddled with the cost and  burden
of recycling, back "upstream" to the
manufacturing sector.
  One version of this proposal that is
popular among packaging
manufacturers is to allow companies
several options to what  is  traditionally
considered recycling. For instance,
rather than setting up a recycling
program, the  manufacturer could make
reusable or refillable containers or
redesign its containers to reduce their
volume and weight.
  Another approach supported by
packaging manufacturers is to create  a
system of marketable recycling and
waste reduction "credits." Under the
"credit" scheme, a company that does
more than is  required by law would
receive marketable recycling "credits."
Companies that do not meet federal
recycling and waste minimization
standards would be required to
purchase enough "credits"  from their
competitors to make up the difference.
• Changing federal procurement
standards. With 7,000 buildings under
its jurisdiction, the General Services
Administration (CSA) is one of the
country's largest paper consumers.
However, current federal government
specifications favor the use of virgin
materials. Proposed RCRA
amendments  would direct EPA to
work with other federal agencies,
including the GSA, to draft new
purchasing standards which favor the
purchase of recycled paper and  other
office products, as well as plastics and
rubber products (including asphalt
pavement containing rubber derived
from waste tires). These new standards
would assure that the federal
Many federal proposals are aimed at conserving room in landfills.
Scarce landfill space has left some communities no option but to
transport their wastes to other regions—often incurring steep
transport costs and the ire of people in the receiving communities.
government becomes a major consumer
of recycled goods.
•  Establishing a national recycling
clearinghouse to provide information
on recycling technologies and
regulations. The clearinghouse would
also maintain a database designed to
match those who generate recycled
materials with manufacturers who can
use the materials.
  Already, private  industry throughout
the United States and Canada has
established regional networks for
exchanging industrial wastes such as
scrap  metals and spent solvents. These
"waste exchanges" could serve as a
model for EPA in designing a national
waste exchange network which would
include municipal  waste.
"Green" Advertising
A trip to the grocery store shows why
advertising has become a hot issue in
the RCRA debate. The labels may
claim that the plastic,  cardboard, or
other packaging on the products we
buy,  as well as the products
themselves, are "recyclable,"
"environmentally friendly," "ozone
safe," or "biodegradable." However,
until recently, there were no federal
guidelines for this type of labeling,
making it difficult to tell whether
products lived up to their marketing
claims.
  One result of the RCRA  debate has
been to focus national attention on the
need to regulate environmental
advertising. In late July 1992, the
36
                                                                                                      EPA JOURNAL

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Federal Trade Commission, with the
help of EPA, announced new
guidelines to prevent the use of
misleading environmental marketing
claims. These new guidelines define a
number of "green"
terms—"recyclable," "refillable,"
"biodegradable," etc.—and are
intended to discourage companies
from using these terms in a misleading
or deceptive way (see box on page 10).

Sham  Recycling
Although recycling is on the upswing,
recyclers claim that even more
recovery of recyclable materials would
take place if the regulations governing
these activities were simplified. One of
the trickiest issues facing Congress is
how to encourage valid recycling
efforts while preventing "sham"
recyclers from polluting the soil and
ground water. This is no small
concern. In the past, many companies
which called themselves "recyclers"
indiscriminately dumped the wastes
they collected—and then went  out of
business,  leaving behind scores of
severely contaminated sites.
  One proposal for keeping an  eye on
recyclers (while reducing the
regulatory burden) is  to develop a
tiered  permit program. Construction
and operating standards, reporting
requirements, and government
inspections would be based on  the
types of materials being recycled and
the risk of environmental damage if
these materials are managed
incorrectly.

Batteries, Tires, Oil, and Appliances
Some specific waste disposal problems
are serious enough to merit special
consideration on Capitol Hill. This
year, "top billing" has gone to four
types of wastes generated in virtually
every household: lead-acid batteries,
used tires, used oil, and old
appliances.
  Indeed, these four wastes alone have
the potential to do substantial damage
to our surroundings. Many of the 70
million used lead-acid batteries
disposed of each year contaminate
ground water.  Most of the 250 million
scrap tires generated each year end up
in local tire piles, where they become
fire hazards, threats to the air and
ground water,  and vectors for the
spread of disease. Forty percent of the
one billion gallons of used oil
generated each year goes  into landfills,
sewers, and storm drains,  threatening
water supplies: A single quart of used
oil can contaminate 250,000 gallons of
drinking  water. Used appliances leak
ozone-depleting refrigerants  into the
atmosphere and fill up valuable
landfill space.
  Recognizing that municipal
governments are often ill-equipped to
deal with these wastes. Congress has
considered several ways of shifting
responsibility. One idea, for  instance,
is to require businesses to establish
"take-it-back"  programs to assure that
these products do not end up in
landfills or incinerators. Recycling may
also be encouraged by an outright ban
on the incineration or land disposal of
tires and lead-acid batteries, and by
developing a less burdensome
regulatory program than currently
exists for the recyclers of used oil.
  Whether or not RCRA is amended  in
1992, the trend is clear: Congress will
eventually pass a bill that includes a
comprehensive federal program to
encourage recycling, sets standards for
"green" advertising, and protects
against "sham" recyclers. We will all
be encouraged to recycle problematic
household wastes such as used oil and
tires, spent batteries, and old
appliances. Municipal governments,
states, recyclers, the packaging and
bottling industries, and others will be
watching closely to see who bears the
cost and responsibility for making all
of this happen.
  Even after it is finally reauthorized,
the new RCRA bill will take years to
implement. Nevertheless, when RCRA
becomes a "cradle-to-cradle" law, with
programs for the reuse of waste
materials,  our chances for successful
and  long-term recycling will be much
improved. Q
                                                                                    Cartoon by Schwadron, Reprinted ivfl/i permission.
JULY/AUGUST 1992
                                                                                                                 37

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Con
IIIIIU  I UN  Ul

Urgent   Responses
by  the  States
                              by Eugene J. Wingerter
Legislatures try demand-oriented initiatives
     ver the past few years, states have
     legislated recycling goals as high
as 50 percent of their waste stream.
The clock is ticking toward those
statutory deadlines, and most states
aren't even close. The question is, How
do we get there from here?
  As discussed elsewhere in  this issue
of EPA Journal, recycling does not
happen—the loop is not closed—until
collected material is processed,
manufactured into a new product, and
sold. Without this sequence of steps,
recyclables can sit in warehouses or
find their way to landfills. Mandatory
curbside  collection programs  across
the United States have flooded the
newspaper market. Many communities
have had to pay to have the material
taken away. The nation also faces gluts
of green glass,  plastics, and office
paper.
  Many state and municipal recycling
authorities are searching for the same
thing: markets  for the recyclable
material they are collecting. Small
wonder that state legislatures are now
stressing  market development in their
recycling laws.
  State laws to help develop  markets
take several approaches:

• Minimum levels of recycled content
in newsprint and other products
(Wingerter is the Executive
Director/CEO of the National Solid
Wastes Management Association. The
associalion, with over 2,500 members,
serves the private-sector waste
management industry in North
America.]

38
                                • Requirements that the state buy
                                recycled products, even if they are
                                more expensive than comparable
                                products of virgin material
                                • Tax credits/incentives and grants
                                • Recycling market development
                                boards or offices.

                                  In 1991, seven states passed
                                minimum content legislation. North
                                Carolina, Oregon, Rhode Island, and
                                Texas passed laws requiring
                                post-consumer content in newsprint at
                                levels ranging from 7.5 to 40 percent;
                                West Virginia required "the highest
                                practicable content." The  year before,
                                seven states had passed recycled
                                content laws for newsprint. In
                                addition, Maryland and Oregon  passed
                                minimum recycled content
                                requirements for telephone directories
                                in 1991.
                                  Oregon imposed a  minimum content
                                requirement on glass containers;
                                California, on fiberglass insulation.
                                Both states set recycled content
                                requirements on rigid plastic as  one of
                                four options available to plastics
                                packagers to achieve waste reduction
                                goals.
                                  While Oregon's law encourages the
                                use of recycled plastic, it  also
                                recognizes that sometimes recycling is
                                just  not economically feasible. The law
                                requires that, by 1995, all rigid plastic
                                packaging must either be  reusable five
                                times, 10-percent source reduced,
                                recycled at a 25-percent rate, or
                                contain 25 percent post-consumer
                                content. Some of these options could
                                develop recycling markets. However,
                                the law also says that counties have to
                                pick up plastic only if markets are
                                "stable" and are paying at least 75
                                percent of collection costs. In other
                                words, the statute recognizes that
supply could outstrip demand, and,
with no takers, there's no point in
spending money to collect the
material. Also, Oregon is paying
attention to collection, processing, and
transportation costs, stipulating that
recyclers should not be forced to
collect something that is not
cost-effective.
  This feasibility threshold is
important, because today's sorely
stretched state and municipal budgets
cannot afford a hemorrhage from
recycling losses.
  Another way to develop a market is
to become a customer. States are
legislating themselves into becoming
larger purchasers of recycled-content
goods. Every state now has legislation
encouraging state agencies to buy
paper with recycled content.
Twenty-seven states apply a price
preference to paper with secondary
content; the preference usually
amounts to 5 to 10 percent more than
the  price of competing virgin paper.
Fourteen states require "set-asides": In
other words, a certain percentage of
their paper purchases must be  paper
with recycled content. One of the most
ambitious laws is a new Arkansas
statute setting a 60-percent set-aside
for paper by the year 2000. Twelve
states have both price preferences and
set-asides. Scores of city and county
governments have set their own "buy
recycled" policies as well.
  In addition to paper, states are
increasingly looking at procurement
requirements for other products. For
example, California extends price
preferences to compost, glass, oil,
solvent, paint, tires, and glass
products. Maine requires compost to
be used  on all public land
maintenance and landfill closure
projects that use  state funds. Several
states are using—or studying the use
of—recycled materials in road
maintenance: crushed glass to make
"glasphalt" or scrap tires to make
rubberized asphalt.
  Other state aids to recycling  include
tax credits and grants to support the
use  of recycled materials. In  1991,
seven states—Arkansas, Colorado,

                        EPA JOURNAL

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                                             ; | D
 Washington County, Mj/ne, composts blueberry ivaMe, horse bedding,
 wood ash. Maine requires that compost be used for all public land
 maintenance.
 Illinois, Louisiana, Montana, New
 Mexico, and Oklahoma—passed laws
 allowing tax credits for the use of
 post-consumer materials in
 manufacturing. In addition, Montana's
 law allows an additional tax deduction
 of up to 5 percent from taxable income
 for the purchase of recycled material
 that is a business-related expense. A
 total of 21 states now offer tax
 incentives for recycling.
  Also, some state recycling grants can
 be applied to the demand side of the
 equation. In at least 17  states, grants
 may be used to invest in the
 manufacture of recycled products.
 Arkansas, California, Illinois,
 Michigan, Missouri, Nebraska, and
 Oregon offer grants that can be used
 for market development.
  To supply more direct assistance,
 Arkansas, Illinois, Mississippi, Oregon,
 South Carolina, Tennessee,
 Washington, and  West Virginia passed
 laws last year creating advisory
 councils to aid in  market development.
 The scope of the mandates varies
 widely. West Virginia's council deals
 only with recycled newsprint;
 Washington's targets mixed paper,
glass, tires, compost, and plastics. The
Clean Washington Center represents a
legislative upgrading of the previously
created Washington Committee for
Recycling Markets. Its activities
include funding demonstration
projects and providing technical
assistance and feasibility studies.
  Market development initiatives can
come from state governors as well as
from legislatures. For example, Florida
Governor Lawton Chiles recently
created a recycling plan with a unique
closed-loop marketing strategy. Under
this plan, the state would buy certain
products only from designated
recycling business ventures. These
groups, comprising haulers,  processors,
and manufacturers of recycled goods,
would bid competitively both to
remove specific  recyclables from state
institutions and  to sell  the recycled
products back to the state.
  States are also demonstrating how
cooperative purchases can increase
their recycled buying power.  Banding
together to boost demand for  recycled
paper, the Council of Great Lakes
Governors,  through its Great Lakes
Recycling program, will acquire 30
million pounds of recycled copy paper
at an estimated cost of $13 million.
According to a spokesman for the
council, the program, which was
announced this summer, "shows
business that government can  be a
serious consumer." At the same time,
the scale of this cooperative effort will
realize significant savings for the
individual states: Indiana, Minnesota,
Pennsylvania, New York, Illinois,
Michigan, Wisconsin, Ohio, and South
Dakota.
   Finally, new and substantial
recycling markets are likely to develop
as new uses for recyclables are
sanctioned by standards-setting
industry groups. This year, at the
urging of the New Jersey Department
of Environmental Protection (DEP), the
National Association of
Plumbing-Heating-Cooling Contractors
changed its widely  used National
Standard Plumbing Code to permit the
use of 3/4-inch crushed glass as fill in
laying French drains around perimeter
walls of buildings. (Mixed-color
crushed glass is otherwise of no value
and  has to be landfilled in many
cases.) Because scores of federal
agencies, states, and localities  use this
code or model their own codes on it,
the change could  soon have a
widespread effect.
   According to a  spokesman for the
New Jersey DEP, the code change will
create an important market for the
45,000 tons of crushed mixed-color
glass generated in the state each year.
Other changes in  construction  codes
could further expand the use of
crushed glass as an  aggregate fill
around subsoil culverts, pipes, and
drains.
  These demand-oriented initiatives
are just in their early stages; it's too
soon to see results.  As state and
municipal officials gain more
experience with recycling, the
economic and feasibility challenges
become clearer. Market demand and
cost effectiveness  are major
requirements. State  laws and executive
programs keyed to these concerns will
help recycling succeed, n
JULY/AUGUST 1992
                                                                         39

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From  Lumber  to  Lampshades
Young businesses put recyclables
to new uses
by Kathrin Day Lassila
    he Daily Planet, a mail-order
    catalog company targeting the
young and progressive, used to sell
papier-mache bracelets sculpted from
wastepaper and earrings made out of
fishing line collected on the beach.
Unfortunately, the bracelets tended to
lumpiness and the earrings looked like
nothing so much as coils of fishing
line, and the overall effect was more
environmental than ornamental. "We
haven't sold them for two years now,"
says the company's manager.
  Wastepaper bracelets and
fishing-line earrings epitomize a
concern felt by some seasoned
recycling advocates: Americans will
judge the potential of recycling by a
few creative but economically
insignificant products, dismiss the
entire concept as a fad, and continue
burying and burning valuable materials
as if there were no tomorrow.
  "The key to ending the solid waste
glut isn't innovation," says Allen
Hershkowitz, a senior scientist at the
Natural Resources Defense Council.
"It's mainstreaming. What we need are
federal standards for post-consumer
content in high-volume products like
paper and packaging."
  But if innovation is only a
supporting player on the  national
recycling stage,  it plays a starring role
in dozens, or perhaps hundreds, of
small-scale operations springing up all
(Lassila is Director of Publications at
the Natural Resources Defense Council
(NHDC). This article represents her
own views and not necessarily those of
the NHDC.J
over the country. These young
businesses—which run the gamut from
light industry to cottage industry—are
putting recyclables to new and
sometimes unusual uses. An Oregon
woman founded Deja Inc., to
manufacture Deja Shoes from used
textiles, rubber products, and other
post-consumer waste. Turtle Plastics in
Cleveland, Ohio, turns used swimming
pool liners and scrap automobile trim
into industrial floor matting and urinal
screens. Earth Partners, based in
Oregon, plans to make newsprint into
floor paneling material and molded
panels for hollow-core doors.
  None of these entrepreneurs, or their
fellow venturers around the United
States, is likely to take issue with the
need for mainstreaming. But they are
seeing concrete local benefits from the
innovative use of recyclables: small
but tangible quantities of material kept
out of landfills; new  economic niches
that create jobs in their communities.
  One organization, Bronx 2000 of
New York City, has turned to recycling
and recyclables specifically as a means
of furthering its community
development mission. The 12-year-old
      Will they sell? Eco Sneaks, made by
   Deja, Inc., are made from used textiles,
             rubber products, and other
                 post-consumer waste.
                         Oejcj. Inc. photo.

nonprofit group has set up 10
recycling companies around the
country, and is now launching a new
venture to recycle wooden pallets and
skids used to stack shipped goods for
storage and transportation. According
to president David Muchnick, half the
hardwood used in the United States
(including a generous proportion of
oak) goes into pallets, and half of these
in turn are destined for one-way trips
that generally end in a landfill or
incinerator.
  Bronx 2000 will have a prototype
factory on line by early fall  to grade
pallet wood, turn the best grades into
high-quality butcher-block furniture,
and sell the rest back to pallet
manufacturers and to deforested
tropical countries. Within two years,
Muchnick plans to train 100 inner-city
youths, and to spin  off the factory as
an independent commercial venture
and a model to be replicated in other
communities.
  But it is as economic ventures that
recyclable-based businesses are most
vulnerable. Innovation in business
invariably involves  risk, and
entrepreneurs who use recyclables
                                                                                                   EPA JOURNAL

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have more to contend with than most.
To the usual list of startup hurdles
they must add the uncertainties and
flaws still impeding the supply of
recycled materials.
   U-Save Tire Recyclers, for example,
proved to be an environmental idea
whose time had not yet come. U-Save
was established in Massachusetts to
manufacture "Flash," a children's
playground swing in the shape of a
horse. Flash was "very successful as a
product," its founder says, generating
inquiries every week and ultimately
selling about 10,000 copies over the
year and a half of U-Save's life. But
with no uniformity or standards
governing the quality of the raw
material, Flash's production was
impossible to automate and too
labor-intensive to yield a workable
profit margin.
   Chicago Art Glass and  Jewels, Inc.,
in Plymouth, Wisconsin, is dealing
with problems in its own
post-consumer supply by developing a
new product tailored to the material.
The company currently sells over 600
products, from faceted glass "jewels"
used in stained-glass windows to vases
and lily-shaped lampshades. Although
it reuses all its own industrial scrap
and uses post-consumer bottle glass in
several items, most of its products are
too delicate to tolerate a sizable
proportion of the  lower-quality
post-consumer glass. However, owners
Debra and Ray Selk recently developed
a glass tile that can incorporate  a much
higher post-consumer percentage.
         Theirs was the only glass exhibit out
         of 500 entries in a major international
         tile show this summer, and the interest
         it received has encouraged the Selks to
         move ahead with a second line in glass
         tile that will likely expand their
         workforce from 12 to 18. "Everybody
         in business knows there's always a
         problem with post-consumer waste,"
         says Ray, "and if you're working in
         that direction, you'd better make some
         commitments to be innovative."
           Both Bronx 2000 and Chicago Art
         Glass have put substantial energies
         into careful product development.
         Sometimes, a handy supply of
         recyclables can lure a company into
         skipping this step. Mary Kohrell, who
         helps put  recyclers in touch with
         potential buyers through the
         Wisconsin Cooperative Extension
         Service, has seen it happen several
         times. "For a couple of months last
         year," she says, "I was getting a call
         once a week from some company
         saying, 'I want to make plastic lumber
         because I know I can get a supply.'
         They were putting their marketing
         principles backwards. Success depends
         on planning."
           One company that Kohrell believes
         has done its planning homework well
         enough to succeed with plastic lumber
         is the three-year-old Recycled Plastics
         Industries in Green Bay, Wisconsin. Its
         president, Lee Anderson, states the
         company's guiding principle this way:
         "The trick is to not let the variables
         control the show. You have to control
         the variables to the best of your
                    ability." There are several dozen
                    plastic lumber facilities in the country
                    that use a random mix of plastics in
                    their product, but Recycled  Plastics is
                    one of a handful that restrict their raw
                    materials to the high-density
                    polyethylene used in milk jugs, bleach
                    bottles, soap bottles, and similar
                    containers. The result, Anderson
                    claims, is a more homogeneous,
                    high-performance product, tougher
                    than wood and bacteria-resistant. The
                    result of a more dependable product is
                    a more dependable demand. Recycled
                    Plastics is still a small operation, but it
                    sells to food warehouses, paper mills,
                    park and recreation departments, and
                    manufacturers of reusable pallets, and
                    demand is growing constantly.
                      If these companies are any
                    indication, entrepreneurs in
                    recyclables have healthy ambitions.
                    Chicago Art Glass has doubled its sales
                    every year over its three-year life.
                    Recycled Plastics Industries recently
                    turned down a bid to produce a
                    million pallets a month for 36 months,
                    simply because it could not yet handle
                    the volume. Earth Partners aims
                    eventually to have 50 plants, each
                    handling 100 tons of newsprint a day.
                      Clearly, these fledgling
                    entrepreneurs don't divert a large part
                    of the waste stream. But perhaps the
                    trick may be to last long enough and
                    do well enough to graduate  from
                    "innovative" to "mainstream." After
                    all, even  the horseless carriage and the
                    electric candle were innovations in
                    their day. Q
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JULY/AUGUST 1992
                                                                                  41

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Is (he nation on the right track in its
approach to recycling? EPA Journal
posed this question to two observers
who have been actively involved  in
municipal solid waste issues. The
question is wide open to controversy,
as their commentaries, printed below,
indicate:
Lynn Scarlett
(Scarlett is Vice President of
Research for the Reason Foundation, a
nonprofit public-policy think tank in
Los Angeles, California.)
    o doubt about it, Americans throw
    out a lot of stuff—about 4.3
pounds per person each day of what
we call municipal solid waste.
  Five years ago, watching the
peripatetic garbage barge from Islip,
New York, search in vain for a
destination—a place to offload its
dubious cargo—Americans abruptly
began worrying about trash. Would we
soon be buried in waste? And how
could we stem the tide?
  Recycling, long practiced to a
modest extent, loomed large as an
answer—a way of turning trash into
treasure, diverting discards  away from
disposal facilities, and averting a
crisis. By 1992, at least 38 states  had
established recycling goals or
mandates. Local governments had set
up over 4,000 curbside recycling
programs. And recycling collection
programs were diverting some 17
percent of the municipal waste stream,
up from barely 10 percent just a few
years earlier.
  A success story? Partly. Can we
reach even higher levels of recycling?
Probably. But are we on the  right
track? Will mandated recycling and
prescriptive packaging regulations
designed to "create  markets" for
recyclables serve us well? Specifically,
will the current legislative push to
enshrine recycling as the preferred
approach (apart from source reduction)
to handling discards improve our
environment? Will it save resources or
improve waste management? And at
what cost?
  Some recycling makes sense. And in
some locations—those close to
recyclable markets,  or where disposal
costs are high—a lot of recycling
makes sense.
  Take aluminum cans. Making new
cans from recycled aluminum takes 95
percent less energy than fashioning
aluminum out of bauxite. And the cans
are light, easily crushed, and, thus,
easily transported—even long
distances—to smelters. In short, the
collection and transportation process
consumes fewer resources than are
saved in energy and raw materials
consumption at the smelter. This
means aluminum recycling makes
economic (and, not incidentally)
environmental  sense.
  The same can be said of some glass,
plastic, wastepaper, and other  metal
recycling. But the critical word is
"some." Whether such efforts make
sense depends, critically, on location
and on comparative costs of available
alternatives for waste  disposal.
  As with aluminum, it generally takes
less energy to make glass or newsprint
using recycled  materials than using
virgin materials. But for glass and
newsprint these energy savings are
more modest—sometimes so modest
that collecting and transporting the
recycled material actually consumes
more energy than can be conserved in
the manufacturing process. And, in the
case of paper, recycling can involve
shifts away from renewable (wood
residue) fuel to fossil  fuels, with
important cost  implications.
  One European study of wastepaper
recycling, looking at total energy
consumption under three
scenarios—maximum  recycling,
selective recycling, and zero recycling
with wastepaper
incineration—concluded that overall
fuel inputs were actually greater in the
maximum recycling case than in the
zero recycling case.
  Mandated by law, recycling becomes
an end in  itself. It should, however, be
viewed as a means to  a broader
end—the efficient use of resources,
including labor, energy, capital, and
raw materials. Sometimes—with some
materials and in some
locations—recycling achieves this end;
other times not.
  One-size-fits-all legislation ignores
this caution. And mandatory use of
recyclables—an effort  to artificially
"create markets"—limits the ability of
42
                                                                                                      EPA JOURNAL

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manufacturers to respond flexibly to
particular costs and constraints.
Ignoring these constraints, through
prescriptive packaging regulations,
results in  unintended consequences.
And that can mean higher costs to
consumers and greater resource
consumption.
  The devil, as the saying goes, is in
the details. Consider a few examples.
Increasing recycled content in
paperboard from 10 or 15 percent to
over 30 percent will  reduce the
container's strength.  Achieving similar
strength requires additional inputs of
total fiber. In fact,  the container with
less recycled content uses 20 percent
less total fiber than a comparable
container  with high recycled  fiber
content. The same tradeoff occurs with
plastic bags: More  recycled plastic
content means less bag strength,  thus
requiring  a thicker bag to achieve
similar  strength  characteristics.
  But resource conservation in
manufacturing processes is not the
only justification for recycling. Indeed,
much recent recycling was pursued,
primarily, to conserve landfill space,
reduce waste management costs, and
avoid the  perceived harms associated
with landfilling  and  incineration.
  Here the case for mandating
recycling  has been overstated—and
waste management needs have been
misperceived. The United States is not
"running out of landfill space."
Though the total number of municipal
landfills has declined from over 18,000
to less than 6,000,  two points are
worth noting.
  First,  new landfills are on average
four times larger than those they are
replacing, so we should expect total
absolute numbers of  landfills to
decline. Second, Gonzaga University
economist Clark Wiseman has
calculated that all  of the municipal
waste produced  in the United States
over the next 1,000 years could fit into
a space  covering less than 0.1  percent
of the continental United States.  No,
we wouldn't site such a mega-landfill.
But Wiseman's calculation puts into
perspective the fear that we will soon
be overrun by landfills.
  Moreover, notwithstanding cost
increases in the 1980s for most U.S.
regions, traditional waste collection
and landfilling remains less costly
than recycling—even taking into
account avoided landfill costs. Though
recycling costs vary by program
design, most local programs cost
between $100 and $200 per ton of
materials collected.  By contrast, total
Mandated by law, recycling
becomes  an end in itself.
traditional disposal costs—including
collection and landfill costs—fall
somewhere between $60 and $100 per
ton of disposed material. In a few
areas, especially in the Northeast, costs
are considerably higher. There,
recycling can reduce total  waste
management costs. But for most U.S.
cities and counties, mandated
recycling means higher costs. And
higher costs are a signal that we may
be consuming more, not fewer,  total
resources to accomplish our ends.
  Public sentiment, which cannot and
should not be ignored,  does  deter the
siting of some landfills (and
incinerators). Often, however, this
opposition results from misperceptions
about the health and environmental
problems associated with these
facilities. Old-fashioned dumps  and
belching incinerators did pose
potential hazards. Some municipal
landfills, in fact, are now Superfund
sites. But modem,  state-of-the-art
facilities—both landfills and
incinerators—pose small, even
insignificant,  harm to public health,
according to EPA's own risk
assessments.
  Simply mandating recycling does
little to  educate the general public
about waste management options and
comparative costs. Indeed,  such
mandates often perpetuate
misconceptions and further undermine
efforts to site needed waste
management facilities.  Much  of the
public now assumes, for example, that
most of the municipal  waste stream
can be recycled—at a savings to local
governments. Yet garbologist  William
Rathje and U.S. Chamber of Commerce
researcher Harvey Alter estimate, by
contrast, that even vigorous recycling
efforts are unlikely to divert more than
20 to 35 percent of the waste  stream.
Household recycling now typically
diverts  less than 7 percent  of  the waste
stream. And at least some of this
recycling may bring us few, if any, real
environmental benefits.
  We need to recast the discussion
about solid waste management. Yes,
recycling has a role to  play. But such
efforts need to be market-driven.
  This does not imply  a do-nothing
policy.  Many local governments still
fail to charge households directly for
waste management service. Consumers,
therefore, have little incentive to
reduce the amount of waste they
generate—by recycling, composting, or
altering purchasing habits.  We need to
introduce user fees. And we need to
ensure that waste disposal  fees fully
reflect total costs of operating such
systems. E. S. Savas at  State
University, New York,  notes that many
local governments understate  waste
management costs by 25 to  30
percent—in effect, subsidizing such
programs.
  Introducing these two
measures—user fees and
business-based accounting
practices—would  give consumers and
local decision  makers the necessary
information with which to  decide how
to handle their discards. This, not
mandates, will result in sustainable
recycling and integrated waste
management systems that meet local
needs,  Q
JULY/AUGUST 1992
                                                                                                                43

-------
A
                     (Continued)
Peter L, Grogan
 (Grogcm is a partner in the national
 consulting engineering firm of R.W.
 Beck and Associates, and the
 president of the National Recycling
 Coalition (NRC). The views expressed
 in this commentary are those of the
 author and do not represent the
 positions of the NRC, the Recycling
 Advisory Council, or R.W. Beck and
 Associates.)
                                           The United States does not have a
                                           comprehensive solid waste
                                       recycling strategy. Since the action on
                                       waste reduction has  been at the state
                                       and local levels, it would be more
                                       accurate to ask if we are on the right
                                       track in our approaches (plural).
                                         The 42 states that  have recycling
                                       laws each have a different approach,
                                       but most involve target waste
                                       reduction goals that  will be met
                                       primarily, by source  reduction,
                                       recycling, and composting.
                                         We can analyze those recycling
                                       approaches  in general terms by looking
                                       at their three common components: the
                                       collection of recyclable materials, the
                                       processing of recyclable materials, and
                                       the marketing of recyclable
                                       commodities.
                                         Are our collections approaches on
                                       the right track? Some of the evidence
                                       is optimistic. More than 4,000 local
                                       governments now provide residential
                                       collection of recyclable materials, and
                                       that number grows by nearly 1,000
                                       each year. That means we are
                                       providing waste recycling collection
                                       services to about a quarter of the
                                       population. This is a good start, but we
                                       have generally under-invested in
                                       recyclables  collection programs and
                                       over-invested in collection designed
                                       for disposal.
                                          Other elements of our collections
                                       approaches are definitely on track. For
                                       example, many of the trial-and-error
                                       practices of the recycling collection
                                       systems of the 1980s will be replaced
                                       in the 1990s with surer methods. The
                                       emergence of cost-based rates, which
                                       work much like utilities' charges  for
                                       water and electrical  services, is a good
                                       trend. Charges for solid waste services
                                       are thus correlated to the volume
                                       generated.
                                          Seattle and Portland are two of the
                                       first large cities to experiment with
                                       variable-rate systems at the residential
                                       level,  with notable success. In these
                                       cities the more waste you generate, the
                                       more you pay. The outcome, especially
                                       in Seattle, has been  reduced waste
                                       generation,  increased recycling and
                                       composting, and resultant financial
                                       savings for the ratepayer.
                                          Another positive direction for
residential collections involves the
demise of the single-collection
vehicles, which some cities now use to
provide services for trash, recyclable
materials, and organics. The next
generation of collection systems—often
referred to as "2-sort" or "4-sort"
programs—will radically change waste
collection and processing beginning in
the mid-1990s.
  As the standard trash-compactor
truck goes the way of the rotary dial
phone, the goal will become to collect
all of the materials, with maximum
waste recovery, in one or two vehicles.
Residential and commercial sectors
will participate in these collection
programs, and rural areas will be
served by a truck that is part
compactor, part recycling truck. These
vehicles are already serving
communities like Telluride, Colorado.
The result: higher waste recovery and
lower collection expense. As this shift
takes place, it will represent the first
step towards appropriate capitalization
of hardware.
  Are we on track to providing the
appropriate infrastructure for
processing recyclable materials? Here,
again, the nation  is off to a good start,
but a lot of work  lies ahead.
  The system of choice for processing
recyclable materials at the local
government level is the material
recovery facility,  or MRF.
Approximately 250 MRFs are now
recovering recyclable materials from
local governmental programs. The
primary role of these facilities is to
remove materials from the waste
stream and return them to the stream
of commerce.
  The trend in MRFs represents an
under-invested but appropriate
direction that needs bolstering in two
areas. First, we need to build  a
national MRF infrastructure, just as we
have for other governmental services,
such as  fire protection.
  The second problem area is design.
Most of  today's facilities were
designed to process only residentially
collected recyclable materials. If future
facilities are set up for 2-sort and
4-sort collection programs, they will be
designed to process most of the entire
                                                                                                       EPA JOURNAL

-------
waste stream. Economics will be
improved by the larger mission of
future MRFs through economies of
scale.
  Recycling costs cannot be aptly
compared to the costs of traditional
solid waste collection and disposal
simply by comparing the cost per ton
of each service. A true comparative
analysis must take into account, on the
side of traditional disposal practices,
such factors as hidden tax supports;
economic impacts from environmental
degradation; the costs of proper
landfill closure and post-closure
procedures such as those spelled out
in EPA's 1991 regulations setting the
first comprehensive federal standards
for municipal landfills;  and liability
considerations.
  EPA's 1991 regulations, issued under
the Resource Conservation and
Recovery Act (RCRA), set location,
design, operating, and closure
standards, as well as clean-up
requirements for existing
contamination.  Importantly, the new
regulations also set financial assurance
criteria, requiring owners/operators of
landfills to demonstrate their ability to
finance required monitoring and other
follow-up activities for 30 years
following closure of a landfill.
  Given the realities of  state-of-the-art
landfiiling and  the new federal
requirements governing municipal
landfills, urban areas have a
compelling opportunity to bring down
their total solid waste management
costs with aggressive recycling and
composting. In  fact, some cities have
already accomplished this goal.
  Opponents of recycling claim that
recycling services drive up costs. This
is not necessarily the case. The value
of recyclable commodities will
improve with increased demand
brought about primarily by content
legislation and progressive industry
target recovery goals. Consequently,
when the recession ends, the market
value for commodities will be
improved.
  It comes down to this: All the best
collection and processing strategies in
the world are useless without
comparable success in developing the
end-use markets for recyclable
commodities.
  Are we on track toward creating
viable markets that will support
aggressive waste recovery? This,
unfortunately, is where we are having
the most trouble getting a foothold. For
solid waste recycling to succeed as a
national strategy, a decade of market
development infrastructure work lies
ahead, and we have three major
hurdles to clear.
  First, we have neither a national
strategy nor enough federal
A decade of market
development infrastructure
work lies ahead....
governmental leadership on this issue.
Second, some states, like Washington
and New York, have developed
successful market development
programs, but most have not. And
third, while some industries are
actively stimulating the recovery of
their products,  other industries are not.
  Because of slow progress at the
federal level, the mantle of leadership
falls on state governments. They have
a unique opportunity to include
market development for recyclable
commodities as part of their ongoing
commerce development role.
  State governments do an effective
job of marketing everything from
tourism to produce, and Washington
and New York  have demonstrated that
by making market development for
recyclable commodities a priority, they
can attract major new recycling
industries. These industries offer new
economic development opportunities
and employment opportunities in
addition to end-use markets for local
government's recyclable commodities.
Washington, for example, now has
enough mill capacity for all waste
newspaper generated in the state, and
a brand new recycled content
phone-directory paper mill.
  The  states that effectively staff and
fund recyclable commodity market
activities and aggressively market the
availability of recyclable commodities
to industry will be big winners.
  Private industry can also continue to
expand its leadership role. More than
95 million tons of recyclable
commodities were recovered in 1991,
and almost every community
experienced record recovery. U.S.
paper mills have already spent $42
billion in the past three years
re-tooling to manufacture recycled
content paper. These actions on the
part of major newsprint manufacturers
demonstrated that recycled-content
legislation has worked effectively in
the interest of creating significant new
demand for waste newsprint and
magazines.
  Most of the major commodity groups
with consumer products including
plastic, metals, and glass have set
target recovery goals for this decade.
Those are positive steps in the right
direction, and most of the goals are
likely to be achieved.
  Industry must also dedicate itself to
manufacturing recycled  content
products. At least 11 states now have
recycled-content laws that require the
manufacturers of specific products to
use recycled-content material in their
products. Overall, the commodity
marketing job is progressing on the
right track.
  We are beginning to change
America's behavior from a throwaway
society to a conserving society.
State-mandated recycling goals have
encouraged millions of Americans to
voluntarily participate in solid waste
recycling. More sophisticated
collection systems will improve
recovery and cost efficiency. Giving
future MRFs a larger mission in life
will help us process additional waste
streams.
  If, over the next decade, we can
make enough progress in developing
markets in recyclable  commodities, the
end results of this nation's integrated
solid waste management approaches
that include recycling will be as other
industrialized nations have
demonstrated: enhanced resource
conservation, an improved gross
national product, increased trade
exports, and a reduction in solid waste
and environmental degradation. D
JULY/AUGUST 1992
                                                                                                                45

-------
Source Reduction
In 1987, the vagabond "Islip garbage
barge" became a symbol for d nation
producing too much trct.s/i.
46
                                                   EPA JOURNAL

-------
Slowing  the  Waste  Behemoth
Source reduction is overshadowed by recycling's success
                                     by Bette Fishbein and
                                     David  Saphire
 1 Jjerman Miller, a Michigan-based
 B I furniture manufacturer, saves
more than $1 million each year since
the company changed from single-use
cardboard packaging to reusable
blankets for protecting furniture during
shipping. Pepsi Cola has reduced the
amount of corrugated cardboard it uses
to deliver two-liter bottles to market by
80,000 tons per year since it switched
to reusable plastic shipping crates.
And, each day in New York City,
10,000 pounds of food that restaurants,
corporations, and cafeterias would
otherwise throw away is brought to
homeless shelters, daycare centers, and
other social service facilities by City
Harvest.
  What do  these examples have in
common? They are just a few
illustrations of initiatives to reduce
solid waste "at the source."
  Source reduction, reducing the
amount or toxicity of garbage, tops the
now widely accepted national solid
waste hierarchy, which places
recycling and composting second and
disposal options, such as incineration
or landfilling, last.  Making less  garbage
not only decreases the amount of
waste that must be managed, but also
preserves natural resources and
reduces pollution generated during
manufacturing and disposal. Source
reduction is the most cost effective
solid waste strategy, because garbage
(Fishbein is director of the Municipal
Solid Waste Program at INFORM, Inc.,
and Saphire is a research associate.
Funding for INFORM's source
reduction research has been provided,
in part, by EPA Region 2 and the Risk
Reduction Engineering Laboratory.
INFORM's forthcoming report, Making
Less Garbage: A Planning Guide for
Communities, documents successful
source reduction strategies.)

JULY/AUGUST 1992
that is not produced does not have to
be collected, let alone recycled or sent
to the landfill.
  Four converging trends over the past
several decades have contributed to
the garbage crisis in the United States.
The population has increased; per
capita waste generation has soared; the
waste has become increasingly toxic;
and landfills—the country's primary
means of waste disposal—have been
filling up while, at the same time, new
ones have been increasingly  difficult to
site and construct.
  Recycling has emerged as the
number one solution to the crisis.
Nevertheless, there  is a growing
recognition that recycling is not a
panacea. Major obstacles remain to be
overcome: shortage  of markets, absence
of processing infrastructure, and the
costs of starting and operating a
program.
  With these problems in mind, some
communities are beginning to ask, why
dispose of or recycle something that is
not needed in the first  place? Yet,
despite this recognition, despite source
reduction's position atop the garbage
management hierarchy, currently it
receives the least attention. Thirty-
eight states and the District of
Columbia have recycling goals; only
seven have source reduction goals.
  Why? The answer lies in the nature
of source reduction, itself. There
appears to be a parallel with health
care: As a country, we  find it easier to
treat than to prevent.
  At the local government level,
planners, engineers, and managers are
familiar with the steps involved in the
collection, separation, processing, and
marketing of materials  for recycling.
However, most have only a vague idea
of how to encourage businesses and
citizens to produce  less waste. Many
municipal planners are not aware of
the variety of source reduction
 strategies they could adopt.
  Source reduction also has not yet
 received the widespread media
 attention that recycling has. This may
 be due, in part, to public policy
 debate, which often pits recycling
 against incineration. For the
 individual, source reduction requires
 changes in behavior—what we buy and
 how we operate at work—which are
 more difficult to accomplish than
 simply separating wastes that have
 already been generated.
  Further, there is concern that source
 reduction may be anti-prosperity: If we
 consumed less, we would generate less
 waste.  The challenge is to sustain
 economic growth while still being less
 wasteful. It can be done: other
 industrialized countries enjoy the  same
 standard of living that we do, but they
 generate less waste per capita.

 Business as role model
 Source reduction initiatives can have a
 major impact in the commercial sector,
 which  generates about 40 percent of
 the country's waste. Many companies
 have taken such initiatives as a way to
 improve operating efficiency and cut
 costs, as well as to reduce waste.
  AT&T recognized the potential of
 reducing the use of office paper to save
 money. Nationally, the use of office
 paper has soared from  1.5 million  tons
 in 1960 to 7.3 million tons in 1988,
 making it one of the fastest growing
 segments of the waste stream. AT&T
 set a goal of reducing office paper
 waste 15 percent by 1994 from a 1990
 baseline. A key strategy is promoting
 double-sided copying. The company
 estimates that annual savings, if
 double-sided copying is increased  to
 50 percent, will be 77 million sheets,
which  would reduce paper purchasing
costs by $385,000.
  The Rainier Brewing Company, a
Seattle-based maker of beer, has been
                                                                     47

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buying back and refilling all of its
single-serve bottles since 1990. After
the first year of the program, Rainier
estimated that it had refilled 20
million bottles, saving enough landfill
space Id  fill the Seattle Kingdome—a
60,000-plus seat stadium—three feet
deep and enough energy to serve 1,434
homes for a year.
  For Rainier, buying back its old
bottles and refilling them means a
savings in new bottle costs. Local
recyclers also benefit, since selling
intact Rainier bottles back to the
brewery  pays more than selling cullet
to area glass processors.
  Refilling bottles, a once common
practice:  in this country, has virtually
disappeared. In the early 1960s, 89
percent of all packaged soft drinks,
and nearly 50 percent of all packaged
beer was sold in refillable bottles.
Today, only about 6 percent of
packaged beer and soft drinks,
combined,  is sold  in refillables. In
comparison, German legislation passed
in May 1991, mandates that 72 percent
of beverages must be sold in refillable
containers.
  Nationwide, corrugated cardboard is
the  largest component of the waste
stream, accounting for nearly 13
percent of the total by weight. Ninety
to 95 percent of all U.S. manufactured
goods are shipped in corrugated boxes,
which are typically used only once.
  Many manufacturers and suppliers
have realized the benefits to be reaped
from switching to reusable shipping
containers made from plastic or
corrugated cardboard. A rigid plastic
container may make 250 trips or more
in its lifetime. Besides reducing
wastes, these containers may also cut
operating costs, including packaging,
transportation, warehousing, and waste
disposal.
  Toyota Motor Manufacturing, USA,
Inc., in Georgetown, Kentucky, has
saved $3.6 million per year in the cost
of transporting materials from
suppliers since it adopted a modular
reusable system. Because the
containers are designed to better fill a
standard trailer, Toyota can receive
more parts per delivery. For the
suppliers, switching from one-way to
reusable containers means a long term
savings in packaging costs.

Government Programs That Work
Successful source reduction programs
are emerging in the public sector as
well. Seattle officials estimate a
reduction of 12 percent in the amount
of yard waste collected since
instituting a backyard composting
program that includes free bins and
in-home instruction. The New York
State prison system has embarked on a
program that replaces disposable food
trays with reusable  ones, composts
food wastes and cotton mattress filling,
and reuses paper.
  Over 200 communities in  19 states
are now charging residents for waste
pickup based on the amount of waste
they generate. These programs,
however, are primarily directed at
promoting recycling (recyclables are
picked up free), and it  is not known
48
                                                                                                       EPA JOURNAL

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whether reductions are due to
increased recycling or source
reduction. Variable rate systems that
charge something for recyclables but
more for trash could provide the
incentive for residents to adopt source
reduction practices. Such programs
have not yet been implemented.
  Government is our country's biggest
customer, accounting for 20 percent of
our gross  national product and
employing one  in six workers. While
procurement guidelines have been
used to promote recycling, they  are
rarely used to promote source
reduction. Only Connecticut has
passed legislation promoting the
purchase of  reusables over disposables.
Wisconsin is working on a life-cycle
costing system that bases purchasing
decisions on the average cost of  a
product over its useful life, thereby
recognizing  the cost savings of
purchasing more durable products.
Purchasing policies could also require
suppliers  to  ship in reusable
packaging, require longer warranties,
and specify  products  with fewer toxic
constituents.

The Future is Now
Over the past 40 years, the United
States has come to symbolize the
"throwaway society." Pressed for time
and seduced by  convenience, we have
seen products that formerly lasted a
lifetime re-emerge as  single-use
items—the throwaway camera, for
example. Increasing concerns about
our environment may reverse the
trend. Industry  is responding to
growing "green consumerism." The  CD
long box will soon be a relic of the
past, and McDonald's, a company that
epitomizes convenience,  is working
with environmentalists to reduce its
wastes.
  As knowledge of these and other
successful efforts spread, source
reduction may truly become top
priority, n
David Sdpi
                                                            Empty soda bottles
                                                                are loaded for
                                                           washing at Stewart's
                                                               Bottling Plant in
                                                              Saratoga Springs,
                                                            New York. Refilling
                                                                 bottles, once
                                                           common practice in
                                                           the United Stales, is
                                                                  rare today.
                                                          These standard/zed,
                                                          reusable shipping
                                                          containers arc used
                                                          by automotive parts
                                                          suppliers for
                                                          deliveries to 7oyoM
                                                          Motor
                                                          Manufacturing,
                                                          U.S.A., in
                                                          Georgetown,
                                                          Kentucky.
JULY/AUGUST 1992

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Getting   Serious
in   Germany
Germans are reducing their output
of household waste
by Cynthia Pollock Shea
 (Pollock Shea is a freelance writer
 Jiving in Bonn, Germany. She was
 formerly a senior researcher with  the
 Worldwatch Institute in Washington,
 DC.)
         or most Americans, walking into a
         German grocery store is a shocking
      experience. The products not only
      have funny names, many are not even
      wrapped. Meat and cheese are cut to
      order, and if you're lucky, the bakery
      clerk will hand you warm rolls.
        The biggest surprise comes at the
      checkout counter.  There are no bags,
      or baggers, waiting at the cash register.
      Plastic bags may be purchased  for
      seven cents  apiece, and sometimes
      there are extra packing boxes available,
      but most consumers bring their own
      bags or baskets to tote groceries. Older
      patrons often use "bags on wheels" to
      make the walk home less strenuous.
        Because of a wide and growing
      variety  of such source reduction
      measures, Germany is the only
      member of the 24-nation Organization
      for Economic Cooperation and
      Development that  n;duci;d its
      household waste output during the
      1980s. Household  waste production
      per person fell 9.3 percent from 1980
      to 1989 to 318 kilograms (700 pounds]
      a year. The average German produces
      one-third as much household waste as
      the average American.
        A close look at the products
      available in German stores reveals
      numerous differences. Yogurt and
      refills of wet wipes for babies come in
      containers covered solely with
      aluminum foil. A first purchase of wet
      wipes means having to buy the
      package with a dispenser top for a
      higher price. Tubes of aluminum-foil
      refills are also less expensive than
      their boxed counterparts. A toothbrush
      with three snap-in brushes costs the
      same as one  traditional model.
        Laundry detergent, in recycled  paper
      boxes, is widely sold in a concentrated
      form that packs the same punch into
      two-thirds the powder. The first boxes
      on the market included a measuring
      cup and a mesh sack.  (The sack is
refilled with detergent for each load
and helps distribute the soap evenly in
Germany's front-loading washing
machines.) Today most boxes are
labeled as refills and forego the extras.
A purchaser of a concentrated bag of
fabric softener mixes the contents of
the bag with three parts water in the
empty bottle at home. The practice
reduces packaging waste by 85
percent.
  Fresh produce is  generally loose,
except for onions packaged in net bags
and potatoes, in plastic. Selected fruits
and vegetables are placed in thin
polyethylene sacks  and weighed by the
customer on electronic scales. German
scientists have found the plastic bags
less environmentally damaging than
paper when the overall life cycle of the
bags  are compared.  Many Germans,
however, still buy their produce at
outdoor markets or directly from the
grower.
  Most beverages come in refillable
glass or plastic bottles and require a
deposit of 20 to 50 cents per bottle,
plus  more for the case itself.
Throughout Germany, 75 percent of
the beer, water, soft drinks, fruit juice,
and domestic wine  is sold in refillable
bottles, a share that is rising as
disposable containers become more
expensive and less popular among
environmentally aware shoppers.  Milk
is also available in refillable bottles,
but because of the higher price only 17
percent is sold this way.
  Coca-Cola, with 60 percent of the
German soft drink market, packages 65
percent of its retail  sales  in refillables.
The container of choice  is refillable
glass bottles, followed by steel cans;
refillable PET plastic bottles; one-use,
recyclable bottles; and FANTA juice
boxes. The refillable 1.5 liter plastic
bottle, introduced in 1989, accounted
for 90 percent of Coke's growth in
Germany last year. Lightweight and
50
                                                                                                  EPA JOURNAL

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                                                                                          Most German shoppers bring
                                                                                          their own bags to carry
                                                                                          groceries. Household waste
                                                                                          production per person in
                                                                                          Germany fell 9.3 percent from
                                                                                          1980 to  1989.
                                                           Owen Franken photo, Cjprmtin [n/ormutfan Outer
unbreakable, the containers will be
refilled at least 25 times at one of 15
bottling plants around the country
before rejects are sent to the
Netherlands  for  recycling.
  Despite the diversity of source
reduction activities, Germans are still
not satisfied  with their performance.
When asked  why the country produces
so little waste, Germans  immediately
set you straight  and describe a  huge
waste management problem they say
has only begun  to be tackled. Many of
the problems are universal:
diminishing  landfill space, political
opposition to incinerators—even the
technologically  advanced and
well-monitored  German  variety—and
popular recycling programs that are
overwhelming secondary materials
markets.
  Mounting concern over these
problems resulted in a new national
packaging ordinance in the  spring of
1991. The law requires  private
collection and recycling of all types of
household product packaging. By July
1, 1995, 72 percent of glass, tinplate,
and aluminum must be recycled and
64 percent of cardboard, paper, plastic,
and composites, such as drink  boxes. If
industry fails to achieve these targets,
government will require hefty deposits
on virtually all packaging.
  Six hundred retailers, packagers, and
consumer products are scrambling to
meet the law's interim deadlines and
hope to offer private collection service
to 90 percent of German households by
the end of the year. Glass containers
will continue to be collected through
dropoff programs.  The new industry
network, known as the Duales System
Deutschland, has given households
yellow bins and bags to store the
remainder of the discarded packaging.
To be eligible  for private collection,
packages must  carry the "green dot," a
symbol developed  by Duales. After
paying a licensing  fee to Duales that
averages one cent per package,
companies may place the green dot on
their product.  As of April 1992,
domestic and foreign-based firms had
purchased 5,000 licenses, covering 40
billion packaging units, through this
privately managed and funded
program.
  The new law also encourages source
reduction. Since December  1, 1991,
product distributors have been forced
to take back their boxes and pallets for
reuse or recycling.  Before that time,
only 13 percent of  the 2.3 million
metric tons of distribution packaging
used annually was considered
reusable. Most containers were made
of recycled paper or cardboard, but the
use of plastic shrink wrap was
growing. Now reusable plastics and
wood are increasingly used to deliver
foods, pharmaceuticals, furniture, and
biking supplies.
  Schoeller International, based in
Munich, invented the plastic beverage
case 50 years ago. It is now working on
a collapsible polypropylene  crate
designed for packing and display.
After the sides are removed, the tray is
placed directly on store shelves,
eliminating the job  of unpacking.
Uniform, interchangeable parts and
removable labels mean that after
washing, the same crate can be
circulated among cookie makers,
cosmetic manufacturers, and pasta
producers. Dubbed  the Multi-Transport
System, or MTS, the system  is being
tested by 14 retail chains and 25
consumer product companies.
Schoeller hopes the MTS will become
a European standard.
  On  April 1, 1992, the second part of
the packaging ordinance came into
effect, permitting customers  to leave
excess packaging in specially provided
JULY/AUGUST 1992
                                                                                                                 51

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bins next to the checkout counter.
Boxes surrounding toothpaste tubes,
cellophane wraps around cardboard
boxes, and plastic blister packs all  fall
into this category. Retailers, unwilling
to become garbage dumps, pressured
their suppliers to eliminate any excess,
and it seems to be working.  A recent
survey designed to detect altered
behavior among 400 Duales  members
found that a quarter of previously
packaged products are now sold au
nature!. Polyvinyl chloride and plastic
foams were abandoned completely. Of
the 146 companies that formerly used
plastic blister packs, only one still
does.
  The German tradition of conserving
resources is largely  a result of the
devastating scarcities suffered during
and after World War II. Though rich in
technical expertise, Germany is a
densely populated country  with a
miserly endowment  of natural wealth,
and societal pressure to behave
responsibly and consume frugally
remains strong.
  As a result, German companies
frequently view environmentally
friendly products and production
processes as market  opportunities,  not
government punishments. Indeed,
market response often exceeds
company expectations.
  Thirty months after introducing a
concentrated laundry detergent
designed to reduce packaging and
water pollution, Procter and Gamble's
innovation had captured 30 percent of
the powdered detergent market. Sixty
percent of the company's fabric
German companies
frequently view
environmentally friendly
products and production
processes  as market
opportunities.
softener is sold in refill bags. Six
months after introducing mercury- and
cadmium-free batteries in 1989, the
German company Varta saw its share
of grocery-store battery sales more than
double, from 7 to 17 percent.
  Source reduction efforts in Germany
extend far beyond the grocery store
and factory floor. Dehoga, a major
hotel and restaurant association, urges
members to reduce  energy, water, and
waste; limit use  of harmful cleaning
products;  and recycle garbage
   for ;
-------
                               aSSROOM
                       "Tweety and the Beanstalk" is taken from Tweety's Global Patrol, a series of teacher-friendly
                       activities that are designed for third and fourth grades. Tweety's Global Patrol is a joint effort of
                       EPA, the Alliance for Environmental Education, and  Warner Brothers.  For more information, please
                       contact the Alliance for Environmental Education,  51 Main Street, The Plains, VA 22171, (703)
                       253-5812.
                               ET,
                                                    Tweety and the  Beanstalk msSa5s=s=:5K.

                                                    Nature's Original Recycling Program
                                                    In nature, there is no waste  Everything is ted back into the system!  Imagine a world
                                                    without waste!  We  can learn from nature's recycling program:  the world ol cycles.
                                                    Hut. how can we feed crenllniig back into the system-" Well, that's pretty difficult.
                                                    but Tweety has some Ii)KA STARTHRS!
                                                    Think Cycle.

                                                    Tmvty'x Idea Sktrtcr
                                                    The end is the beginning.
                                                     Key words: Cycle, recycle,
                                                     compost, decomposers
                                                   ! You will need as many 2 liter recyclable plastic bottles as you want to use with your {
                                                   !_ class, leaves that have fallen or grass clippings, soil, scissors, and a source of water, j
                                                                                                        ; -
Tnlike nature, we try to get rid of as much yard waste (leaves, grass clippings, small
branches, etc.) and food .scraps as possible.  But guess
what!  What we think is the etui of their usefulness
can actually be the beginning of something wonderful!
Let's watch it happen'

• Cut  2 bottles anil tape pieces together as shown
Many  different arrangements can be made, but this
one is tor compost columns.
• Make air holes in cylinder with healed paper clip.
scissors,  or cold needle. The decomposers (living
things that assist  in the natural process til decay) need
oxygen.
• J-'ill columns with small pieces ol leaves or other
organic material, with and without soil. (You may want
to start one ahead of time so "before and alter" com-
parisons can be made without waiting so long.)
• Schedule for it to "rain"  periodically, Watch1 As the
organic material decays, it turns into compost.
Idea 1 — Can each student make a compost column?
Can they be set up differently and results compared-1
Idea 2 — What will we do with the compost? Cirow a
giant beanstalk, what else"'

Tuwty's Ich'ci Starter
A Giant Beanstalk or a "Giant" Anything Else
                                                                                                                     '  ,
                                                  !" For giant beanstalk's — use Scarlet "Runner liean" seeds. For giant" anytHitig" else —"try
                                                    seeds of marigolds, coleus, sunflowers, or Fast Plants from Carolina Biological
                                                    Supply. You II also need soil and "pots", such as cardboard egg canons, small plastic-
                                                    containers or milk cartons  with holes in the bottom — all with a waterproof protec-
                                                    This can be fun — and messy!  A Mathstartcr«»\Ve'll need to mix some compost
                                                    material with the soil ( I  part compost to 3 parts soil), and put some into each "pot."
                                                    Follow directions for planting seeds and keep soil moist, \Vhen the seeds start to
                                                    sprout, it is very important to keep them in a sunny window — south or west
                                                    direction,  if it's possible to move the seedlings into a garden outside, we will have a
                                                    beautiful school garden, or a garden at  home! Slake beanstalks so they will grow tall.

                                                    Idea 1 — Compare seeds grown in soil only and in soil with compost, What do you
                                                    think we will find out'  Make a graph of results.  Idea 2 — Write a poem. song, or
                                                    story about this experience anil the things you have  observed.
                           :- Alliance for Environmental Education
                          Made possible mrough a grant ttom the United Stales Environmental Protection Agency
                         TWEETY'S GLOBAL PATROL, characters, names and all related indicia are trademarks of Warner Bros Inc. '1992
JULY/AUGUST 1992
                                                                                                                             53

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FOR  THE CLASS®
A  Lesson   Plan
on   Recycling
                (For Junior and
 Senior High School Students)
What Is Municipal Solid Waste?
Municipal Solid Waste (MSW) is the
garbage that Americans produce in
their homes and where they work. The
word "municipal" means anything that
is operated and controlled by elected
local officials, such as city or county
governments. MSW refers to what we
throw away each day, including
newspapers, yard waste, old
appliances, household garbage, and
just about anything else you can think
of that ends up in the garbage or trash.
  Americans generate more than 195
million tons of MSW each year. This
means that, on average, each of us
creates over 4 pounds of garbage every
day.
  What goes into our nation's MSW?
The figures below show you the
components of what we throw away
by weight.
  Together, these components create a
lot of trash, and more will be created
in the years ahead. According to the
Environmental Protection Agency
(EPA), Americans will be throwing
away over 25 million more tons of
garbage every year by the year 2000.

Disposing of MSW
Where does all the garbage go? Over 66
percent of MSW goes into the ground
in landfills. About 16 percent is
burned, and  17 percent is recovered
for recycling or composting.
  Landfills have been the method most
societies have used to get rid of
garbage. A landfill is a special pit that
has been dug in the ground to hold
garbage. Once the pit is full,  dirt is
used to cover the trash.
  For many reasons, fewer landfills are
 Acknowledgement: Teachers Sue
 Rafferty and Fran EarJe of Yorktown
 High School in Arlington, Virginia,
 worked with EPA Journal staff to
 prepare this feature.
       Paper Paperboard 37.5%
  Yard Wastes 17.9%    Miscellaneous 8.3%
 54
                                                                                          EPA JOURNAL

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                                                              REPROCESS

being built today, as older landfills
close. There are about 5,000 landfills
left in the United States, and half of
these will be closed by the year 2000.
  Population growth has had the
largest impact on the solid waste
stream. Since 1865, when  the
population was 35 million, the number
of people living in the United States
has grown to 250 million.  As the
number of people has grown, so has
the total  amount of trash produced.

What Is Recycling?
Although the best answer  to the MSW
problem  is to reduce the amount of
waste we create in the first place, some
waste will probably always be
produced. Many waste materials,
however, can be remade into useful
products, and this process is called
recycling. Glass, for example, can be
crushed into small pieces called cutlet,
melted down, and made into new
bottles. Every time we remove
             0  6!
                                6
                                 ff
                     materials from our garbage and trash to
                     recycle it, less garbage and trash have
                     to be trucked  to  the landfill.
                       The three arrows in the recycling
                     symbol represent basic steps in the
                     recycling process: coJJect, reprocess,
                     and reuse. All three steps must occur
                     before we can say that recycling  has
                     taken place. It is not enough, for
                     example, to collect old bottles  and
                     crush them into  cullet. Someone has to
                     buy the cullet and use it to make new
                     bottles.



What Can We Recycle?
Besides glass, the following materials
commonly found in our garbage and
trash can be recycled.
Aluminum cans—melted  down and
made into new  cans.
Tin-plated steel cans—the tin is
dissolved  off and sold separately as
ingots; the steel cans are washed and
sold as high grade steel.
Paper—shredded, mixed with water,
and beaten into pulp. The pulp is
screened to get  rid of most of the
water; the remaining fibers are pressed
and dried  into recycled paper.
Plastics—soft drink  and milk
containers, the two  items  most
commonly found, are made of different
kinds of plastic. Separated or mixed,
they are melted down to br, reshaped
into recycled products. If  ihey are
separated, they  can  be r made into
higher quality product.
Yard waste—grass,  leaves, and shrub
and tree clippings can be  ground up,
then composted into mulch.
            Continued on next page
 Plastics 8.3%
Metals 8.3%   Glass 6.7%  Food Wastes 6.7%  Wood 6.3%
JULY/AUGUST 1992
                                                                                            55

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For the Teacher
• Explain the recycling symbol. Muke
an overhead transparency from an
enlargement of  the illustration and
explain what each arrow means.
• Have each  student carry a grocery
bag for a day to collect all trash
(anything that would be thrown away)
he or she generates during a 24-hour
period. The next day in class, sort and
classify the components (such as
paper, plastics,  and aluminum) of each
person's trash and weigh the
components.
  Calculate component percentages
both for individuals and for the class
as a whole. Discuss differences
between individuals.
  Using the total weighs calculated for
the  class and using published
population figures, calculate the
amount of trash produced each day by
the  school, the  city or county, the
state, and the nation.
• Divide the  students into groups to
research and  prepare reports on the
following (this  issue of EPA Journal
provides source information):

  How do government  regulations and
policies affect recycling?
  How can plastics, metals, glass, and
paper be recycled?
  (One report for each type of
material.)
Conclusion. Students have collected
and separated their personal trash, the
first arrow of the recycling symbol.
Their reports should give insight on
the  second  (remake) and third (reuse)
arrows.  End this unit in a class
discussion on how the  recycling loop
can be closed in your community.
Additional Activities
• Have the students examine the trash
collected during the above activity to
determine the recyclable materials not
collected by your community. Have
them write a letter to the local county
board or city council apprising
officials of the results of your study
and urging them to expand their
recycling efforts.
• Organize a trip to tour a recycling
plant.
• Imagine that you have been told that
your school's supply budget for the
rest of  this year has been eliminated.
Have your students design new  uses
for materials, remaking and reusing
them. Create a display of these
materials.
• Stage a class debate, after providing
time for researching the issue. The
debate question could be: "Is recycling
worthwhile?"
• Have the students choose a product
that seems to have excess packaging
and write to the  manufacturer urging
that the package be streamlined. Have
them ask that recycled materials be
used whenever possible.
• Have the students create an art
display using trash as "found objects."
• Using archaeological techniques, the
Garbage Project at  the University of
Arizona has sorted, catalogued,  and
evaluated more than a quarter million
pounds of garbage since 1973. Have
your students try their hand by  using
the trash they have collected. Ask the
question: "What  does this trash  tell us
about the people who threw it away?"
Look for clues such as the amount of
processed  foods, microwave foods,
brand name or gourmet foods, generic
or in-house brands, etc. Can you form
a profile of this group? What is
missing from this trash? Is it possible
to form an accurate picture from this
collection?
Sources
"Let's Reduce and Recycle: Curriculum
for Solid Waste Awareness," presents
lessons and activities to teach  students
in grades K-12. (EPA/530-SW-90-005)
"School Recycling Programs: A
Handbook For Educators," presents
step-by-step instructions on how to set
up a school recycling program.
 (EPA/530-SW-90-023)
"Environmental Education Materials
For Teachers and Young People"
(Grades K-12). Annotated compendium
of educational materials on
environmental issues.
 (EPA/OCEP A-21 K-l 009)
Call the EPA Solid Waste Hotline at
1-800-424-9346 (in Washington, DC
382-3000) or write to: RCRA
Information Center (OS-305), U.S. EPA,
401 M Street, SW., Washington, DC
20460 for copies of all EPA
publications and for information on
how to contact recycling coordinators
in your  area.


Also Available
"The Consumer's Handbook for
Reducing Solid Waste," a practical
guide suitable for junior and senior
high school students
(EPA530-K-92-003).
                                                                                                      EPA JOURNAL

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A  Meeting  with  the  Dynamometer
Cars must pass the
scrutiny of EPA's
emissions laboratory
by Lily Whiteman
                   7es( vehicles spin
                 their wheels and the
                      engines rev at
                 programmed speeds
                 while being checked
                        on the EPA
                     dynamometer.
fWhiteman is a poJicy analyst with
EPA's Office of Mobile Sources.)

JULY/AUGUST 1992
    typical car rolling off the
    assembly line today emits only
about 5 percent as much pollution as
did the typical new car in 1972. The
fuel economy of 1992 models, twice as
efficient as typical 1972 models,
averages about 28 miles per gallon.
The average car on the road today is
about 80 percent cleaner than 20 years
ago.
  Where do these high-tech facts come
from? Answer: EPA's National Vehicle
and Fuels Emissions Laboratory
(NVFEL) in Ann Arbor, Michigan. It is
here—a stone's throw from the motor
city of Detroit—that EPA scrutinizes
the emissions and  fuel consumption
patterns of real-life automobiles. As
sample vehicles are tested at NVFEL,
their inputs  and outputs are measured
much as human responses are
monitored during stress tests.
  The  heart  of NVFEL vehicle tests is
the dynamometer.  Just as a treadmill
allows a human patient to exercise in
place, a dynamometer allows the test
vehicle to simulate driving on the road
without leaving the test lab. Immobile
though a test vehicle may be, it
nevertheless pumps out as much
pollution as if driven under
comparable conditions on the road.
And as the test vehicle runs on the
dynamometer, its tailpipe exhaust
emissions are routed to precise
laboratory equipment for measurement.
  NVFEL is one place where the
principles of equality prevail; no
favoritism here. Elite Lamborghinis
complete the very same test
schedule—a triathalon of sorts known
as the Federal Test Procedure
(FTP)—as do everyday Ford Escorts.
The main part of the FTP consists of a
43-minute dynamometer test run that
simulates an 11-mile urban commute.
In this fast-changing sequence, short
periods of idling punctuate stretches of
stop-and-go city driving and short
sprints. A second 13-minute
dynamometer test mimics 10 miles of
free-wheeling highway driving. During
                                                                  57

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these dynamometer runs, fuel economy
is also measured.
  Two additional tests were added to
the FTP after NVFEL scientists found
pollutants were released from areas
other than tailpipes. Surprisingly large
amounts of pollutants, NVFEL
experiments reveal, evaporate directly
from fuel systems that are heated even
just slightly—even when they are
parked.
  NVFEL scientists collect and
measure evaporative emissions with
the help of a Sealed Housing for
Evaporative Determination (SHED). In
order to estimate emissions released
during heating caused simply by high
afternoon temperatures, emissions
from a test vehicle in the SHED are
monitored as the temperature of its
fuel system is slowly raised from 60  to
84 degrees Fahrenheit. Another SHED
test, conducted on a recently revved
vehicle, is designed to gauge
evaporative emissions generated by a
parked car that is cooling down from a
recent run.
  It is the acute sensitivity of NVFEL's
analysis equipment to exhaust
emissions levels that makes the FTP
much more accurate than
neighborhood inspection and
maintenance (I/M) tests used today.
While both the FTP and I/M  tests
measure hydrocarbon and carbon
monoxide emissions, the majority of
I/M tests do not measure nitrogen
oxide levels as the FTP does. The FTP
test also accounts for many factors
influencing emissions—such as cargo
weights and wind resistance—that
current  I/M tests ignore. Moreover, the
specificity of the FTP facilitates
comparisons between emissions  test
results and federal standards.
  Any prototype vehicle that produces
pollution excesses either on the
dynamometer or in the SHED gets two
more tries. However, if the test vehicle
belongs to the 1 percent of engine
families that fail the additional tests,
the manufacturer may be fined. A
second failure also gets the engine
family scrapped or sent back to the
drawing board—only to confront
another judgement day at NVFEL
down the road.
  Failures are infrequent, because, as
required by law, manufacturers engage
Even after EPA releases an
engine family to  the mean
streets, emissions
surveillance continues.
in extensive tests on their home turf
before sending prototype vehicles to
EPA for review. These analyses, which
last about six months, put prototype
vehicles through grueling tests
equivalent to covering about 50,000
miles. Emissions are sampled every
5,000 miles. As a general practice, only
when a new engine family is deemed
durable and clean enough to pass
federal standards is the data submitted
to EPA.
  EPA usually considers the
manufacturer's home-turf test results
sufficient evidence of compliance with
federal standards to approve an engine
family for mass production.
Nevertheless, the Agency selects
prototype vehicles representing 30
percent of new engine families to strut
their stuff at NVFEL. Some  engine
families are randomly selected for
these tests. Others are picked because
their design is significantly  different
from previously  tested vehicles. And
sometimes EPA needs to view FTP
results to determine whether an engine
family deserves to be taxed  as a gas
guzzler.
  Exotic, low-production vehicles are
more likely to fail the FTP than are
more ordinary models with longer
histories and larger total production.
For example, the Dodge Viper, which
sells for between $60,000 and
$100,000, took many tries over several
months and several rounds of
improvements to earn a thumbs-up
from EPA.
  Even after EPA releases an engine
family to the mean streets, emissions
surveillance continues. The Agency
may run surprise checks at auto
assembly lines to ensure that mass
produced cars are at least as clean as
their tested prototypes. Sometimes, the
widespread popularity of an engine
family focuses EPA attention on
certain models. Consistent failures on
I/M tests may suggest to EPA that the
emissions performance of certain road
warriors is not holding up under
real-world driving conditions.
  Once EPA identifies suspect models,
the Agency—relying on the kindness
of strangers—borrows privately owned
vehicles for testing at NVFEL or other
test labs around the country. Poor
emissions grades on extensive EPA
tests yield expensive recalls, an option
that manufacturers consider too costly
to let happen often. Indeed, the
industry's relatively high pass rate at
NVFEL shows that EPA's policing
system does keep automakers  honest
and on their toes.  But recalls do occur.
  Despite the success of the current
program, EPA's test procedures are not
written in stone, so to speak. EPA is
currently reevaluating its testing
procedures  to reflect insights into
typical real-world driving patterns
gained through driver surveys and the
lab's own testing. In addition, EPA's
current deliberations  over whether to
regulate "nonroad" mobile pollution
sources, such as locomotives, motor
boats, and chainsaws, may mean new
moving targets for NVFEL testing. Q
58
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Thinking  about  the
Consen/ative  Thinkers
A Book Review by  E. Donald Elliott
   ook out, EPA! Just when you
   thought you'd survived the
 conservative onslaught, here comes
 Fred L. Smith, Jr., and friends.
  The environmental policies  of
 Bush-Quayle/Reilly-Habicht have
 emphasized reforming EPA's programs
 to incorporate market incentives,
 risk-based priorities, cost-effectiveness,
 and voluntary cooperation from
 industry to prevent pollution.
 According to the Smiths of the world,
 these reforms are mere halfway
 measures. They amount to "the
 ecological equivalent of ... market
 socialism," the failed policy of former
 Communist countries in which goals
 were set politically but implemented
 through markets. They may even be
(Elliott is Julian and Virginia Cornell
Professor of Environmental Law and
Litigation, Yale Law School, and is
affiliated with Fried, Frank, Harris,
Shriver and Jacobsen, New York City
and Washington, DC, as a consultant.
During 1989 to 1991, he served as EPA
Assistant Administrator and General
Counsel.]
dangerous, because they "make it
[regulation] easier" (horror of horrors),
not to mention cheaper and more
efficient.
  The real target, argues Smith and a
growing segment of the conservative
intelligentsia, should be the entire
concept of centralized regulation of the
environment by the government. Not
only is centralized, bureaucratic
regulation inherently subject to
self-serving manipulation by "special
interest groups," including
environmental groups and bureaucrats,
but, more fundamentally, the concept
of centralized regulation protecting the
environment is wrong.
  Environmental Politics: Public Costs,
Private Rewards, edited by Michael S.
Greve and Fred L.  Smith, Jr. (Praeger,
1992; 209 pp.), consists of nine
chapters.  Seven are case studies by
authors of particular environmental
decisions, from the Clean Fuels
Program (under the 1990 Clean Air
Act), to Superfund, and the
controversy over the use of the
synthetic hormone bovine
somatotropin to increase milk
production in dairy cows. The
common theme is "rents," the
argument popularized by University of
Chicago economists that government
regulation provides a ready political
lever that special interests can use for
their own purposes. This is not a new
idea, but the case studies are
interesting and useful in that they
illustrate how the process works in
environmental regulation.
  The intellectual core of the book,
however, is in the introductory and
concluding essays by editors Greve
and Smith. Greve summarizes the
arguments about what is wrong with
the present system. Curiously absent
from his summary is the criticism that
regulation does too little, that the
present system requires huge volumes
of information and, therefore, is slow
and cumbersome, and leaves some
problems unaddressed. In the final
chapter, Smith develops his
provocative theoretical argument that
private remedies should replace the
JULY/AUGUST 1992
                                                                                                        59

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present system of government
regulation.

Market Failure Re-Examined
For decades, the standard theoretical
justification for public environmental
regulation has been the concept of
"market failure": Unregulated markets
fail to internalize the true social costs
of pollution because polluters can
"externalize"  the costs of their
pollution onto others as damages that
go uncompensated. Thus, government
should step in to regulate.
  This "market failure" argument is
useful as far as  it goes; however, a
number of academics have criticized  it
for failing to consider the moral—if not
outright religious—dimension that
underlies our attitudes about the
environment; among other things, the
conventional  economic argument for
regulating pollution implies  that not
having enough pollution is bad
(because the money spent could
produce greater benefit elsewhere), an
idea that many find strange.
  Smith attacks the market failure
justification for public regulation from
a totally different perspective. The  best
way to protect the  environment,
perhaps the only way, he says, is not
through government regulation, but
through expanding private markets to
include environmental quality: "Rather
than viewing  the world  in terms of
market failure, we  should view the
problem of externalities as a failure to
permit markets and create markets
where they do not  yet—or no
longer—exist." This has some force in
areas such  as  municipal solid waste,
where government  monopoly on trash
collection hides the true costs of waste
disposal from consumers.

Private Environmental  Law
In emphasizing private alternatives to
government regulation of the
environment, Smith is part of a
growing chorus of  free-market thinkers,
as illustrated  by the recent books of
Richard Stroup and John Barden, and
Terry Anderson and Donald Leal.
While this literature is long on
criticism of the present system and on
theoretical arguments for "private
environmental law," it is very short on
the practical details of how private
property and litigation rights would
actually replace public regulation in
protecting the environment.
  The standard view, which Smith
discounts, holds that private nuisance
or damage suits by individuals harmed
by pollution, while useful in some
cases, cannot be relied on to regulate
pollution because of the problem of
"transaction costs": The costs of
developing information about the harm
I doubt that "private
environmental law" will ever
replace government
regulation.


caused by pollution are too large, and
the provable damages that could  be
recovered by  individuals  are too  small
to make it worthwhile for many
lawsuits to be brought, particularly
since case-by-case litigation is very
expensive and time-consuming.
  Smith acknowledges that these
problems are  "real" but argues that
moving the issue into the public  sector
doesn't make  the problems less
difficult:  "Under a private regime,
proof problems and the like will
sometimes cause a failure to abate
pollution. The political manager, in
contrast, can limit pollution even
without proof of damage."
  Smith's arguments  are interesting
and provocative, but  a bit Utopian. I
doubt that "private environmental
law" will ever replace government
regulation. History never repeats  itself
exactly, and the 19th century's
approach to regulating pollution is
unlikely to be reinstated. A more likely
future is a "hybrid" system, in which
both private rights and governmental
regulation work together.
  Elements of public/private hybrid
systems already exist: for example, in
Superfund, which consists of a strange
amalgam of government  regulation and
private litigation; and in the Toxic
Release Inventory, in which
government regulation requires the
compilation and disclosure of
information, but private, local action
then "enforces" pollution prevention
based on this information. The record
of such systems is mixed, but the high
costs and long delays in the Superfund
program do not inspire confidence that
case-by-case litigation in the courts is a
cure-all for the problems of public
environmental law.
  Most conservative thinkers complain
bitterly about private lawsuits as a
regulatory device where  they currently
exist—product liability,  medical
malpractice, toxic torts. It is a strange
anomaly that they have such faith in
private lawsuits to take on the much
larger, and more difficult task of
environmental regulation,  o
60
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A  Conservationist  in  the  Wings
     y friend Ramsay fancies himself
     a real bass man. We met when
we were at business school. That was
back in the late sixties, at the
University of Virginia. Ramsay fished
all the time. He had married a local
girl whose father had a bass pond right
behind the house. Her old man kept it
filled with largemouth bass, big lazy
lunkers that just lay there waiting to be
fed .... Ramsay loved to catch bass.
  After graduation, I had gone to work
for a developer of vacation homes. I
spent most of my time touring the
most beautiful parts of New England,
figuring out how to chop them up into
lots for A-frames. Business school had
warped my values. I'd become
consumed with making money.
Ramsay had taken a prestigious job
with the Boston Consulting Group.
Unfortunately for Ramsay, Boston was
a long way from his father-in-law's
bass pond. When he called me one
day, he was desperate ....
  I thought back to Jordan's Camps*
and remembered how much I loved to
fish. Every night, if it wasn't raining or
too windy, we'd row out and try our
luck .... We always caught a bundle
of fish: hornpout, white perch, yellow
perch, and even an occasional
smallmouth bass. Catching a bass in
Lovewell Pond  was a big deal. Real
bass men didn't fish Lovewell. They
went to a secret pond, up toward
North Fryeburg ....
  Then I got the call from
Ramsay .... I told him not to worry,
that there was a secret pond just north
of Fryeburg that supposedly was
loaded with smallmouth
bass .... Meanwhile, I was thinking to
myself that this pond might give me a
chance to make some money. Given
the growth that had taken place
around Fryeburg, it must just be ripe
for development.
*A campsite just outside Fryeburg,
Maine, on the south side of Lovewell
Pond, where the author had
vacationed as a child.
  Ramsay was parked outside my door
at noon the very next Saturday. He had
his canoe tied onto the top of his car
and the back was loaded with all kinds
of camping and fishing
equipment .... Ramsay made me read
aloud from McLane's Standard Fishing
Encyclopedia as we headed for
Fryeburg. The chapter on bass  was
dogeared and thoroughly
annotated ....  "The smallmouth bass
is widely acclaimed as the  top trophy
of the bass family. The fish is
extremely active and usually jumps
when hooked. The average smallmouth
is not nearly  as large as many
freshwater fish, but the capture of a
four-to-five pounder requires more
skill and more patience than the taking
of many species of comparable size."
Ramsay had me read that part several
times .
                                                               Brmon photo
  When 1 finally found the pond,
Ramsay insisted that we launch the
canoe immediately .... Except for one
new cabin down at the far end,
nothing had changed. The pond was
still natural and wild.  It reminded me
of what Lovewell  used to be like when
I was a kid. It was a developer's
dream ....
  Ramsay took  complete command, lit:
put me in the bow and told me that we
would paddle about thirty yards from
shore, trolling a line on each side of
the canoe. I tied on a Rapala, an
underwater lure that looks like a
minnow. Ramsay  scoffed at my Rapala.
"Overrated,"  he said. He chose a Tony
Accetta Jelly  Belly with the Glow
Eyes ....
  Within ten minutes I felt a strong
jerk on my line. I  looked back and saw
a smallmouth leap out of the water.
JULY/AUGUST 1992
                                                                                                        61

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L.
Ramsay was ecstatic .... [He] carefully
photographed it from several angles
before releasing it. He was sure that in
a matter of minutes he would be
posing with one of his own.
  Only it didn't happen. My Rapala
hooked another beauty, which Ramsay
didn't bother to photograph. He was
too busy changing lures. His second
selection was Bagley's Famous Mud
Bug....
  By nine o'clock, the Rapala had
scored again, but the  Mud Bug had
lured only one fish, and it got
away .... He rummaged through
several layers of his tackle box and
finally settled upon Fred Arbogast's
classic Double-Lobed Lip Jitterbug.
This particular model had the
markings of a green frog and two sets
of treble hooks.
  It was totally dark by the time we
started back to camp. We were each
trailing about twenty-five yards of line
when Ramsay announced he had a
strike ....
  Ramsay was positive he had a big
one.  "Let's hear it for Fred Arbogast!
This could be a new school  and pool!
This mother's really jumping!"  Then
there was a dramatic  change in his
voice. "Hey," he said anxiously,
"something's wrong here."
  "Ramsay! Get your rod down! You're
going to lose him if he comes up!" .. .
  At that moment, a large white object
came soaring over the canoe and
slammed into the water. "Get the
light!" Ramsay screamed  ....
  "What light?"
  "The one in my tackle box!"
  I leaned back, but  I couldn't reach
his tackle box. By this time, Ramsay's
"fish" had taken off again. It circled
the canoe and crashed into the  woods.
  "Ramsay," I said, "you must have
caught a bird. Hold the line, and I'll
paddle us to shore."
  "The hell with that. I'm cutting this
line, before whatever it is comes back."
  I started to protest, but Ramsay cut
the line .... We could hear  the bird in
the woods, trying to shake the
Jitterbug. "Let's get back to camp,"
Ramsay said. He was not pleased ....
  "Wait a minute," I said. "We can't
leave that bird. It might be an
eagle." . ..
  We heard the tinkle of hooks as the
bird  continued to try to free itself. It
was only a few hundred feet away.
"I'll tell you what,"  I said.  Let's go
down to that cabin and see if they
have some flashlights . ..."
  We paddled down and introduced
ourselves to Dick and Pat de La
Chapelle and their four children.  The
de La Chapelles couldn't believe that
Ramsay had caught  a bird. The kids
quickly ran off to find it.... After
half an hour, we had found nothing.
We were just about  to give up when
we heard the sound of hooks tinkling
under a bush. I turned the  light toward
the sound and saw two huge brown
eyes  glaring at me. The bird was a
barred owl. Its beak and talons were
locked together by the treble
hooks ....
  I took off my jacket, one of those
heavy, red-and-black Woolrich shirts,
and threw it over the owl.
   Back at the cabin, I placed the bird
on the picnic table,  next to Dick de La
Chapelle's big kerosene lantern. I
gingerly removed the jacket. The bird
lay there, studying me with its huge
brown eyes ....
  "Ramsay," I said.  "Get in here and
help me clean your  fish."
  "You've got to be  kidding," Ramsay
said.
  "Come on, it's just a bird."
  "That's not just a  bird; that's a big
bird, with a big beak, big talons, and
big hooks."
  I knew he was right, but I had to  try
to free this bird .... "Come on. All
you have to do is hold the wings  and
consult. I'll do the cutting."
  The idea  of consulting must have
appealed to Ramsay. He stepped
forward and grabbed the owl by both
wings. I took a pair  of pliers and went
to work. I had no idea what the owl
might do when I freed its beak and
talons. "Ramsay," I said, "if he starts to
attack me, let him go."
  "Don't worry" was all Ramsay said. I
could see the sweat  on his brow and
felt a bead trickling down my own
nose.
  Remarkably, the bird just lay there.
It must have been in shock. As I
removed the final hook, I no  longer felt
like a developer. I felt like  John J.
Audubon, Izaak Walton, and  Aldo
Leopold all rolled into one.
  "Okay, Ramsay, nice going,"  I told
him. "Your consulting job  is  over."
  Ramsay looked very relieved .... I
wrapped the bird back into my jacket,
picked it up, and laid  it on the dock.
Swaddled in my Woolrich  with only
its head showing, it looked like a baby
with extra big eyes and a funny
haircut. "Ramsay, quick, take a
picture," I said. "You can send it to
your father-in-law.  Show him what  a
real smallmouth looks like."  Ramsay
got one shot of his  owl before it
wriggled itself free, defecated on my
jacket, and flew into the night.
  We fished again the next morning.
Instead of thinking about ways  to
develop the pond, I found  myself
thinking about ways to protect  it. All
Ramsay was thinking about was fish.
My Rapala caught one more nice bass,
but [his] Sidewinder came  up empty.
No fish, no birds, no nothing.
  I was in high  spirits during the drive
back to Boston.  This trip had
convinced me that  I was not  cut out to
be a developer.  I didn't want  to exploit
these beautiful places. What I really
wanted to do was protect them ....
  I called Ramsay at his office a few
days later. I wanted to see  if  we were
going fishing and tell him that  I was
looking for a job in conservation. I
planned to give his owl full credit.
Ramsay's secretary told me that he was
out of town and wouldn't be  back until
the following week. He was on  some
personal business. He  had  gone to see
his father-in-law in Virginia,  a

—From "One Over Our Limit"  by
David E. Marine and originally
published in Down East magazine.
Copyright 1988. Reprinted by
permission of Down East magazine
and David E. Marine.  Also available in
Good Dirt, GJobe Pequot Press, 3990.
62
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G. Tracy Mehan III is a new
Associate Deputy
Administrator. Mehan's
responsibilities will include
coordination of policy and
regulatory issues on behalf of
the Deputy Administrator.
  Mehan was the director of
the Missouri Department of
Natural Resources (DNR)
from 1989 until August of
this year. In that capacity he
managed the state's
environmental, energy, and
parks programs. Before his
stint at the Missouri DNR, he
was a partner in the St. Louis
law firm  of Anderson, Gilbert
& Garvin. From 1978 to 1979,
Mehan served  as staff
attorney in the St. Louis
County Counselor's Office.
He also served as a law clerk
for Judge John J. Kelley,
Missouri Court of Appeals,
Eastern District.
  Mehan earned his
undergraduate and law
degrees from St. Louis
University. He has served as
chairman of the Upper
Mississippi River Basin
Association, Commissioner to
the Midwest Interstate
Low-Level Radioactive Waste
Compact, Vice-Chairman for
the Missouri Basin States
Association, and as a member
of the State/EPA Operations
Committee, which  seeks to
create better working
relationships between states
and EPA.
Nancy B. Firestone has been
appointed as an EPA
Environmental  Appeals
Judge. The Environmental
Appeals Board  consists of
three judges—Ronald L.
McCallum and  Edward E.
Reich have already been
named and were profiled in
the March/April issue of EPA
Journal—called from the
ranks of senior  Agency
attorneys. The board will
make final Agency decisions
in appeal cases contesting the
adjudicatory decisions of
Administrative  Law Judges
and Regional Administrators.
  Firestone previously served
as an Associate Deputy
Administrator. She has also
served as the Deputy Chief of
the Environmental
Enforcement section at the
U.S. Department of Justice. In
addition to her  duties at EPA,
Firestone is currently an
Adjunct Professor at the
Georgetown University Law
Center, where she teaches
environmental law.
  She earned her bachelor's
degree from Washington
University in St. Louis and
her law degree from the
University of
Missouri—Kansas City Law
School.
The new Director of the
Environmental Monitoring
Systems Laboratory in Las
Vegas, Nevada, is Wayne N.
Merchant. The lab develops,
evaluates, and applies
methods and systems for
monitoring the environment.
It also develops monitoring
techniques for a variety of
environmental pollutants and
conducts environmental
studies nationwide.
  Merchant has previous
experience in managing
research programs. From
1988 until July of this year,
he served as Chief of
Research and Laboratory
Services in the Bureau of
Reclamation. He also served
as Deputy Assistant Secretary
for Water and Science in the
Department of the Interior
from 1986 until 1988.
Previously, Merchant served
as program manager and
scientist at the U.S. Bureau  of
Mines in Washington, DC,
and at Salt Lake City
Research Center.
  Merchant earned a
bachelor's degree in
chemistry at the University  of
Nevada and a
doctorate in chemistry at the
University of California. o
JULY/AUGUST 1992
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Acid Rain Damage?
The May/June issue of EPA Journal contains a photograph
of a seriously damaged forest. The caption [which reads,
"Dealing with modern environmental problems, such as
acid rain, requires ingenuity and new approaches."]  implies
that acid rain caused the injury and death of the trees
shown in the picture [p.6]. This implication is not correct.
Acid rain (more accurately called acid deposition because of
its many physical and chemical forms) has not been proven
to be the primary cause of tree injury and death in any
natural forest that I know of in North America.
  A call  to the Editor confirmed rny suspicion that the
forest shown in the photo was part of the mixed Kraser
fir/red spruce forest near the summit of Ml. Mitchell in my
home state of North Carolina. From  1995 to 1989. I was the
Mount Mitchell Site Director for an  EPA-sponsored research
program  called the Mountain Cloud Chemistry project. (See
article in the May/June 1989 issue of EPA Journal entitled
"There's  More Than Poetry in the Clouds.") The purpose of
this program was to measure the deposition of airborne
pollutant chemicals and some other stress factors that occur
at this high-mountain location.
  At this site, the primary cause of injury and death of
Fraser firs in this mixed conifer forest is not  acid
deposition, but rather an insect called the Balsam  Woolly
Adelgid.  Acid rain, acid snow, acid cloudwater, ami
phytotoxic concentrations of ozone all occur frequently at
this site.  It is possible that these pollutant chemicals
predisposed the trees to attack by this insect. But the insect
itself is capable of causing injury and death to Fraser fir
trees.
  Although the implication  of this  picture and caption is
not correct, their publication in the  KPA Journal provides
stimulus for some readers  who may wish to continue their
education about how acid  deposition affects various types
of forests in North America:

• In some forests with minimal supplies of available sulfur
and nitrogen, acid deposition adds to the supply of these
essential nutrients and thus  helps the forest grow.

• In some forests where the trees grow in acid soils  with
low buffering capacity, the cumulative deposition  of acidic
and acidifying substances over many decades induces
further acidification. This leads to eventual impoverishment
of the soil caused by depletion of available calcium.
magnesium, and/or other nutrients  that are essential  for
normal growth and development of trees.

• In some  forests receiving large cumulative deposition of
acidifying nitrogen compounds, the soil eventually becomes
nitrogen  saturated. This sometimes leads to surface-water
and ground-water accumulations of nitrate that  exceed safe
drinking water standards.

• In high-elevation red  spruce forests in the  northern
United States, acid cloudwater sometimes predisposes the
trees to damaging or killing  frost. This effect has not been
noted at  Ml. Mitchell and other high-elevation locations in
the southern United States, probably because injurious cold
occurs here less frequently than  in northern parts of our
country.

• In some  other forests  (including the spruce fir forest at
Mt. Mitchell), we do not yet know  if, when, where, or to
what extent, acid deposition is causing changes (directly or
indirectly through interactions with other factors) in forest
growth, health, productivity, species composition, genetic
stability, aesthetic quality, wildlife habitat, water quality, or
other aspects of the forest environment.

Ellis Cowling
Professor of Plant Pathology and Forestry
North Carolina State University
Raleigh, North Carolina
Skeptical of the  Skeptic

The Congress and the President have not been drawing
much praise these days, but fortunately they were not
nearly as dumb as Michael Gartner thinks they were when
they enacted the 1990 Clean Air Act Amendments ["A
Skeptic Speaks," EPA Journal, May/June 1992], Among
other things, the Act requires the nation's utilities to cut by
nearly half, or 10 million tons, their sulfur dioxide (SCs)
emissions,  a crucial precursor of acid rain, and cap total
emissions at the reduced level. To make sure that utilities
and their rate payers do not have to pay more than
necessary to meet this ambitious mandate, the Act permits a
utility that  has trouble meeting its requirements to offset its
extra emissions if another utility cuts its emissions more
than required. The nation  still gets the total reductions as
bargained for, but at a lower cost—up to $1 billion a year
lower—than if every utility had to make the same
reductions  no  matter what the cost. Without that cost
savings, Congress probably would not have passed, nor the
President signed, such a tough acid rain program. Instead,
fewer reductions would  have been required and total
emissions would not have been capped.
  Mr. Gartner worries that this cost savings might come at
the expense of the people  living near the utilities that use
this system to  emit more SO2 than otherwise allowed.
Fortunately, the President and Congress  worried about
exactly the same thing. That is why the law says that  no
matter how many extra emissions offsets a utility buys from
others that  make extra reductions, it can never increase its
emissions above the standards set by other provisions of the
Clean Air Act to protect public health. In addition, all
utilities will be making an overall reduction of 10 million
tons.
  That is also why comparing the Clean Air Act's acid rain
emissions trading system to trading off "No Smoking"
sections in  restaurants, as Mr. Gartner does, misses the
point entirely. Emissions trading under the acid rain
program allows us to get the most reductions for every
dollar spent without sacrificing public health or
environmental protection.  In view of the urgency of our
nation's environmental and other social challenges, we
cannot afford to pay more  and get less emissions control.

Joseph Goffman
Senior Attorney
Environmental Defense  Fund
                                                                                                                   EPA JOURNAL

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Sieve DaJoney photo. KP/V
                                                                                                Youthful enthusiasm is one of the driving
                                                                                                forces behind recycling.
                                                                                                Back cover: "Honey, did you put out the
                                                                                                recyclables?"
                                                                                                Photo by Art Stein /or FuJio. Inc.

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