STATUS REPORT
ON SOLID WASTE
DISPOSAL CHARGE
Third Report to the President and Congress of the United States
Mandated by the Resource Conservation and Recovery Act of 1976
(Public Law 94-580)
RESOURCE CONSERVATION COMMITTEE
July 1978
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THE RESOURCE CONSERVATION COMMITTEE
DOUGLAS M. COSTLE, Chairman
Administrator, Environmental Protection Agency
JUANITA M. KREPS, Secretary of Commerce
CECIL D. ANDRUS, Secretary of the Interior
F. RAY MARSHALL, Secretary of Labor
W. MICHAEL BLUMENTHAL, Secretary of the Treasury
CHARLES WARREN, Chairman, Council on Environmental Quality
ELIOT CUTLER, Office of Management and Budget
ROBERT LITAN, Council of Economic Advisors
ALVIN ALM, Department of Energy
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CONTENTS
Section Page
Transmittal Letter i
I. Staff Papers on Solid Waste Disposal Charge
A. Introduction 1
B. Review of the Current Status of Solid
Waste Management—Staff Background
Paper No. 10 4
C. Rationale for National Solid Waste
Disposal Charge Legislation—Staff
Background Paper No. 8 37
D. Solid Waste Disposal Charge Design
Issues—Staff Background Paper No. 9 . . 47
E. Public Comments on Staff Background
Papers No. 8 and 9 71
II. Status Report on Committee Work Program . . 156
Appendix
Invitation to Participate in Public Meetings on
Solid Waste Disposal Charges A-2
Index to Public Comments on Solid Waste Disposal
Charges A-6
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RESOURCE
CONSERVATION
COMMITTEE
THE FEDERAL INTERAGENCY COMMITTEE ESTABLISHED UNDER PUBLIC LAW 94-580
401 M Slice! S W Washington D C 20460
JUL 2 6 1978
Douglas M Costle
Administrator Environmental Protection Agency
MEMBERS
JuanllaM Kreps
Secretary of Commerce
Cecil D Andnii
Secretary of tie Interior
f Ray Marshall
Secretary ol Labor
W Michael Blumenthal
Secretary of trie Treasury
Charles Warren
Chairman Council on
Environmental Qualify
Eliot Culler
Office of Management
and Budget
Nina Cornell
Council of
Economic Advisors
AMnL Aim
Department of Energy
To the President and the Congress:
I hereby transmit for your consideration the third
report of the Resource Conservation Committee. The
Committee was established under Section 8002 (j) of
Public Law 94-580. This is the third in a series of
four reports required by the law. We submitted our
second report in January 1978. This report describes
the activities of the Committee since that time.
The report contains preliminary staff papers on
solid waste disposal charge legislation and a discussion
of the status of pending Committee activities. The
activities include studies that must be completed
before we can make recommendations regarding solid
waste disposal charge legislation. They also include
studies on other resource conservation issues which the
Committee is reviewing.
We have encountered significant delays in completing
our evaluation of the impacts of solid waste disposal
charge legislation. These delays are the result of
difficulties we have experienced in developing a
satisfactory computer model of the affected industries.
This model is essential in quantifying the costs and
benefits of disposal charges. We anticipate resolving
this problem soon and will forward recommendations on
solid waste disposal charges in our final report.
However, because of the delay in analyzing the
solid waste disposal charge, we will not be able to
complete the full study of resource conservation issues
by October 1978. After discussions with Senator Jennings
Randolph, Chairman of the Senate Public Works Committee
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- 2 -
and Congressman Fred B. Rooney, Chairman of the Subcommittee
on Transportation and Commerce of the House Interstate
and Foreign Commerce Committee/ we have decided to
delay the submission of our final report until March 1979.
Respectfully submitted for the Resource Conservation
Committee,
Enclosures
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RESOURCE CONSERVATION COMMITTEE STAFF
PAPERS ON A- SOLID WASTE DISPOSAL- CHARGE
INTRODUCTION
Section 8002{j)(D) of Public Law 94-580 mandates the Resource
Conservation Committee to study:
the appropriateness and feasibility of enploying as a
resource conservation strategy the imposition of solid
waste management charges, which charges would reflect
the costs of solid waste management services, litter
pick-up, the value of recoverable components of such
product, final disposal, and any socia] value associated
with the non-recycling or uncontrolled disposal of such
product...
During the past six months the Resource Conservation Comrittee (RCC)
and its staff have studied the desirability of adopting a national
solid waste disposal charge which would reflect the cost of municipal
solid waste collection and disposal in the cost of products.
The basic rationale for the disposal charge initiative under consider-
ation thus far is that it would cause the prices of consumer products
and packaging to reflect the social cost of municipal solid waste
collection and disposal. By "pricing" the cost of solid waste management
in the relevant raw material and product markets, the disposal charge
could encourage a more efficient allocation of economic resources
in general and also conserve natural resources and reduce the municipal
solid waste burden. In order to assess the potential for improving
pricing, the RCC staff is studying how services ideally should be
priced and how they are priced at the present time. Subsequently,
a practical charge initiative must be designed and analyzed to see if
it can significantly improve existing pricing methods.
This report contains three RCC staff papers which provide background
information useful for the design and the assessirent of the desirability
of a solid waste disposal charge. However, no quantified analysis or
conclusions with respect to the desirability of the charge have been
included in this report. The RCC staff has not yet completed its
analysis of the charge, and the Committee has not made any attempt to
take a position with respect to the disposal charge.
Although the Committee has chosen to examine the feasibility of
using a national charge to alter the pricing of products to include
costs of solid waste management services, a similar incentive could
be designed to alter product prices to take other economic and non-economic
factors into account. These factors could include:
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o pollution externalities;
o the economic advantages of virgin materials relative to
recovered materials due to existing Federal policies;
o the "costs" of excessive import-dependence;
o resource conservation, per se.
These factors/ in addition to the inadequate pricing of consumer
products and solid waste services, could be used to justify an incentive
to encourage additional use of recycled materials. Such an incentive
might have benefits similar to the disposal charge in terms of conservation
of natural resources and reduced municipal solid waste burdens.
However, the Committee intentionally chose to initially exclude
these other rationales for a product charge and concentrate on the pricing
question. This does not mean that these other rationales are not a valid
basis for a "product charge" or that the Committee will not consider these
other rationales in the future.
Staff Background Paper No. 8 summarizes the conceptual argument
for implementing a national solid waste disposal charge, and as such,
it is an advocacy paper. It was prepared by the RCC staff to serve
as a conceptual starting point for analyzing the charge and does not
in any sense represent the opinion of the staff or the Committee as
to the desirability of the charge.
Considerable debate has been generated by the Rationale paper.
Members of the Committee and the public have questioned whether rrunicipal
solid waste services are significantly mis-priced, and if they ere,
whether a national charge could improve the pricing of municipal
services. These are the issues currently being analyzed by the staff.
Staff Background Paper No. 9 identifies and discusses possible
policy options for eleven solid waste disposal charge design issues.
The discussion of the policy options clearly indicates that the options
which would inprove pricing to the greatest extent would considerably
conplicate the administration of the initiative. This suggests that
the adoption of measures increasing the benefits of the charge initiative
would also increase the costs.
Municipal solid waste management costs vary considerably between
localities. Different resource recovery methods save irunicipalities
different amounts of money, and some municipalities are already using
quantity-based pricing techniques. Adjusting the national charge
rate on a site-specific basis to account for these variations would
improve the overall efficiency of the charge as a resource allocation
mechanism, but in each case such adjustments would be undesirable
from an administrative standpoint.
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The necessary administrative compromises limit the potential of a
national charge to improve the pricing of municipal services, but a
national charge could still improve pricing in the aggregate if the
inprovement brought about by the charge is sufficiently large in munici-
palities where services are mispriced. The RCC staff is currently
undertaking an empirical analysis to determine whether the overall
inpact of the charge would be positive.
Staff Background Paper No. 10 provides a review of the current
status of municipal solid waste management operations. Information is
presented on organizational arrangements, actual costs of collection
and disposal, and financing systems. This information provides the basis
for the on-going staff efforts to estimate the net benefits of the best
national disposal charge which can be designed.
The analysis required to assess whether a national disposal charge
can improve natural resource use has turned out to be exceedingly
complex. Economic theory indicates that improved pricing will improve
natural resource utilization. However, a national disposal charge must
be compared with existing pricing mechanisms. Since no practical
mechanism is ideal, the analysis of the disposal charge must determine
whether the administrative compromises inherent in a national charge
unduly limit the potential improvement associated with an ideal charge
system. The results of this quantified analysis of the impact of the
charge will be presented with the Committee's recommendation to the
Congress in the final Resource Conservation Committee report.
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STAFF BACKGROUND PAPER NO. 10
July 10, 1978
A REVIEW OF THE CURRENT STATUS
OF MUNICIPAL SOLID WASTE MANAGEMENT
I. Introduction
Scope of the Paper
This paper describes the current status of municipal solid waste
management in the United States, in terms of the amount and composition
of waste generated, organizational arrangements, actual costs of collection
and disposal, and financing systems. Relying largely on recent
survey data, this paper is primarily descriptive and is intended as
a source of background information for members of the Resource Conservation
Committee. This paper puts a number of solid waste management issues
into perspective and serves as a preface to analytical Staff papers
which will follow. These analytical papers will deal with the environ-
mental and economic impacts of various waste reduction and resource
conservation policies under consideration by the Committee.
Municipal solid waste, as used here, refers to post-consumer
solid waste collected from small residences, multiple unit dwellings,
and commercial establishments. Agricultural, industrial, mineral and
hazardous wastes are not discussed.
Summary
The conclusions drawn in this paper are based largely on survey
data compiled in 1974 and 1975 by researchers from Columbia University,
the International City Management Association and Public Technology, Inc.,
on national surveys conducted in 1974 and 1975 by Waste Age Magazine,
and on data compiled by the Environmental Protection Agency.
Most of the information dealing with the organization of collection
systems, the costs of collection and landfilling, and financing systems
is taken from the Columbia University survey. This survey, conducted
under a grant from the National Science Foundation, covered in its broa
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Based on the sources noted, the following conclusions are reached:
1. Net nunicipal solid waste disposed of totalled 135.5 million tons
in 1976, an increase of 8.4 percent over 1971. It is expected that
this will increase to 166 million tons annually by 1985. 2/
2. In 1974, it cost nearly $4 billion to collect and dispose of this
nation's municipal solid waste; it is estimated that complying with
Federal and State environmental standards for disposal will increase
annual costs for nunicipal waste disposal by about $400 million. 3/
3. Private firms are involved in over half the residential mixed refuse col-
lection arrangements in this country, in 70 percent of service to multiple
unit dwellings, and in 81 percent of service to commercial establishments. 4/
4. Small cities are likely to employ private contractors to collect
refuse, while large cities more frequently use municipal arrangements. 5/
5. Fifty-seven percent of residential collection systems provide pick-up once
per week and 31 percent provide twice per week service. Fifty-
three percent provide curb or alley pick-up while only 12 percent
provide backyard service. 6/
6. While 96 percent of the country's municipal solid waste is disposed
of on land, nearly 2/3 of the land disposal sites do not meet
environmental standards. 7/
7. Incineration is a relatively rare method of disposal, accounting for
4 percent of municipal solid waste, and is becoming increasingly
rare (down from 8 percent in 1972), while the use of resource recovery
systems is increasing. 8/
8. Nationwide, as indicated by the Columbia University survey data,
the average cost of residential solid waste collection in 1974
was $23.97 per ton. The average cost of disposal on land was
$3.72 per ton. 9/
9. Total collection costs are extremely sensitive to the amount of
labor used and to the wage rate. Frequency of collection and location
of pick-up are also important cost determinants. 10/
10. Engineering estimates of the cost of processing refuse through
RDF resource recovery facilities indicate net per ton costs of
between $8 and $15. Processing wastes through incineration costs
between $25 and $35 per ton. ll/
11. Of 2,069 collection systems surveyed which serve single family residences,
36 percent financed solid waste management out of general revenues,
51 percent utilized a flat rate user fee, and 13 percent used
a variable fee. 12/
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12. For all classes of service recipients, systems using local user fees
are more common than systems using taxes. User fees are more
likely to be the mode of payment for multiple unit dwellings and
commercial establishments than for small residences. Plat rate fees
are more widely used than variable fees foe small residences,
but the reverse is true for commercial establishments. 13/
13. In large cities, solid waste handling for other than multiple-
unit-dwellings is more likely to be financed through taxes than through
local user fees. 14/
14. Among systems that utilize variable rate user fees, contract arrangements
tend to match their fee with their actual costs; municipal arrangements
tend to charge less than actual cost. 15/
II. Quantity arx3 Composition of Municipal Solid Waste
In 1976, the net municipal solid waste disposed of in the United
States totalled 135.5 million tons, an increase of 8.4 percent over
1971 and up only slightly from the 134.8 million tons generated in
1974. "Net waste disposed of" includes collected and uncollected
wastes disposed of by incineration, land-filling, dumping, and littering,
after accounting for amounts of materials recycled. 16/ Approxiirately
70-72 percent of this refuse originated in residences, with the remainder
coming from commercial establishments. IT/
The material source composition of the municipal solid waste generated in
1976 is presented in FIGURE 1.
Nonfood
Product
Waste
63%
Misc.
Inorganics
1%
Nonfood product waste includes
paper, glass, metal, plastics,
rubber, leather, wood and textiles
and accounted for 63 percent of
the net waste disposed of. Food
waste accounted for 17 percent,
yard waste for 19 percent, and
miscellaneous inorganics for 1
percent.
FIGURE 1: MATERIAL COMPOSITION OF POST-CONSUMER NET SOLID WASTE
DISPOSED OF, 1976 IB/
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TABLE 1 presents the composition of non-food product waste. From
a product-source perspective, over half of this category of refuse
was comprised of packaging and container waste. In terns of material
categories, paper dominates the tonnage of product waste, followed by
glass and metals.
TABLE 1
POST-CONSUMER NET SOLID-WASTE DISPOSED OF, BY MATERIAL AND PRODUCT
CATEGORIES , 1971-1976 19/
Product Composition
Newspapers, books, magazines
Containers and packaging
Major household appliances
Furniture and furnishings
Clothing and footwear
Other Products
Total Nonfood Product Waste
Material Composition
As-Generated Weight
(millions of tons)
1971 1976
10.3
41.7
2.1
3.2
1.2
18.4
76.9
12.6
44.7
2.2
3.4
1.4
19.6
Psper
Glass
Metal
Ferrous
Aluminum
Other
Plastics
Rubber and leather
Textiles
wood
Total Nonfood Product Waste
39.1
12.0
11.8
(10.6)
(0.8)
(0.4)
4.2
3.3
1.8
4.6
76^9
42.3
13.6
12.2
(10.7)
(1.1)
(0.4)
5.1
3.3
2.1
4.8
8379"
Environmental Protection Agency projections indicate that net
waste disposed of will increase to 166 million tons annually by 1985.
In 1974, collecting and disposing of municipal solid waste cost
this country nearly $4 billion. It is estimated that complying with
existing and proposed environmental standards for municipal waste
disposal facilities will result in additional annualized costs of over
$400 million. 21/ Of this, 45 percent is attributable to proposed
Federal criteria* and 55 percent is due to existing State standards
which have yet to be complied with. 22/
The proposed Federal criteria were developed under the authority
of the Solid Waste Disposal Act as amended by the Resource Conservation
and Recovery Act of 1976, and the Federal Water Pollution Control
Act as amended by the Clean Water Act of 1977.
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III. Organization and Nature of Services
Collection Arrangements
Municipal solid waste collection systems are characterized by
a number of arrangements between those who arrange for the service and
those who actually provide it. Most coimonly, the arrangement takes
one of the following forms:
1) "municipal"; a local government agency both arranges for and
actually provides the service.
2) contract; the local government arranges for a private firm to
provide the collection service. Payments are made by service
recipients to the community, through either property taxes
or special billing. Payments to the firm are made in a lump
sum by the community.
3) franchise: a private firm with an exclusive franchise both
provides the service and collects payment for it directly
from service recipients. Under this system, the arrangement
may be made by either the service recipient or the community.
4) private; a firm with a non-exclusive franchise provides
service to recipients who arrange for it themselves. Payments
are made directly to the firm.
5) self-service; the waste generator disposes of his waste,
either on site or by transporting it to a public or private
disposal facility.
"Other- 1*
Franchise 6%
Of 2,060 cities surveyed by Columbia
University in 1974, 1,342 had private
firms participating in residential
collection either by a franchise,
contract, or private arrangement,
769 had some sort of municipal
residential collection, 377 had
self service, and 23 had some other
sort of arrangement (such as
location within a regional
sanitation district).
FIGURE 2; RESIDENTIAL COLLECTION ARRANGEMENTS, 1974 23/
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A number of conclusions regarding the distribution of collection
arrangements can be drawn from the data presented in APPENDIX A.
First, larger cities more commonly use municipal collection
arrangements. This being true, it follows that central cities are
more likely than suburban areas to have municipal collection arrangements.
70
f*f\
60
50
Percent 40
of
Cities 30
20
10
0
p —private
M — Municipal
C —Contract
F -
_ 37
_
-
-
P
23
M
65
F*P
55
- Franchise
16
C
2,500-
9,999
35
24
I MBiM
6
71
P
_
M
22
•••••i
C
8
71
10,000-
49,999
16
Mi^HMB
P
M
11 13
Vn F
cfpl I P
^^™
M
55
50,000- > 250,000
249,999
City Population
FIGURE 3: CITY SIZE AND RESIDENTIAL SOLID WASTE COLLECTION ARRANGEMENTS, 1974 24/
Second, private firms serve most of the cities outside the South,
where municipal arrangements are prevalent. In the Northeast and North
Central regions, private service of one type or another is three times
more common, and in the West twice as common, as municipal service.
But in the South municipalities provide their own solid waste services
three times as frequently as they employ private firms.
Service Levels
The level of service provided by municipal solid waste collection
systems is defined by three characteristics:
1) frequency of collection;
2) location of pick-up; and
3) the existence of special collections for items such as yard
wastes and bulky durable goods.
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Lea Tton Onea/Weck 1%
Mora Thin Tmca/Wmk 2%
With respect to the frequency
of residential collection,
of 2,091 systems surveyed,
only 33 provided collection
more than twice per week,
643 provided it twice per
week, 1,196 once per week, 17
less than once per week, and
202 had some other service frequency,
such as seasonal peak load
variations or multiple collection
frequencies for different classes
of customers.
FIGURE 4: FREQUENCY OF RESIDENTIAL COLLECTION, 1974 25/
APPENDIX B shows the distribution of collection frequencies by
city characteristics. Collection tends to be more frequent in the South
than in other regions of the country. This may be due to the warm
climate, which increases the health hazard of having refuse piling up
due to infrequent collection, or to lower labor costs.
Region
I
vt
O — Twice/Week or More
O - Once/Week or Less
J
10 20 30 40 50 60 70 80 90 100
Percent of Cities in Region
FIGURE 5: GEOGRAPHIC REGION AND FREQUENCY OF RESIDENTIAL COLLECTION, 1974 26/
10
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"Other11
2%
With respect to the location of
pick-up, of 2,084 residential col-
lection systems surveyed,
250 provided backyard pick-up,
1,105 provided curbside or
alley pick-up, and the remainder
had some other arrangement,
such as a combination of
pick-up locations.
FIGURE 6: LOCATION OF PICK-UP, 1974 _27/
The data presented in APPENDIX C indicates that in the largest
cities, a variety of pick-up locations is common, the likelihood of
curbside service being provided is greater in smaller cities, and
pick-up from the yard is more common in the South than in other regions
of the country.
1,814 of the cities surveyed by Columbia University provided
special collections of bulky materials from residential customers.
It was found that municipal collection systems are more likely than other
kinds of collection arrangements to provide special pick-ups of bulky
materials (Table 2).
TABLE 2
PERCENTAGE OF CITIES PROVIDING SPECIAL COLLECTION OF BULKY
MATERIALS, BY COLLECTION ARRANGEMENT, 1974 28/
Municipal
Contract
Franchise
Private
Self-service
51%
9%
4%
28%
24%*
*The total exceeds 100 percent because many cities have more than one
of collection arrangement.
11
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The fact that few contractors provide special pick-ups of bulky
materials does not necessarily mean that they do not collect them, since
it is fairly common for contractors to make arrangements to pick up
bulky items on their regular runs without scheduling special pick-ups.
Disposal Modes
The two methods of "disposing" of municipal solid waste currently
in use in the United States are: landfill (both sanitary and otherwise)
and incineration.
Sanitary landfill is defined by the American Society of Civil Engineers
as
"a method of disposing of refuse on land without creating nuisances
or hazards to public health or safety, by utilizing the principles
of engineering to confine the refuse to the smallest practical
area, reducing it to the smallest practical voluire, and covering
it with a layer of earth at the conclusion of each day's operation,
or at such frequent intervals as may be necessary. 29/
Not all disposal of refuse on land meets this specification; "cosmetic
landfills" (i.e. covered dumps) are not sanitary landfills. Many
such sites exist. They were located with consideration only of convenience
and have since been covered because of public pressure to eliminate
"open dunping." 30/ Implementation of the proposed HCRA standards will
change the accepted definition of "sanitary" landfill.
Incineration is largely a method of solid waste volume reduction.
However, due to the passage of strict air pollution control laws and a
growing desire to conserve non-renewable resources, many new systems
are being proposed in place of incineration.
Land Disposal
Disposal of solid waste on land is by far the most common mode of
disposal in this country. More than 90 percent of America's solid waste
is disposed of on land. A survey of the country by Waste Age Magazine
in 1975 reported over 17,000 known land disposal sites. Of these,
slightly less than one-quarter met approved environmental standards.
Two percent of the remaining sites had permission from the state to
continue operations. Seventy~five percent, however, were operating without
meeting standards and without state exemption from the standards.
A similar survey, conducted in 1976 and reported by Waste Age Magazine
in January of 1977 indicated that the total number of known land
disposal sites had decreased to 16,000. Of these, 36 percent were
operating in compliance with state standards and permits, 27 percent
were capable of being upgraded sufficiently to receive permits, and
37 percent were expected to be closed as incapable of satisfying
environmental standards. 31/
12
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EPA estimates that the additional costs to industry and municipalities
of meeting environmental standards will be $1.6 billion a year of which about
$400 million can be attributed to municipal wastes. 32/
In 1974 the International City Management Association surveyed
442 cities that operate their own land disposal sites in an effort to
determine the environmental and safety acceptability of the sites.
49 percent of the cities had operations based on a formal design and
operating plan prepared by engineers, 7 percent provided methane gas
control 89 percent provided daily cover, 66 percent provided litter
control, 29 percent leachate control, 8 percent leachate treatment, and
5 percent used an impermeable membrane. In general, it was found that
as city size increases, the acceptability of the landfill in terms of
environmental and safety standards also increases. The distribution
of landfill characteristics by city size, geographic region, and city
type is presented in APPENDIX D.
In 1976, there were 105 municipal incinerators with capacities in
excess of 50 tons per day operating in the United States.* Of these
105, 75 were not in compliance with appropriate emissions-control regulations,
and out of the 75, 23 were not even on a compliance schedule. Since
1976, 28 municipal incinerators have ceased operation, leaving 77
currently processing municipal solid waste. Incinerators are much more
commonly used in the Northeast and North Central regions of the country
than in the South or West. As shown in APPENDIX E, for every population
category, rated capacity exceeds actual utilization. Incineration is
generally the most expensive method of processing solid waste, and the
cost per ton increases if the rated capacity is seldom reached.
"Resource recovery" is a general concept referring to any productive
use of what would otherwise be a waste material requiring disposal.
As such, it represents an alternative to land disposal or volume reduction
by incineration. Resource recovery includes narrower concepts such
as: recycling of materials to their original use (e.g., melting down
bottles to make new bottles); material conversion (e.g., crushing
bottles and mixing the glass with clay to make glassy bricks or composting
the organic fraction); and energy recovery (capturing the heat value
from organic waste, either by combustion or by first converting it
into an intermediate fuel product). The volume of waste to be landfilled
can sometimes be reduced by up to 90 percent by recovering the combustibles,
glass, aluminum and ferrous materials from the waste stream. There are
two general approaches for extracting resouces from the waste stream:
1) Source separation, where specific components are kept out of the
general waste collection system at the point of generation; and 2)
mixed-waste processing, involving the extraction of material and energy
*This number does not include waterwall combustion units (WWC) which
recover energy and are, therefore, considered resource recovery facilities.
There are currently five WWC plants operating in the U.S.
13
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values from collected mixed municipal waste at centralized (usually
large scale) processing facilities. In 1971 8.1 million tons of
refuse (6.1 percent of discards) were recycled and in 1976 9.2 million
tons (6.4 percent of discards) were recovered. 33/
There are currently 27 operational resource recovery facilities in
the United States capable of processing collected mixed waste. Additionally,
there are 6 systems under construction. Recycling centers number
approximately 3,000 and are concentrated in the Northeast and in
California. Forty communities have separate collection locations
for paper, glass and/or cans, and 175 have source separation programs
for paper. State involvement in resource recovery includes 12 states
with grant or loan authority, 20 states involved in planning or
regulation, and 6 states with operating authority. A list of resource
recovery, mixed-waste facilities is presented in APPENDIX F.
IV. Actual Cost Factors in Solid Waste Handling
The costs of municipal solid waste collection and disposal are
highly variable across localities. The Columbia University survey
reported a nationwide average cost of residential collection of $23.94
per ton* in 1974. However, the range of observed costs was very
broad - from $4 per ton to over $50 per ton.
10
9
8
7
6
5
4
3
2
1
.
-
-
6.7
-
-
2.8
-
- .6 .6
rr~
5.6
—
10.7
3.4
9.0
L2
10.1
6.6 5.6
3.4
12
4.0 40
2.8
11
1.7
1.1
1.1
H
2.3
4.0
U
24 6 810121416182022242628303234363840424446488)
Dollars per Ton
FIGURE 7: RESIDENTIAL COLLECTION COST DISTRIBUTION, 1974 3J/
*177 cities were included in this special cost survey in the Columbia
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The average repotted disposal cost was $3.72 per ton.** Again,
however, the range was broad - from less than §1 per ton to over $9
per ton. 35/
IJ
1Z
11
10
3
S 8
3
•s '
1 6
"" 5
4
3
2
'
.
-
-
.
-
-
-
.
1 E
32
16
109
as
88 88
BO
—
5J
40
32
~™l
24 32 24
I 1 1 16 16 16 16J 1
8 1 1 8| 8 8 1 88
ol n ~r l.rr
35 70 >05l«OI752IO!.lS29J3r53S)385«20«H«905r, 560S906256eO
Dollars per Ton
FIGURE 8: DISPOSAL COST DISTRIBUTION, 1974
(cont.) * University study; all had populations between 2,500 and 1.5 million.
Because the sanple did not include large cities, and because large cities
account for a relatively large share of total national waste generation
and frequently have higher costs, the nean cost calculated from this
sanple may be less than the true national average for all cities.
Nevertheless, the Columbia University data remains the best available,
both in terms of accuracy in reporting and because of the relatively large
number of conrarunities covered.
**A11 177 cities surveyed used landfill as their disposal method. They were
not all environmentally acceptable. Disposal costs were obtained only
for cities served by private firms, and the cost reported was the fee
paid by the firm for refuse disposal. Thus, these disposal costs
do not include the costs of transfer stations or of bulk hauling from
transfer stations.
15
-------
Determinants of Cost
Collection Costs
There are many factors which explain why such a wide variance in
per ton collection costs was observed. Two dimensions by which costs
vary are city size and the type of collection arrangement.
City
Population
o
in
o o
o o
T- in
o o
•o o
52
30.05
Municipal
18.87
1 Contract
21.02
Municipal
16.58
'iContractf
v
26.35
10 15 20
Dollars per Ton
25
30
FIGURE 9: AVEFAGE PEP TON COLLECTION COSTS, BY CITY SIZE AND TYPE OF
COLLECTION ARRANGEMENT, IN CITIES WITH ONCE-A-fcEEK COLLECTION,
1974 37/
In every population category, controlling for service level,
contract arrangements had the lowest costs for once per week collection,
followed by municipal systems. Private arrangements were the most
expensive, probably due to the inability of firms serving less than
all households to achieve economies of density which may exist.
Another, and possibly nore inportant, determinant of cost is
the level of service provided. The Coluirbia University survey found
that, on average, per ton collection costs increased 23 percent
when collection services were provided twice per week rather than
once per week. When refuse was collected from the backyard, rather
than from the curb or alley, costs increased an average of 62 percent. 3_8/
16
-------
Additional significant cost determinants are crew size and the
capacity of the collection vehicle. For curbside collection, two
person crews lead to an average increase in per ton collection costs of
120 percent over one person crews. This is not surprising. When a
two person crew is used/ one person generally only drives the truck.
Therefore, the loading time does not decrease. In fact, it appears
that it increases by approximately 20 percent, possibly due to two
person crews taking more breaks or spending more time on their breaks than
one person crews. However, when three person crews were used instead
of two person crews, costs were seen to decrease an average of 22
percent for curbside collection. This is possibly due to a trade-off
between paying two person crews overtime and paying an extra person
a regular salary, the overtime being more expensive. 39/
In spite of higher capital costs for larger collection vehicles,
it was found that using trucks with a capacity of more than 20 cubic
yards led to system wide per ton costs that were approxiirately 18 percent
lower than when smaller trucks were used. This is apparently due to the
fact that fewer trucks were required and less time was spent hauling
to the disposal site.
Disposal Costs
There are two major determinants of disposal cost. One is the
method by which wastes are disposed. On average, current landfilling
practices have costs in the range of $3 to $4 per ton; meeting environ-
mental standards will result in an increase in costs on a nationwide
average of approximately $2.95 per ton. 4j)/ Processing refuse through
resource recovery facilities leads to net per ton costs of between $8
and $15. 4_1/ However, because of the wide variation in landfilling
costs, resource recovery is competitive with landfilling in some locations.
Incineration is the most expensive method of disposal with costs of
between $25 and $35 per ton, including capital amortization and current
operating costs. 42/
If incinerators or resource recovery facilities are utilized,
then the configuration of the waste stream beconres a very important
cost determinant. FIGUFE 10, on the following page, indicates comparative
net costs for five resource recovery plants, each of which processes
510,000 tons of municipal solid waste annually. It should be noted
that these are engineering cost projections, rather than actual
reported costs. Plant A recovers only refuse derived fuel (PDF).
Plant B recovers both RDF and steel. Plant C recovers RDF, steel
and aluminum. Plant D recovers RDF, steel and glass, and Plant
E recovers all four - RDF, steel, aluminum and glass.
17
-------
Plant
E
D
C
B
A
RDF,
Steel,
RDF, Steel
RDF,
RDF
RDF
Steel,
Aluminum, and Glass
and Glass
and Aluminum
12.67
1 11.55
and Steel
Only
10.79
11.34
12.71
6 8 10 12 13 Dollars per Ton
FIGURE 10: COST COMPARISON OF FIVE RESOURCE RECOVERY PLANTS 43/
Cost Components
Collection
The cost components of municipal solid waste collection can be
divided into five categories:
1) labor, including both direct labor costs and overtirre;
2) fringe, benefits;
3) operating costs, including vehicle operation and maintenance,
office expenses, billing, and insurance;
4) overhead costs,; and
5) vehicle depreciation, calculated on a five year, straight line
basis.
From FIGURE 11 the relative importance
of labor cost in overall residential
collection cost can be seen. On
the average, labor accounts for
over 50 percent of the total cost
of refuse collection. Direct labor
and fringe benefits together account
for nearly 70 percent of the total
cost.
FIGURE 11: COST COMPONENTS OF A REPRESENTATIVE RESIDENTIAL COLLECTION
SYSTEM, 1974 44/
18
-------
As a result, the cost of collection is extremely sensitive to the
amount of labor employed and to the wage rate. This would lead one to
expect that where wages are relatively high, a more capital intensive
collection technology would be used than where wages are low. However,
the data for municipal collection arrangements does not necessarily confirm
this expectation.
TABLE 3
COLLECTION TECHNOLOGY, WAGE PATE, AND CREW SIZE, IN CITIES
WITH MUNICIPAL COLLECTION SYSTEMS, 1974 45/
AVERAGE MONTHLY
WAGE RATE
GEOGRAPHIC REGION
(Dollars)
AVERAGE CREW
SIZE
(ftnen)
AVERAGE TRUCK
CAPACITY
(Cubic yards)
Northeast
North Central
South
West
497
684
499
695
3.2
3.2
3.4
2.1
18.9
18.4
19.2
24.9
In the South, where wages in 1974 were relatively low, larger crew
sizes and smaller trucks were used. Similarly, in the West, where
wages were high, smaller crews and larger trucks were used. However,
in the Northeast and North Central regions, no apparent relationship
exists between wage rates and the capital/labor ratio. This suggests
that perhaps municipal collection systems in those regions operate
less efficiently in some respects than do municipal systems in the South
and West.
For private contractor collection arrangements, however, the expected
relationship between wage rate and the capital/labor ratio is reinforced,
as indicated in TABLE 4.
TABLE 4
COLLECTION TECHNOLOGY, WAGE RATE AND CREW SIZE IN CITIES WITH
CONTRACT COLLECTION ARRANGEMENTS, 1974 46/
AVERAGE MONTHLY
WAGE RATE
AVERAGE CREW
SIZE
AVERAGE TRUCK
CAPACITY
(Dollars)
(# men)
(cubic yards)
GEOGRAPHIC REGION
Northeast
North Central
South
West
669
697
614
694
1.9
1.8
2.4
1.7
20.1
20.3
22.2
24.7
19
-------
Disposal
The cost components of sanitary landfill ing can be divided into
five categories:
1) labor, including direct labor and overtime costs;
2) fringe benefits;
3) operation and maintenance of vehicles;
4) administrative costs;
5) capital depreciation, including land, development, stationary
equipment, and vehicles.
As indicated in FIGURE 12, below, overall disposal (through landfilling)
costs are much less sensitive to the labor component than are overall
collection costs. Labor and fringe benefits together account for only
39 percent of total disposal costs. Vehicle operation and maintenance
account for 29 percent and capital depreciation for 22 percent.
Operation tt
Maintenance
29%
FIGURE 12: COST COMPONENTS OF A REPRESENTATIVE LANDFILL, 1974 47/
Unlike landfill sites, resource recovery facilities for processing
mixed wastes are highly capital intensive. Engineering estimates
of the cost components of a representative RDF resource recovery
facility break down as follows: capital depreciation, 53 percent;
direct labor and overtime, 11 percent; fringe benefits, 7 percent;
operation and maintenance, 26 percent; and disposal of residues,
three percent. 48/
20
-------
Incineration facilities, especially where heat recovery is involved,
are also highly capital intensive. Engineering estimates indicate
the following break down: capital costs account for approximately
48 percent of total costs; labor, including fringe benefits, account
for 27 percent; and operation and maintenance for 25 percent. 49/
V. Financing
Modes of Payment
The principal modes currently in use for financing municipal solid
waste collection and disposal are:
1) through local property taxes, deposited in the general fund, and
2) through a system of local user fees or service charges.
Local user fee systems vary widely. Most systems charge a flat
fee, regardless of the amount of waste to be collected or the level of
service provided. Others charge a variable fee which can be either
service or quantity oriented. Many communities have mixed financing
systems, charging some classes of customers and taxing others.
Of 2,060 cities surveyed by
Columbia University, 742
financed handling of municipal
solid waste from residences
through taxes, 1,051 through
flat rate user fees, and 267
cities used variable user
fees.
FIGURE 13: PREVALENCE OF FINANCING MODES FOR RESIDENTIAL COLLECTION, 1975 50/
21
-------
FIGURE 14, below, indicates the percentages of service recipients charged
by the three financing nodes.
S.
60
50
40
30
20
10
0
-
42
Q)
X
44
<0
DC
to
1 s
Variable
34
Ui
8
i=
31
13
OC
UL
34
Variable
32
en
0)
X
l=
16
0)
«-•
"~DC~"
*-•
£
52
Variable
Single Family Multiple Commercial
Residences Dwellings Establishments
FIGURE 14: FINANCING MODES, BY SERVICE RECIPIENTS, 1975 51/
User fees are more likely to be the node of payrrent for irultiple unit
dwellings and for corrmercial establishments than for small residences.
Flat fees are much more widely used than variable fees for small
residences, but the reverse is true for commercial establishments.
This may be explained by the fact that there is nuch variation in the
amount of service required by commercial establishments, while small
residences have relatively uniform and low volume service needs. 52/
APPENDIX G lists the prevalence of payment nodes for systems
serving single family residences by city characteristics. A number
of conclusions can be drawn from these data. First, larger cities
finance solid waste handling through taxes more frequently than through
user fees.
Approximately 13 percent of the cities with populations less than
250,000 utilize variable fees, with cities above that size using them
somewhat more frequently. By and large, central cities depend on taxes
while suburban areas charge a flat rate fee. User fees are more often
collected in the South and West than in the Northeast and North Central
regions of the country.
22
-------
One final observation from the data in APPENDIX G is that variable
fees are nuch more common under franchise and private arrangements
than under municipal or contract arrangements. This would seem to indicate
either that franchise and private collection systeirs offer residents
a wider choice of service options, or that they are more likely than
municipal systems to price their services to reflect the costs of
providing service.
Effect of Mode of Payment on the Cost of Collection
The direct effects of payment mode on the cost of administering
solid waste services include primarily:
1) administrative costs, and
2) the federal income tax status of the payment
The administrative costs to be discussed are billing, accounting,
metering, and monitoring and enforcement. In a general sense, the closer
the design of a user charge is to being an efficient pricing mechanism,
the relatively more expensive it will be to collect that charge. For
both flat rate and variable fees, a small expense will be incurred
for accounting that would not be necessary if the system were financed
out of the general fund. With a variable fee structure, additional
metering and monitoring activities must be performed that are not
necessary with a flat fee or a tax and this, too, adds minor expense.
But the major direct effect of the mode of payment on the cost of collection
is with respect to the cost of billing.
There are three major billing alternatives in current use to charge
for solid waste collection. They are "no billing" (as when financing
is through general revenues or a metered bag system is being utilized),
combination billing with other services, and separate, direct billing
for solid waste services. Of these three alternatives "no billing"
is least expensive, followed by combination billing, and then separate
billing, the most expensive. On the average, combination billing costs
amount to less than 4 percent of total cost. However, separate billing,
which is necessitated by a franchise or private collection arrangement,
has been reported to be as much as 10-15 percent of the cost of refuse
collection in several situations. 53/
With respect to the income tax status of the payment, it is "less
costly" to the service recipient if the service is financed through taxes
than through local user fees because the local property tax is deductible
for federal income tax purposes while the user fee is not. So, for
example, if a taxpayer is in a 20 percent marginal tax bracket, for
every dollar he pays for local services he receives a 20 cent "rebate"
from the federal government. 54/ This provides a fairly substantial
incentive to finance municipal solid waste handling though tax revenues.
23
-------
Adequacy of Fluids Collected by User Pee Systems
The Columbia University survey examined the following issue: "Does
a city tend to make money when it finances solid waste services with a
user fee, to break even, or to subsidize the service (through taxes)
by charging less than the full cost?"
Thirty-seven cities in the sample had municipal collection arrangements
and levied local user fees. The average ratio of collection cost to
user charge was 1.26:1; that is, actual cost was more than 25 percent
greater than price charged. In the thirteen cities with contract
collection arrangements, the average ratio was .96:1. 55/
One would expect the ratio of cost to user fee to be less than
1.0 because the cost, as calculated, excluded disposal costs. Presumably,
a user fee would be set to cover both collection and disposal of
solid waste materials. However, from the Columbia study, one finds
that, on the average, in communities with municipal collection systems,
solid waste handling is subsidized by approximately 20 percent.
The explanation for this might be in the fact that cities with
municipal collection do not know how much it costs, while cities with
contract collection do. When collection is contracted, the cost is
stated in a public document. However, cities with municipal collection
have cost accounting practices which by their nature result in- a failure
to indicate the full cost of service. 56/ The Coluirbia University survey
compared budgeted costs with actual costs in 68 cities with municipal
collection arrangements, and found that, on average, actual cost was
30 percent greater than the cost shown in the budget. 57/
The preceding discussion raises the issue of how solid waste costs
are determined and allocated in local budgeting systems. Difficulties
arise in allocating collection costs because many municipal accounting
procedures have, for example, "fringe benefit" accounts or capital accounts
which are not function specific. According to the Columbia University
data, these two categories together account, on the average, for 18 percent
of total collection cost. With respect to disposal costs, the same kind
of difficulties arise. This explains why many comnunities do not have
accurate estimates of their collection and disposal costs.
-------
REFERENCES
]/ E.S. Savas, ed., The Organization and Efficiency of Solid Waste
Collection (Lexington, D.C. Heath & Co., 1977), p.45.
2/ U.S.E.P.A., Office of Solid Waste, Fourth Report to Congress;
Resource Recovery and Waste Reduction (U.S.E.P.A., SW-600, Washington,
1977), p.20; and estimates by Franklin Associates, Ltd., for the Resource
Recovery Division, Office of Solid Waste, U.S. Environmental Protection Agency.
3/ U.S.E.P.A., Office of Solid Waste, Draft Envirprynental Impact
Statement; Proposed Regulation Criteria for Classification of Solid
Waste Disposal Facilities (U.S.E.P.A., Washington, 1978), p.I-19.
4/ See APPENDIX A and E.S. Savas, ed., Pie Organization and Efficiency
of Solid Waste Collection, p.48.
I/ Ibid.
6/ See APPENDICES B and C.
T/ "An overview of the Land Disposal Problem: 1977," Waste Age
Magazine (Niles, 111., Three Sons Publishing Co., Jan. 1977),
pp. 21-28.
8/ Thomas Hopper, Municipal Incinerator ^Enforcement Manual
(Prepared for Division of Stationary Source Enforcement, USEPA,
October 1976), p.l.
9/ Calculated by Barbara Stevens for the Resource Conservation
Committee from the original Columbia University Survey data.
10/ See Section IV - ACTUAL COST FACTORS IN SOLID WASTE HANDLING -
for a discussion of this topic.
ll/ Jacob Beachey and Robert Hunt, Resource Recovery Plant Costs
(Prepared for U.S.E.P.A., February 1978), p.5.
12/ See APPENDIX G.
1_3/ E.S. Savas, Daniel Baunol, and Wm. A. Wells, "Financing Solid
Waste Collection", in Savas, ed., The Organization and Efficiency of
Solid Waste Collection, p.81.
14/ See APPENDIX G.
15/ Baumol et al, "Financing Solid Waste Collection", in Savas,
ed., The Organization and Efficiency of Solid Waste Collection, p.94.
25
-------
16/ U.S.E.P.A. - O.S.W., Fpurth Report to Congress; Resource Recovery
and Waste Reduction, p.13. and estimates by Franklin Associates, Ltd.,
for the Resource Recovery Div., OSW, USEPA, January 1978.
1_7/ Applied Management Sciences, Inc., The Private Sector in Solid
Waste Management; a Pjcofile of its Resources and Contribution to Collection
and Disposal (v.2., Analysis of Data, Environmental Protection Publication
SW-51d. 1., Washington, U.S. Environmental Protection Agency, 1973); and
Frank A. Smith, Comparative Estimates of Pogt-Consumer Solid Waste
(Environmental Protection Publication SW-148, Washington, U.S. Environmental
Protection Agency, 1975), p.14.
IB/ U.S.E.P.A. - O.S.W., Fpurth Report to Congress, p. 15.
19/ Office of Solid Waste, Resource Recovery Division, and Franklin
Associates, Ltd., Revised February 1977.
20/ Ibid., p.20.
21/ U.S.E.P.A. - O.S.W., Draft Environmental Impact Statement, p. 1-19.
22/ Ibid.
23/
of Soli<
Data compiled from : E.S. Savas, ed., The Organization and Efficiency
id Waste Collection, p.56.
24/ Ibid.
25/ Ibid., pp. 68-69.
26/ Ibid.
27/ Ibid., pp.70-71.
2B/ Ibid., p.51
29/ David Rimberg, Municipal Solid Waste Management (Park Ridge,
N.J., Noyes Data Corp., 1975i), p.50. In the regulations promulgated
under Section 4004a of the Resource Conservation and Recovery Act,
which have not yet been finalized. EPA proposes a somewhat more rigorous
definition of sanitary landfilling. This can be found in 40 Code of
Federal Regulations, Part 257.
30/ Urban Data Services, International City Management Association,
Report 5/75, Local, Government Solid Waste Practices, p. 3.
31/ "An Overview of the Land Disposal Problem: 1977", Waste Age
Magazine, pp. 21-28.
26
-------
32/ U.S.E.P.A. - O.S.W;, Draft Environmental Impact Statement, p. 1-19.
33/ Estimates by Franklin Associates, Ltd., for Resource Recovery
Division, Office of Solid Waste, U.S. Environmental Protection Agency.
34/ Calculated by Barbara Stevens for the Resource Conservation
Coirmittee from the original Columbia University Survey data.
35/ The collection costs reported here were calculated for municipalities
based on their actual costs. Disposal costs were obtained only for
cities served by private firms, and the cost reported was the fee
paid by the firm for refuse disposal. Thus, these disposal cost
figures represent the cost to the service recipient, not necessarily
the cost to the firm.
36/ Calculated by Barbara Stevens for the Resource Conservation
Coirmittee from the original Columbia University Survey data.
37/ Barbara Stevens, "Service Arrangement and the Cost of Residential
Refuse Collection", in Savas, ed., The Organization and Efficiency of Solid
Waste Cpllection, p. 12. The only data reported was for once-a-week
collection.ThTs does not, however, imply that for other frequencies
of collection the pattern of cost differentials would be different.
38/ Barbara Stevens, "Scale, Market Structure, and the Cost of
Refuse Collection," Review of Economics and Statistics, August 1978.
39/ Ibid.
£0/ Office of Solid Waste, U.S. EPA, Draft Environmental Impact
Statement, p. 1-20. One-third of existing sites are already in compliance
and, therefore, would face no incremental costs due to the standards.
This figure is an average nationwide cost; many sites will have
significantly higher costs.
41/ Beachey and Hunt, Resource Recovery Plant Costs, p.5.
_4_2/ Based on the best engineering estimates.
43/ Beachey and Hunt, Resource Recovery Plant Costs, p.5.
44/ Data compiled from: Barbara Stevens, "The Cost of Residential
Refuse Collection", in Savas, The Organization and Efficiency of
Solid Waste Collection, p.103.
45/ Ibid, p.102.
46/ Ibid.
47/ John Thompson, Economics of landfill location, (O.S.W.M.P.,
USEPA), p.4.
48/ Beachey and Hunt, Resource Recovery Plant Costs, p.14.
27'
-------
49/ Franklin Associates, Ltd. , Estimates for Resource Recovery
Division, Office of Solid Waste, U.S.E.P.A., 1978.
SO/ Data conpiled from: E.S. Savas, Daniel Baunol, and Wro. A. Wells,
"Financing Solid Waste Collection", in Savas, ed., Ihe Organization and Efficiency
of Solid Waste Collection, p. 80.
51/ Ibid. , p.82.
52/ Ibid., p.80.
53/ Ibid., p.87.
54/ P. Kenper and M. Quigley, The Econonacs of Refuse Cpllectionj
(Cambridge, Mass., Bal linger Publishing, 1975), p. 55.
55/ Bauirol et. al., "Financing Solid Waste Collection", in Savas,
ed., 3he Organization and Efficiency of Solid Waste Collection,
p. 93.
Ibid., p.94.
57/ Ibid. , p.200.
28
-------
APPENDIX A
ARRANGEMENTS FOR COLLECTION OF PESIDENTIAL
MIXED REFUSE, BY CITY CHARACTERISTICS
TOTAL SELF-
I SYSTEMS MUNICIPAL CONTRACT FRANCHISE PRIVATE SERVICE OTHER
TOTAL
CITY SIZE
a 250,000
50,000-249,999
10,000-49,999
2,500-9,999
GEOGRAPHIC REGION**
Northeast
North Central
South
West
CITY TYPE
Central City
Suburban
2,540*
40
272
707
1,521
983
720
470
376
313
2,227
30%
65
55
35
23
19
20
73
27
61
26
17%
5
11
22
16
22
16
10
20
9
18
6%
5
7
8
6
2
4
3
24
5
6
31%
13
16
24
37
39
46
7
10
15
33
15%
5
10
11
17
18
15
6
18
8
16
1%
7
1
0
1
0
1
1
1
2
1
*The numbers do not sum to 2,060 because some communities have more than one type of
collection arrangement.
** The states included in each geographic region are as follows:
Northeast quadrant:
Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont,
New Jersey, New York, Pennsylvania
North Central quadrant:
Illinois, Indiana, Michigan, Ohio, Wisconsin, Iowa, Kansas, Minnesota,
Missouri, Nebraska, North Dakota, South Dakota
Southern quadrant:
Delaware, Florida, Georgia, Maryland, North Carolina, South Carolina,
Virginia, West Virginia, Alabama, Kentucky, Mississippi, Tennessee,
Arkansas, Louisiana, Oklahoma, Texas
Western quadrant:
Arizona, Colorado, Idaho, Montana, Nevada, New Mexico, Utah,
Wyoming, Alaska, California, Hawaii, Oregon, Washington
Source: Savas, ed.. The Organization and Efficiency of Solid Waste Collection,
(Lexington, D.C. Heath & Co., 1977), p.56.
29
-------
APPENDIX B
RESIDENTIAL SEWICE LEVELS-FREQUENCY OP COLLECTION
1
TOTAL
CITY SIZE
£250,000
50,000-249,999
10,000-49,999
2,500-9,999
GEOGRAPHIC REGION
Northeast
North Central
South
West
CITY TYPE
Central City
Suburban
ARRANGEMENT
Municipal
Contract
Franchise
Private
Other
Source: E.S. Savas,
TOTAL
CITIES
2,091
38
235
611
1,207
776
583
440
292
277
1,814
769
436
151
711
19
ed. , The
MORE THAN
TWICEAK
2%
3
2
1
2
2
0
3
0
2
2
3
2
0
1
0
Organization
THICE/WK
31%
52
40
34
27
23
12
75
23
45
29
46
34
19
15
36
and Efficient
ONCE/UK
56*
37
48
56
60
64
76
16
65
45
66
47
57
70
66
53
y/ of Solid
LESS THAN
ONCE/UK VARIOUS
1%
0
0
0
1
1
1
0
0
0
1
1
1
0
0
0
Waste Collection
9%
8
10
9
10
10
11
6
12
8
10
3
6
11
18
10
(Lexington, D.C. Heath & Co., 1977) pp. 68-6'
30
-------
APPENDIX C
RESIDENTIAL SERVICE LEVELS-LOCATION OF PICK-UP
TOTAL
CITY SIZE
i 250 ,000
50,000-249,999
10,000-49,999
2,500-9,999
GEOGRAPHIC REGION
Northeast
North Central
South
West
CITY TYPE
Central City
Suburban
ARRANGEMENT
Municipal
Contract
Franchise
Private
Other
TOTAL
S CITIES
2,084
38
236
607
1,203
770
582
440
292
278
1,806
768
435
151
709
19
YARD
12%
13
17
12
12
10
9
22
7
15
11
16
8
15
9
0
CURB/ALLEY
53%
26
43
53
56
64
52
40
46
42
55
50
71
40
48
74
VARIOUS
33%
55
39
33
31
24
38
35
46
41
32
34
21
44
38
26
OTHER
2%
6
1
2
1
2
1
3
1
2
2
0
0
1
5
0
Source: E.S. Savas, ed., The Organization and Efficiency of Folid Waste Collection
E.S. Savas, ed., The Organization and Efficiency p
(Lexington, D.C. Heath & Co. ,1977), pp. 70-71.
31
-------
APPENDIX D
CHARACTERISTICS OF PRIMARY, MUNICIPALLY
OPERATED, LANDFILL SITES, 1975
COVEP FREQUENCY
TOTAL
CITY SIZE
> 250, 000
50,000-249,999
10,000-49,999
GEOGRAPHIC REGION
Northeast
North Central
South
West
CITY TYPE
Central City
Suburban
Independent
TOTAL
CITY SIZE
•1:250,000
50,000-249,999
10,000-49,999
GEOGRAPHIC REGION
Northeast
North Central
South
West
CITY TYPE
Central City
Suburban
Independent
TOTAL
# CITIES
442
19
97
326
102
109
170
61
124
163
155
LITTER
CONTROL
66%
89
73
62
63
64
65
75
77
60
64
FORMAL METHANE GAS EVERY EVERY OTHER LESS
PLAN CONTROL DAY DAY FREQUENTLY
49%
74
54
47
52
46
48
54
55
45
50
7%
26
11
5
9
6
6
11
11
5
7
LEACHATE
CONTROL
29%
42
38
26
32
32
28
25
37
25
28
89%
89
87
87
87
90
91
92
90
89
87
LEACHATE
TREATMENT
8%
16
4
8
10
6
8
7
10
5
10
37%
0
3
3
3
2
2
7
1
4
3
7%
11
9
6
7
4
7
11
10
4
8
IMPERMEABLE
MEMBRANE
5%
5
13
3
5
5
7
2
11
2
3
Source: Urban Data Service, International City Management Association, Report
5/75, Local Government Solid Waste Practices, p.2.
32
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APPENDIX E
SUMMARY OF INCINERATOR USE, 1978
COMPLIANCE COMPLIANCE
I INCINERATORS* BURNED/DAY CAPACITY/DAY STATUS SCHEDULE
(mean tons) (mean tons) IN OUT YES NO**
TOTAL
ClrTSIZE
.> 250,000
50,000-249,999
10,000-49,999
2.500-9,999
GEOGRAPHIC REGION
Northeast
North Central
South
west
77
20
20
26
11
46
16
14
1
296
575
232
162
222
237
350
510
150
378
654
330
234
306
325
637
462
150
30
7
5
11
7
16
5
8
1
42
13
15
15
4
30
11
6
0
21
7
7
6
1
18
3
0
0
20
2
7
8
3
11
5
4
0
*This list does not include waterwall combosion incinerators, which recover energy
from nunicipal solid waste. The five of those which are in operation in this country
have been included in the list of resource recovery facilities.
**Por some out-of-compliance facilities, it was not known whether they had been placed
on a compliance schedule.
Source: Data compiled from: Thomas G. Hooper, Municipal Incinerator Enforcement Manual,
(Prepared for Division of Stationary Source Enforcement, EPA, October 1976),
pp. 5-7. Updated May, 1978.
33
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APPENDIX F
SUMMARY OF MIXED WASTE, RESOURCE RECOVERY
FACILITIES IMPLEMENTATION, 1978
LOCATION
TYPE*
THROUGHPUT**
PRODUCTS/MARKET
SYSTEMS IN OPERATION (27):
Altoona, PA
Ames, IA
Baltimore, MD
Baltimore Co., MD(0)***
Blytheville,AR
Braintree,MA
Chicago,IL (SW)
Chicago,IL (NW)
Chicago, IL (CRAWFORD)
E.Bridgewater,MA***
Franklin,OH
Groveton,NH
Harrisburg,PA
Lane Co., OR
Merrick,NY
Miami,FL
Milwaukee,WI
Nashville,TN
New Orleans,LA***
Norfolk,VA
N. Little Rock, AR
Oceanside,NY
Palos Verdes,CA
Pcnpano Beach, FL
San Diego Co., CA(D)
Saugus,MA
SiloaiP Springs,AR
(TPD)
Compost 30
RDF 170
Pyrolysis 800
FDF 550
MCU 50
WWC(u) 240
RWI 1,200
WWC(u) 1,600
RDF 1,000
RDF 160
Wet pulp/sludge 50
MCU 30
WWC(u) 720
RDF 500
RWI 600
RWI 900
RDF 1,200
WWC(u) 400
Materials 650
WWC(u) 360
PWI/WWC 750
Methane Recovery 50-100
Methane Production -
Pyrolysis 200
wwc
MCU
1,200
20
Hunus
RDF,utility,Fe, paper
Steam/utility
FDF,Fe,Al,glass
Steam/Process
Steam/process
Steam/industrial park
RDF/btility,Fe
RDF
Coincineration
Steam/process
Steam
RDF/indus try, Fe
Electr icity(in-house)
Steam/hospital
RDF,Fe
Steam
Fe,glass, Al
Steam
Steair
Gas/utility,Fe
Methane
Liquid fuel/utility,
Fe,Al,glass
Steam/process,Fe
Steam/canning industry
-------
APPENDIX P
(con't)
LOCATION
TYPE*
THPOUQffUT**
PRODUCTS/MARKET
(TPD)
SYSTEMS UNDER CONSTRICTION (6):
Akron ,CH
Bridgeport, CT
Dade Co., FL
Heitpstead,NY
Monroe County, NY
Portsmouth, VA
WWC(P)
RDF
WWC(P)
WWC(P)
RDF
WWC(u)
1,000
1,800
3,000
2,000
2,000
160
Steam/heating and cooling
RDF, Fe,Al, glass
Electr icity /utility ,
Fe,Al, glass
Electr icity /utility
Fe,Al, glass
RDF/utility, Fe, Al,
glass
Steam/heating loop
*RDF-refuse derived fuel; VWC(u)-waterwall combustion, unprocessed waste;
WWC(P) - waterwall combustion, processed waste; RWI-refactory wall incinerator
with waste heat boiler; MCU-modular combustion unit.
**Average quantity of waste processed
***Deironstration plant
Source: L.B. McEwen,Jr., Waste Reduction and Resource Recovery Activities;
A Mat ion-wide Survey, (EPA Publication SW-142, Washington,
USGPO, 1977), pp.1-2. Updated, May 1978 with EPA, Resource
Recovery Division estimates.
35
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APPENDIX G
MODE OF PAYMENT FROM SINGLE FAMILY RESIDENCES
TOTAL
t CITIES TAX FLAT FEE VARIABLE FEE
TOTAL 2,069 36% 51% 13%
CITY SIZE
> 250,000 38 55 29 16
50,000-249,999 238 50 37 13
10,000-49.999 598 41 46 13
2,500-9,999 1,195 30 56 13
GEOGRAPHIC REGION
Northeast 163 47 43 10
North Central 577 35 51 14
South 438 36 58 6
West 291 11 61 28
CITY TYPE
Central City 279 54 34 12
Suburban 1.790 33 54 13
ARRANGEMENT
Municipal
Contract
Franchise
Private
763
430
151
707
58
67
0
0
38
27
66
77
4
6
34
23
Source: E.S. Savas, Daniel Baumol and Williaip A. Wells, "Financing Solid Waste
Collection", in E.S. Savas, ed., The Organization and Efficiency of Solid Waste
Collection (Lexington,D.C. Heath & Co., 1977), p.82.
36
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STAFF BACKGROUND PAPER NO. 8
Revised June 15, 1978
RATIONALE FOR NATIONAL SOLID HASTE
DISPOSAL CHARGE LEGISLATION
I. Introduction
As ever increasing demands for natural resources cause low-cost
domestic reserves to be depleted, there is a growing interest in improving
the efficiency of resource use and in conserving resources. A market sys-
tem efficiently allocates scarce resources when every production and con-
sumption activity bears its full social costs. Full-cost pricing is the
procedure which normally is used to ensure that decisions to produce and
consume are optimal from a resource consumption standpoint. However, for
a variety of reasons, municipal solid waste management services often are
not priced in accordance with the exact cost of providing them to individ-
ual waste discarders.
A national solid waste disposal charge has been proposed as a means
of pricing the consumer product portion of municipal solid waste and im-
proving natural resource utilization. The charge has been the subject of
several Congressional hearings and is currently under consideration as part
of the "National Materials Policy Act" bills (S. 1281 and H.R. 1009).
The Resource Conservation and Recovery Act of 1976 (P.L. 94-580)
specifically directed the Resource Conservation Committee to conduct an
investigation of:
... the appropriateness and feasibility of employing
as a resource conservation strategy the imposition of
solid waste management charges on consumer products,
which charges would reflect the costs of solid waste
management services, litter pickup, the value of
recoverable components of such product, final dis-
posal, and any social value associated with the non-
recycling or uncontrolled disposal of such product ...
This paper presents the conceptual rationale for the adoption of
a national solid waste disposal (or management) charge. The empirical
significance of the problems addressed by the disposal charge and the
ability of the charge proposal to reduce these problems are being studied
by the RCC staff. The results of the staff analyses will be presented in
a future Background Paper on the estimated benefits and costs of the
proposed charge initiative.
37
-------
In this paper and in other work performed by the Resource Conserva-
tion Committee, a "solid waste disposal charge" is defined by the following
specific characteristics:
1) it would be national, rather than regional. State, or
local in its initiation and application;
2) it would be applied at a stage of a product's manufac-
ture or distribution prior to its final use, rather
than at the waste generation or discard point; and
3} its magnitude would be based on the cost of providing
municipal solid waste management services.
Accordingly, the proposed charge differs from a local user fee both in scope
and in its application point. It differs from a revenue-raising excise tax
in that the charge rate is based on the cost of managing a public service.
The issues associated with the exact design of the proposed charge initia-
tive are presented in Staff Background Paper No. 9.
Section II of this paper provides information about the solid waste
generation and natural resource consumption problem. Section III discusses
the importance of pricing municipal solid waste management services and
presents the rationale for solid waste disposal charge legislation. Section
IV briefly reviews the non-pricing resource conservation alternatives to a
national disposal charge approach.
r
38
-------
II. Statement of the Problem
Residential and commercial solid waste generation now totals about
144 million tons annually, of which more than two-thirds is composed of
manufactured products and packaging materials. Although precise historical
data are lacking for most waste categories, analysis of consumption statis-
tics indicates that the product and packaging components of municipal wastes
have more than doubled since the early 1950's. Paper, glass, metals, plas-
tics, and rubber wastes have all increased dramatically since World War II.
The national trend is towards substantial future increases in solid waste
generation, and it is unlikely that increases in resource recovery will do
more than keep pace with the growth.I/
To a very significant degree, our high and rising levels of solid
waste generation are the natural result of an expansive, highly productive
market economy based on an abundance of accessible natural resources and
adjusted to the high labor costs consistent with a high standard of living.
This combination of cheap natural resources and expensive labor has encour-
aged the extensive use of materials and energy and discouraged the recovery
of materials and energy from waste.
The amount of the post-consumer solid waste stream which is not re-
cycled is a useful indicator of the rate of consumption of virgin natural
resources. A high-waste, low-recycle economy necessarily requires high
rates of domestic virgin raw material extraction and processing and/or
high raw material importation rates. The rapid consumption of virgin natu-
ral resources is not in a society's best interest if materials in the solid
waste stream can be efficiently and economically recycled and reused or if
the same products and services can be provided while using fewer virgin
materials and incurring the same social costs.
One of the most important costs not included in decisions regarding
the use of virgin material is the cost of the material's collection and
disposal once the product from which it is made is no longer desired for
its original, intended use. At present, collection and disposal costs re-
lated to consumer products are usually financed indirectly and collectively
either through general real estate taxes or through fixed periodic levies
on each discarder. The amount of the levy is often unrelated in any pre-
cise way to the total generation of wastes.
The information in Table I indicates that while over half of the
cost of commercial establishment solid waste management is financed through
service level or quantity-related user fees, over 86% of all small resi-
dences pay for municipal solid waste services through taxes or flat fee
I/ EPA, Fourth Report to Congress; Resource Recovery and Waste Reduction,
1977, pp. 2-3.
39
-------
financing methods. Thus, individual waste discarders are generally not
charged in proportion to their total waste contribution; individual consu-
mer products are virtually never charged as such. Since the amount charged
individuals using municipal services is generally not directly related to
the quantity of waste they discard, there is a substantial implicit subsidy
for the consumption of consumer products and the materials which compose
them at the present time.
Table I
Current Methods of Financing Municipal Solid Waste Management
(percent of communities sampled)
Service Recipient Taxes Flat Fee Variable Fee* Unknown
Small Residences 42.4% 43.8% 13.4% 0.4%
Multiple Dwellings 34.0% 31.0% 33.7% 1.3%
Commercial Establishments 31.8% 16.3% 51.8% 0.1%
* Varies in relation to service level provided or quantity of waste
removed.
SOURCE: 2,060 communities surveyed by Columbia University
in 1974. Taken from E. S. Savas, The Organization
and Efficiency of Solid Waste Collection, Health
& Co., 1977, p. 80.
Full-cost pricing is the procedure normally used to ensure that
decisions to produce and consume are optimal from a resource consumption
standpoint. When some resources are not fully-priced, decision-makers
generally use more of these resources than they should because the total
cost of their use is either not perceived or is born by someone else in
the society.
EPA estimates that the average cost of collection and disposal of
post-consumer municipal solid waste in 1976 was close to $30 per ton, or
almost $4 billion a year for the U.S. as a whole.^/ These costs include
only direct expenditures (both public and private) relating to existing
disposal practices, which are considered environmentally inadequate for the
majority of U.S. communities.
Collection and disposal costs will rise due to the growth in the
size of the waste stream, the increase in land values, the longer haul
distances to new disposal sites, and the increased requirements for envi-
ronmental safeguards in landfills and emission controls on incinerators.
2/ Ibid p. 4.
-------
Unless there is an increase in the use of quantity-related local user fees
over time, the subsidy for resource use implicit in the current financing
approach will also increase.
Because municipal solid waste management services often are not
priced in accordance with the cost of providing them to individual waste
discarders, the cost of a consumer product's disposal is often not consid-
ered at any decision point in. the product's production and consumption
life-cycle. The probable result is a continuing greater-than-optimal con-
sumption of these products and of the natural resources required to manu-
facture them.
41
-------
III. Rationale for a National Solid Waste Disposal Charge
Economists have long argued that environmental damage costs should
be included in "total social cost" pricing, in addition to the normally
priced labor, capital, and other resources, if resource use is to be opti-
mal* The costs of collecting and disposing of the discarded product when
it enters the solid waste stream could, by similar reasoning, be included
in the sales price of each product.
If all products had to bear a charge which reflected the full cost
of their final disposal, there would be a growing incentive for manufac-
turers to find ways to reduce the product's public disposal costs. This
incentive could be expected to lead to product design changes and technol-
ogical innovation which would reduce total natural resource consumption.
Also, under full-cost pricing, consumers might shift slightly their pur-
chasing more towards low-waste items (returnable containers, reusable
tableware, longer-lived durable goods) and manufacturers might give some-
what more emphasis to recovering materials as an alternative to paying for
their disposal. The end result would be an improvement in natural resource
utilization.
Full-cost pricing of solid waste management services is consistent
with at least four of the five policy design criteria adopted by the Re-
source Conservation Committee :V
1) Policies should be consistent with free-market principles
2) Policies should be consistent with the polluter-pays
principle
3) Policies should be socially and economically equitable
4) Policies should improve economic efficiency
5) Policies should be administratively feasible and low in
cost relative to the benefits derived
The fifth criteria, that implementation of policies entail low administra-
tive cost, is a policy design goal, but it may be inconsistent with some
very precise pricing approaches. Also, if compromises are made to lower
the administrative cost of pricing services, then some of the consistency
of the pricing alternatives with the other four policy design criteria
probably will be lost.
3/ RCC, Implementation Plan for the Resource Conservation Committee, April
1977, pp. 13-15.~
1*2
-------
A comparison of the characteristics of "ideal", flat fee, local user
fee, and national disposal charge pricing alternatives is shown in Table
II.4/ An ideal pricing approach would be one in which each product bore
a charge which was related to the incremental cost of managing its collec-
tion and disposal in the area where it was discarded. If a "discarded"
product were so valuable as to entail no net public disposal costs, it
would bear no charge.
It is clear from Table II that none of the possible pricing alterna-
tives are ideal. The flat fee provides no incentive to improve the use of
natural resources. Both the local user fee and the national disposal charge
are conceptually superior to the flat fee from a natural resource conserva-
tion standpoint, but these pricing systems have other drawbacks. The local
user fee is somewhat expensive to administer and provides an incentive for
illicit dumping. The efficiency of the national disposal charge is limited
because it does not vary as the local cost of solid waste management varies
and because disposal costs would be internalized twice in those communities
where services were already correctly priced.
At the local level the Federal government could do little more than
encourage the adoption of user fees. The decision to implement a local
user fee must be made at the local level where other concerns may seem more
important than how the nation uses natural resources. The advantage of a
national disposal charge is that it can be implemented at the national
level to bring about the national goal of improving natural resource utili-
zation. Also, a national disposal charge would provide a clear signal to
manufacturers that the public disposal costs associated with their products
are also their concern.
4/ The term "local user fee" is used here to describe a pricing system
which varies the amount charged the individual discarder based on the
level of service provided and the quantity of waste collected.
43
-------
Table II
Characteristics of Municipal Solid Waste
Management Pricing Alternatives*
Characteristics
Charges individual discarder
the exact cost of managing
his waste:
Price is based on
quantity discarded
Price is based on
local costs, includ-
ing service levels
Price is related to
composition of dis-
carder 's waste
Has low administrative cost
Provides an incentive to
litter or dump
Improves natural
resource utilization
Ideal
Pricing
Uniform
Flat Fee
Local User
Fee**
National
Disposal
Charge
YES
YES
YES
YES
NO
YES
NO
YES
NO
YES
NO
NO
YES
YES
HO
Somewhat***
YES
Somewhat
YES
NO
YES
YES****
NO
Somewhat
* Property taxes are not considered a "pricing" alternative.
** Some local user fees are structured such that they are
more like a flat fee in practice. The alternative evalu-
ated here is the metered bag, which prices services based
on the volume of waste discarded.
*** Metered bags include an incremental "administrative" cost
of about 7(*/bag.j>/
**** Depends on the complexity of the charge system.
V Urban Systems Research & Engineering, Analysis of Local Solid Waste
Pricing Options, draft to EPA, 3/22/78, p. 24.
44
-------
IV. Non-Pricing Resource Conservation Alternatives
There are several alternatives to improving the pricing of municipal
solid waste management services which could lead to increased virgin mate-
rial resource conservation. The non-pricing alternatives could be designed
to bring about some of the desirable effects of pricing, but none of the
alternatives match the Resource Conservation Committee's policy design
criteria as well as the pricing approaches. The principal alternatives
are:
• Consumption or severance taxes on virgin materials
• Recycling subsidies
• Regulations to increase the recycled material content
in products
• Deposit or bounty systems
Consumption Taxes on Virgin Materials
A consumption tax on virgin materials would have some similarities
to a national disposal charge. It could not be directly related to munici-
pal solid waste management costs except in a very aggregate sense, but such
a tax might be related to environmental or other social costs in some way.
By increasing virgin material prices, it would both reduce natural resource
use and increase the use of recovered (secondary) materials. Revenues from
such a tax could be used for a variety of purposes or contributed to the
general tax fund. Since the tax would raise the present cost of consumer
products primarily for the purpose of conserving material resources for
future use, difficult political decisions would have to be made to deter-
mine either the appropriate level of the tax or the amount of resources
which should be conserved.
Recycling Subsidies
Recycling subsidies could be used to directly encourage the recycl-
ing of materials. Public revenues collected from the general taxpayer
would be the probable source of the incentive. This use of general funds
to address a problem associated with the production and consumption of
specific products violates the principle (agreed to by the Committee in its
First Report) that those responsible for an environmental problem should
bear the costs associated with its management. Also, subsidies would not
internalize disposal costs, so consumer products would continue to be
underpriced, and the total consumption of natural resources would continue
to be excessive.
45
-------
Subsidies could be provided in the form of grants to finance resource
recovery facilities. Resource recovery facilities are capital-intensive
and have economies of scale which make them an expensive means of recover-
ing materials in rural or small urban areas. Even if such facilities were
constructed, of course, there would be no guarantee that recovered materials
would be marketable. Experience with such facilities to date indicates that
factors such as product quality and economics make marketing recovered
resources a difficult task.
Regulations on Recycled Material Content
Regulations could be promulgated which would specify the minimum
amount of recycled material to be used in consumer products. Regulations
would ensure that recovered materials were substituted for virgin materials.
However, there are numerous problems with this alternative. The regulations
would have to be product-specific to be consistent with the technological
requirements associated with product manufacture. Such regulations could
block technological progress and innovation and might create unexpected and
undesirable incentives with respect to product development. Also, there
could be no guarantee that a sufficient amount of recovered materials would
always be available at reasonable prices to make the products consumers
desire. The unavailability of required materials at reasonable prices
could cause serious inefficiencies in the production system. Given the
range of products produced in this country, the monitoring and enforcement
of such regulations could also be difficult.
Deposit or Bounty Systems
Under certain conditions deposits or bounties on consumer products
could be an alternative to user fee or subsidy systems for the promotion of
the reuse or recycling of materials. A deposit on a product provides a
mechanism for the return of used products to a central point from where it
may be economic to reuse or recycle them. The basic rationale behind a
deposit system is that the buyers and the sellers of a product should have
the responsibility for its proper disposal after it is used.
Deposits are often proposed for items which frequently are littered,
such as beverage containers, refrigerators, tires, and automobiles, because
recycling subsidies and product charges are often not large enough to make
the collection of individual littered items economically feasible. Deposits
or bounties are generally not appropriate for products which are seldom
littered or which readily decompose because they encourage the development
of separate collection and disposal systems, which may be a more expensive
way to manage wastes than existing municipal systems.
-------
STAFF BACKGROUND PAPER NO. 9
Revised June 26, 1978
SOLID WASTE DISPOSAL CHARGE
DESIGN ISSUES
Introduction
The levy of a charge on products entering the municipal solid waste
stream has been proposed as a way to improve the pricing of solid waste
management services. The Resource Conservation Committee is assessing the
desirability of a national solid waste disposal charge in order to make
recommendations to the President and the Congress. The rationale for the
disposal charge is presented in Staff Paper No. 8.
This paper reviews disposal charge design issues and compares possi-
ble options with the current Senate proposal on the topic, S. 1281, which
was introduced by Senator Gary Hart of Colorado. The RCC staff is currently
analyzing the design options presented in this paper to determine their
administrative feasibility and their implications with respect to the over-
all effect of the charge. The Resource Conservation Committee will make
policy recommendations on each of the design issues based on the staff
analysis and comments received from the public. Eleven major design issues
have been identified by the staff:
1. What products should be subject to the charge?
2. What type(s) of social costs or municipal services should
form the basis for the charge?
3. What pricing concept should be used to set the charge
level?
4. How should the charge level be determined for specific
product (or material) categories?
5. Should the charge be adjusted to account for geographical
cost variations?
6. Where should the charge be collected?
7. How should imports and exports be treated?
8. Should there be adjustments to the charge and/or credits
for resource recovery and recycling?
8a. How large should any recycling adjustments or credits be?
47
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- 2 -
9. What use should be made of revenues collected from the
solid waste disposal charge?
10. Should the introduction of the charge be phased in over time?
11. How should the level of the charge be adjusted over time?
Each of these issues is discussed below.
II. Design Issues
1. What Products Should be Subject to the Charge?
Ideally, the solid waste disposal charge would be levied on every-
thing entering the municipal solid waste stream. However, a national dis-
posal charge could only be levied on items which are sold as products, and
the waste stream includes other items. Municipal solid waste is a mixture
of dirt, lawn trimmings, leaves, food residues, old newspapers, magazines,
and packaging for food/ beverages, and other consumer products. Excluding
food residues, consumer product wastes made up 60 percent of total munici-
pal solid waste in 1975. Food residues were 18 percent of the total.*
The consumer product portion of municipal solid waste is shown in
Table I. Paper and paperboard make up 48 percent (by weight) of total
consumer product waste, and metal and glass containers compose another 23
percent of the total. None of the other product categories are as impor-
tant a component of municipal solid waste at the present time.
S. 1281 proposes that the charge apply to:
... rigid containers, flexible packaging, and all paper
products with the exception of building, construction,
and industrial grades.
This coverage includes paper and paperboard, glass containers, metal cans,
aluminum foil, and plastic packaging materials. Plastic and aluminum pack-
aging materials compose less than 4 percent of product wastes, but they
were included to ensure equal treatment among competing products.
Minimizing the number of establishments serving as charge collection
points is important from the standpoint of administrative cost. As shown
in Table I, the products included in S. 1281 are, with the exception of
* Environmental Protection Agency, Fourth Report to Congress on Resource
Recovery and Waste Reduction, 1977, pp. 14-15.
-------
TABLE 1
COMPOSITION OF THE NON-FOOD, CONSUMER PRODUCT
PORTION OF MUNICIPAL SOLID HASTE, 1975
Net Contribution
Product
Category
Paper and
Paperboard
Glass Containers
Metal Cans
Aluminum Foil
Plastic Products
Rubber Tires
Wood Packaging
Major Appliances
Furniture ,
Furnishings
Clothing, Footwear
Misc. Categories
Total Non-Food Products
to
Municipal
(io3
Tons)
37,195
12,150
5,680
230
2,635
(2,491)*
1,600
1,800
2,280
3,370
1,250
9,255
77,455
Waste
(Percent of
Non-Food
Products )
48.0
15.7
7.3
0.3
3.4
n.a.
2.1
2.3
2.9
4.3
1.6
11.9
100.0
Number of
Establishments
349
117
396
36
7,678
(3,300)*
206
1,160
1,083
80
17,356
N.A.
3
10 Tons Per
Establishment
106.6
103.8
14.3
6.4
0.3
(0.7)*
7.7
1.6
2.1
0.4
0.1
* 93% by value of all plastic products are shipped by the 3300 firms
employing more than 20 people.
Reference; Franklin Associates, Limited. Product Charge Design Issues;
"Analysis of Specific Product Categories for Inclusion Under
Product Charge Schemes." Draft Report, September 27, 1977,
pp. 2-3.
49
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plastics, produced by a relatively small number of establishments. The
inclusion of plastic packaging greatly increases the administrative com-
plexity of the solid waste disposal charge proposed in S. 1281.
S. 1281 excludes durable products, such as furniture and major
appliances. Durables differ from non-durable products in two respects:
they are not discarded for many years, which makes the appropriate charge
rate difficult to determine, and they are sometimes littered or abandoned
in alleys or along the roadside. As a result, a deposit or bounty mecha-
nism may be a more suitable way to deal with these kinds of products than
a solid waste disposal charge. Littered products impose a high per unit
solid waste management cost on municipalities. Consequently, if a deposit
or bounty mechanism is not used, durable products probably should be in-
cluded in any disposal charge initiative.
S. 1281 also excludes food products from the charge even though they
are normally purchased in the market place and make up a substantial por-
tion of the municipal solid waste stream. Food products apparently were
excluded for three reasons: only food residues ultimately become part of
municipal solid waste; food is a necessity and is often exempted from sales
and excise taxes; and the equitable administration of a charge on food
would be very complex.
Different processed and fresh foods make widely differing contribu-
tions to the municipal waste stream, and setting an appropriate charge on
different commodities would be very difficult. Fresh foods are produced
and distributed by a myriad of small establishments which could make the
collection of the charge very expensive.
However, if food products were excluded from a disposal charge, the
net effect would be to slightly encourage the use of fresh foods relative
to processed foods, because fresh foods use less of the packaging which
would be subject to the charge and fresh food processing waste would not
be subject to the charge. Any resulting shift from processed to fresh
food could be expected to decrease the packaging content and increase the
food waste content of the solid waste stream.
The exemption of published materials from the charge has been sug-
gested because of the importance of mass communications and education in a
democratic system and because publishing is a low profit margin industry.
However, the public has access to a wide variety of communications media,
and it can be argued that each media should bear its share of public costs.
Published materials make up a very large portion of the municipal waste
stream, and it may also be argued that these items should not receive dif-
ferent treatment than other paper products.
50
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OPTIONS
1. Levy the charge on rigid containers, flexible packaging, and all
paper products with the exception of building, construction and
industrial grades.
• This is the coverage proposed in S.1281. Except for plas-
tics it would be relatively easy to administer and covers
75% by weight of all non-food, consumer products.
2. Levy the charge on all non-durable, non-food products entering
the municipal solid waste stream.
• This would increase the coverage of the measure to over 90%
of all non-food consumer products, but it would increase
the administrative complexity of the initiative.
3. Levy the charge on all non-food products (including durables)
entering the municipal solid waste stream.
• This would increase the coverage to include durables, and it
would require special treatment of durable products to
account for their longer life-span.
4. Levy the charge on all products entering the municipal solid
waste stream.
• This would increase the coverage to include food products
which are a major portion of municipal solid waste, but it
would greatly increase the complexity of the initiative.
5. Exempt specific products from the charge (e.g., books).
• Other public policy objectives could provide a basis for the
specific exemption of certain products from the charge.
2. What Type(s) of Social Costs or Municipal Services Should Form
the Basis for the Charge?
The solid waste disposal charge has been developed around the con-
cept of pricing municipal services to cover their full social costs.
Several different cost elements could be used as the basis for pricing
municipal solid waste, including the cost of existing services, the cost of
environmentally "acceptable" services, the cost of litter management, and
the cost of environmental damage related to existing disposal practices.
[Other costs not related to municipal services, such as the "cost" of
import-dependence for certain materials, or other rationales, such as a
desire to neutralize the tax advantages of virgin materials, could also
provide the basis for a product charge.]
51
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S. 1281 does not discuss the pricing rationale used to develop a
charge rate. Rather, the bill specifies charge rates of 0.5£ per rigid
container and $26 per ton for all other products covered by the disposal
charge. At the time they were developed, the specified rates were related
to the average cost of municipal solid waste management services. Basing
the charge on the average cost of existing services would make estimation
of the charge relatively easy/ since the costs of a representative sample
of cities could be used to set the rate.
However, since current disposal practices create unacceptable water
pollution and other environmental problems, basing the disposal charge on
the cost of existing services may be inappropriate. One of the major
objectives of the Resource Conservation and Recovery Act of 1976 (RCRA) is
to upgrade current solid waste management practices. The cost of this
upgrading (probably $2-3 per ton) could be included as an element of the
charge. Including this cost would increase the complexity of implementing
the charge program because the administering agency would have to first
define "environmentally acceptable disposal" and then estimate its cost for
a sample of representative communities. Over time as RCRA is implemented,
existing waste management services will become more environmentally accept-
able, and the initial cost differential between existing and environmentally
acceptable services will disappear. Also, if the charge were to be phased
in over time, the initial magnitude of the environmental cost element
would be very small.
An attempt could be made to quantify the environmental and aesthetic
damage associated with current municipal solid waste management practices
and to include this cost element in the basis for the charge. However, the
successful implementation of RCRA will reduce the environmental damage and
the related costs through direct regulatory approaches.
The aesthetic degradation and clean-up costs associated with litter
are (for some product categories) an important component of their overall
solid waste management costs. To neglect these costs would result in a
failure to internalize all socially-relevant costs. However, only a very
small proportion of any consumer products is littered. Consequently, a
litter-related disposal charge would be born primarily by the consumers of
a product who do not litter, and the charge could not be expected to signi-
ficantly affect the rate of littering. Precise estimates of litter control
costs have not been developed, but one study indicates that the annual cost
could be as high as one billion dollars.* This would be equivalent to
about $15/ton if allocated over all the products included in 5. 1281.
Samtur, Harold, Litter Control Strategies, undated draft prepared for
the Environmental Protection Agency, p. 34.
52
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The imposition of a tax on materials has also been suggested as a
means to account for their inherent scarcity or the "cost" of excessive
import-dependence. This argument touches on the much broader issue of how
natural resources should be valued by society, which will be discussed at
the Conference on Resource Conservation to be sponsored by the Resource
Conservation Committee.
Virgin materials currently have tax advantages not shared by second-
ary materials. Although unrelated to municipal solid waste costs, a charge
could be levied on virgin materials to eliminate the existing tax advantages.
However, the elimination of inequities in current taxation policies would
seem to be best handled through the direct modification of the appropriate
provisions in the existing tax code. This subject is currently being stud-
ied by the Committee in conjunction with the Department of the Treasury.
OPTIONS
1. Base the charge solely on the direct cost of existing municipal
solid waste management (excluding litter management).
o This is similar to S.1281, and it is the simplest way to
price municipal solid waste services.
2. Base the charge on the cost of providing environmentally accep-
table municipal waste management services.
• This is a more complex pricing alternative, which in prac-
tice, might not be too different from the first option.
3. Include in the charge the environmental damage "cost" of lit-
ter or poor disposal practices.
• Quantified environmental damage costs would be a valid basis
for a charge, but cost estimates do not currently exist, and
aesthetics are hard to quantify. These costs may ultimately
be largely "internalized" by regulation.
4. Relate the charge to the cost of litter management.
• This is another waste management pricing option, but suffi-
cient data are not available to allocate litter control
costs to specific products, and pricing would provide
little incentive to stop people from littering.
3. What Pricing Concept Should be Used to Set the Charge Level?
There are two basic methods of pricing public services with respect
to costs. Consumers may be charged the proportion of the total costs asso-
ciated with their use of a service (average cost pricing), or they may be
53
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charged the additional cost incurred by the system which corresponds to
their incremental use of a service (marginal cost pricing).
Accepted economic theory indicates that resource utilization effici-
ency is maximized when the price of a service is equal to the incremental
or marginal cost of providing the service. However, when the marginal cost
is less than the average cost, this pricing approach yields revenues which
do not cover the total cost of operating the system.
Average cost pricing is less economically efficient, but it ensures
that all users pay their share of the cost of services. Average cost
pricing is also easier to administer than marginal cost pricing because the
price or charge can be based on the total cost actually incurred in the
past. To determine the incremental or marginal cost of providing services,
time and motion and engineering studies must be carried out to estimate the
cost increase or reduction associated with expanding or reducing the service
by a unit amount.
In order to estimate marginal costs, an additional distinction must
be made between those incremental cost increases or savings due to service
changes in the short-run and those increases or savings occurring in the
long-run (5-10 years). In the short-run existing equipment and labor agree-
ments often restrict the amount of savings which may be obtained through a
reduction in the amount of municipal solid waste. Disposal costs would be
saved on every ton of waste not handled, but collection cost savings might
be small if existing routes and service frequencies were maintained. How-
ever, in the long-run there would be opportunities to reduce capital re-
quirements and service frequency and to extend route lengths as a result
of lower waste loads per household. Ideally, the long-run marginal cost
should be used to price public services.
A study is currently underway to determine the relationship between
the average and long-run marginal costs of municipal solid waste management
services. If these costs are similar, ease of administration suggests that
average costs should provide the basis for the disposal charge level.
S. 1281 specifies a charge level which is most closely related to the aver-
age cost of municipal solid waste management services.
OPTIONS
1. Use average cost pricing as the basis for the charge.
• This is the easiest way to price and ensures that users pay
the full costs of services.
2. Use short-run marginal cost pricing as the basis for the charge.
• This approach relates'prices to the short-run savings asso-
ciated with municipal waste reduction, which is an ineffi-
cient way to price services in the long run.
-------
3. Use long-run marginal cost pricing as the basis for the charge.
• In theory this approach ensures the most efficient use of
resources/ but in practice it is hard to carry out*
4. How Should the Charge Level be Determined for Specific Product
(or Material) Categories?
If waste management services are to be priced by relating the charge
on each product to its municipal waste management cost, then total waste
disposal costs must be allocated among the various product categories. At
the present time only the collection and disposal costs of managing mixed
waste streams are known. The actual cost of managing ,the disposal of dis-
carded products seems to depend on both the weight and the volume of the
product.
A weight-based procedure would be the easiest way to allocate solid
waste costs to products because weight is the only indicator of waste quan-
tity which is relatively easy to measure. However, a recent study performed
for EPA suggests that waste volume may be a better measure of costs than
weight.* A volume-based allocation is complicated by the general lack of
information on the density of material components in the waste stream and
by the change in volume (and density) of discarded products at each waste
processing stage.**
S. 1281 proposes that some products be charged on a weight basis
and others on a unit basis:
The initial base charge schedule shall include a charge
of 1.3 cents per pound ($26 per ton) and 0.5 cents per
container (§5 per thousand containers) for rigid con-
tainers, adjusted for that fraction which would normally
be lost in any subsequent production stage.
In some situations, a volume-related cost structure could be approximated
by a unit-based product charge, but a uniform rate for all rigid containers
would be inappropriate for some types of container.
Franklin Associates, Ltd., Analysis of Environmental and Economic
Impacts of Waste Reduction Procedures and Policies, (Task Order No. 6,
Substask No.2), December 14, 1977.
The National Bureau of Standards ,is currently investigating how costs
are related to product characteristics as part of an effort to develop
and evaluate a variety of cost allocation procedures for the RCC staff.
55
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Table 2 presents the results of a preliminary analysis of municipal
solid waste management costs by type of product. The actual cost per ton
is believed to be more closely related to the volume-based measure, which
is shown in the first column. The data in Table 2 suggests that a uniform
charge of $30 per ton would overcharge glass containers and aluminum foil
and undercharge a variety of other materials. The S. 1281 charge approach
(0.5£ per container) might be better for glass containers, but it would
appear to severely overcharge aluminum containers.
In addition to these approaches/ representatives of industry have
recently suggested that a solid waste disposal charge be based on the value
of the product (an ad valorem approach)• If a uniform ad valorem charge
rate were specified, more valuable products (e.g. beer in aluminum cans)
would be charged much more than lower-valued products (e.g. newspapers).
Clearly, unless the ad valorem rates were set by product category, the
charge on a product would not be closely related to its waste management
costs.
OPTIONS
1. Apply one uniform charge rate to all covered products based only
on product weight.
• A uniform weight-based charge would be the easiest
physically-based charge to administer. However, weight
is not the only or necessarily the most significant
determinant of quantity-related solid waste management
costs.
2. Apply one uniform weight-based rate to most products, but charge
rigid containers on a unit basis.
• This is the approach proposed in S. 1281. It is slightly
more sophisticated than a weight-based charge rate, but
it could seriously overcharge some types of containers.
3. Apply different charge rates to different products which reflect
their actual contribution (on a nationwide average) to solid
waste management costs, and leave the final specification of the
charge rate to the administering agency and the National Bureau
of Standards.
• This approach would price waste management services more
precisely, but it would increase the administrative cost
of the program.
56
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Table 2
COMPARISON OF PRELIMINARY PRODUCT DISPOSAL COST ESTIMATES
AND S. 1281 PROPOSED CHARGE RATES
(Dollars per Ton)
Waste Component
Durable Goods:
Major Appliances
Furniture
Rubber Tires
Miscellaneous
Weight
a/
Estimated Average Cost/Ton
Volume
Basis
17.78
64.62
18.33
52.18
S. 1281
Proposed
Charge Rate
NC
NC
NC
Nondurable Goods:
except food 14.97 30.00
Glass Containers 15.47 30.00
Steel Cans 41.23 30.00
Aluminum
Cans 65.00 30.00
Foil 4.00 30.00
Corrugated 70.13 30.00
Other Paperboard 45.40 30.00
Packaging Paper 58.33 30.00
Plastics
Containers 93.33 30.00
Other Plastic Packaging 52.95 30.00
Wood Packaging 19.29
Food Waste 10.23
Yard Waste 30.25 —
Miscellaneous 30.63
Average 37.80 30.00
Range 4.00-93.33
Standard Deviation 24.18 —
30.00
16.05
59.26
227.00
30.00
30.00
30.00
30.00
91.43
52.95
19.29
10.23
30.25
30.63
57.4
16.05-227.00
63.4
a/ Assumes disposal costs for all products are uniform and based only on
weight.
b/ NC indicates not covered under S. 1281 provisions.
Reference: Franklin Associates Limited, Analysis of Environmental
and Economic Impacts of Waste Reduction Procedures and
Policies, Task Order No. 6, Subtask No. 2 — Alternative
Bases for Product Charge, December 14, 1977, p. 8.
57
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4. Apply a uniform ad-valorem (percent of market value) charge rate
to all products covered, based on the total amount of revenue to
be raised.
• This approach would be easy to administer, but it would
not relate the charge rate applied to a product to its
disposal costs and therefore would not improve resource
utilization efficiency.
5. Should the Charge be Adjusted to Account for Geographical Cost
and Pricing Variations?
If a charge were imposed on all products based on the national aver-
age of their collection and disposal costs, consumers in areas with low
collection and disposal costs would pay too much, while consumers in high
cost areas would pay too little. Similarly, in those communities where
quantity-based local user fees are already being charged, the imposition of
a national disposal charge would cause products subject to the charge to be
overpriced from an efficiency standpoint. This characteristic of a uniform
national charge limits the ability of the charge to improve the economic
efficiency of resource use and could cause some income redistribution.
Preliminary information prepared for the RCC staff indicates that
the variation in costs between broad geographic regions may not be particu-
larly significant. However, the cost of managing and the method of pricing
wastes vary considerably between individual localities. Because adjusting
the charge on a site-specific basis is not administratively feasible at the
national level (due in part to the complexity of inter-area commerce), the
associated loss in economic efficiency must be accepted as an inherent
drawback of the disposal charge scheme. Undesirable income redistribution
effects, on the other hand, can be remedied through the revenue allocation
mechanism (discussed under Issue No. 9).
OPTIONS
1. Specify a uniform national charge rate for products.
• This is the most feasible approach from an adminis-
trative standpoint, but it entails some economic
efficiency losses.
2. Specify disposal charge rates by broad geographic region.
• Varying the rates between large regions would be
complex administratively and would not address the
more significant local variation problem.
58
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3. Specify disposal charge rates on a local-area-specific basis*
• A localized approach is not administratively feasible
with a national disposal charge initiative.
6. Where Should the Charge be Collected?
The location of the charge assessment point in the product produc-
tion and distribution system is a key determinant of administrative
costs. The principle options range from placing the charge at the virgin
material extraction point to placing the charge at the product fabrication
point. In general, as the collection point moves down the distribution
chain, more establishments are involved, and the collection aspect of the
charge program becomes more costly to administer. Placing the charge at
the wholesale or retail distribution stage in a product's life cycle would
be highly undesirable from an administrative standpoint.
The administrative requirements associated with possible adjustments
to the charge (e.g. for imports, exports, and recycling) also affect the
decision on where to place the charge. The material flow analysis in
Figure 1 indicates the potential administrative complexity of a sophisti-
cated national solid waste disposal charge.
Material recycling normally occurs at the bulk material manufactur-
ing point, so any recycling adjustments would be easier to administer if
the charge were placed at that point. Imports and exports occur at many
levels of product manufacture and distribution. Consequently, if the
charge were levied prior to the product fabricating point, a separate set
of charge regulations might have to be developed to handle the import and
export of finished products.
S. 1281 specifies that the judgment as to the specific point to
collect the charge for each product category should be determined on a
case-by-case basis by the agency administering the charge:
In making this decision as to who shall pay the charge,
the Administrator shall take into account the number of
establishments that would have to be monitored, the
difficulty of making the adjustment for secondary mate-
rial content, the ability to distinguish the product
stream to be charged, and such other factors as affect
the administrability and equity of the charge. However,
it is the intent of this Act that the charge be levied
at the earliest practical stage of the product's manu-
facturing sequence.
The need for adjustments suggests that ,most products could be most readily
charged at the product fabrication point, but some (e.g. paper) might be
handled more efficiently at the bulk material manufacturing point.
59
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Figure 1
MATERIAL FLOW ANALYSIS
Other
Manufacturer
VIRGIN MATERIAL EXTRACTION
export
PRODUCT FABRICATION
Recycling
DISTRIBUTION
CONSUMPTION
Recycling
.Import
»| BULK MANUFACTURING"] Export
-Import
Export
-Import
Txport
Secondary Material
Export
_ MSW MANAGEMENT
ICF INCORPORATED
60
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OPTIONS
1. Place the charge at the product fabrication point (the place
where the product assumes final form).
• This would make import/export adjustments simpler, but
it would require charge collection from many points.
2. Place the charge at the bulk material manufacturing point (e.g.,
tinplate, paper) and include a charge adjustment to account for
the material lost in pre-consumption manufacturing stages.
• This would simplify the charge collection process and
would make recycling adjustments relatively easy, but
it would limit the basis of the charge to weight and
might make further additional import/export adjustments
necessary.
3. Place the charge at the point of purchase of virgin materials.
• This would make a recycling adjustment unnecessary and
would further simplify charge collection, but it would
not be possible to confine the charge strictly to mate-
rials which enter municipal solid waste with this
approach.
4. Leave the Final Determination to the Implementing Agency.
• This would provide the needed flexibility for implemen-
tation, but it would make the impact of the initiative
more difficult to predict.
7. How Should Imports and Exports be Treated?
The proposed solid waste disposal charge is designed to internalize
the costs of domestic solid waste management. Thus, in principle, exports
should be excluded from the charge as their disposal costs will be incurred
elsewhere, and imported products should be made subject to the charge.
Additionally, it is important to ensure that imports not be given unfair
trade advantages and that exports not be placed at an unfair trade disad-
vantage. S. 1281 proposes the following treatment for exports:
After consultation with the Secretary of the Treasury,
the Administrator shall establish procedures to insure
that products exported prior to final use do not bear
the charge. The Administrator may satisfy this re-
quirement by 'a rebate to the exporter or by adjusting
the product charge paid by the manufacturer.
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With respect to imports, S. 1281 proposes that:
Any charges established by the Administrator under
this title shall, in accordance with regulations pre-
scribed by the Secretary of the Treasury, be levied on
and paid by the person who manufactures, produces, or
imports the product in either its bulk or finished form
as determined by the Administrator.
The language in S. 1281 is consistent with the intent that waste
management costs be internalized, but the difficult problem of developing
administrative procedures to deal with imports and exports is not addressed.
All domestic excise tax measures must deal with this administrative problem,
and procedures have been developed to exempt exports and charge imports at
low administrative cost. However, as discussed under Issue No. 6, the
designation of the charge collection point would affect the administrative
feasibility of handling imports and exports in an efficient and equitable
manner.
OPTIONS
1. Treat exports the same as domestically-sold products.
• This would avoid the administrative problems associ-
ated with import/export adjustments.
2. Exempt exports from the charge.
• This would be the proper approach from an economic
efficiency and equity standpoint.
3. Levy the charge on imports by developing special procedures
if necessary.
• This would be the proper approach from an economic
efficiency and equity standpoint, but it might be
costly to administer.
4. Exempt imports from the charge.
• This would avoid the administrative problems associ-
ated with export/import adjustments.
8. Should There be Adjustments to the Charge and/or Credits for Resource
Recovery and Recycling?
The purpose of the charge is to better internalize the cost of
municipal solid waste management services. Accordingly, if a product does
not enter the municipal waste stream, no charge should be levied on it.
62
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Alternatively, if all products were originally charged to simplify tax
administration, a credit could be provided when covered products were
diverted from the waste stream.
If a firm is involved in the recovery, reprocessing, and reuse of
materials that would otherwise become municipal waste, that firm may be
reducing the municipal solid waste management problem. The provision of
a disposal charge rebate or credit to those private organizations who divert
materials from the waste stream would encourage the recycling of secondary
materials. This "reward" for recycling has been a key element in obtaining
support for the national charge initiative proposed in S. L2B1.
Modifying the charge proposal to account for recycling would increase
its administrative complexity. Also, unless properly structured, a recycled
materials credit might permit deductions for scrap materials (e.g. automo-
biles) which are not part of municipal solid waste, for materials which are
subsequently dumped back into the municipal waste stream, or for materials
for which another organization had already claimed the credit. From an
economic efficiency standpoint, too much crediting might constitute an un-
justified public subsidy for recycling.
There are a variety of procedures which could be used to make a re-
cycling adjustment.* The simplest approach would be to reduce the amount
of the disposal charge to account for the total municipal nationwide savings
due to recycling activities. This approach would price municipal services
at the right level in the aggregate, but the incentive for any one firm to
recycle would be almost completely eliminated by distributing the associated
cost savings over all firms.
Preliminary information from a survey of communities around the
nation indicates that some municipalities are already financing resource
recovery approaches as a municipal solid waste management cost-minimization
technique. Accordingly, the overall reduction in the charge (the first
approach mentioned) to account for the savings due to recycling could be
coupled with a requirement that municipalities fund cost-effective resource
recovery programs in order to be eligible for revenues from the program.
This could encourage municipalities to seek out and fund more viable
resource recovery operations.
Another approach would be to reduce the charge levied on a manufac-
turer's products by the percent of post-consumer secondary materials used
in the product. This is the approach proposed in S. 1281. This would
encourage those manufacturers who were subject to the charge to recycle,
but it would not encourage those industries not subject to the charge
This discussion focuses primarily on possible credit or rebate mechanisms;
a discussion of the proper credit amount is included as Issue 8a.
63
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(e.g. wallboard producers) to increase their use of secondary materials
(in fact, the higher secondary material prices which would result from an
intra-industry rebate approach would inefficiently discourage industries
from recycling secondary materials into other products).* Also, it might
be difficult to distinguish post-consumer waste materials from other types
(e.g. steel from old bridges), which could result in excessive claims for
the credit.
Another approach would be to provide a tax credit or cash rebate to
anyone recycling secondary materials from post-consumer waste. Energy
recovery could also be eligible for a credit. The very large number •£
participants associated with this approach would greatly increase the like-
lihood of falsified claims associated with this use of the tax system.
Enforcement against double-counting and the crediting of inapplicable
(non-post-consumer) waste materials could require a complex secondary
material tracking procedure which could entail high administrative costs.
An alternative approach would be to allow the credit (or rebate)
only to manufacturers making products subject to the charge, but to allow
them to sell to other users any recovered post-consumer waste materials
they did not need. This would make the original manufacturer the agent
for extra-industry manufacturers who could not claim the credit themselves.
This approach would allow major extra-industry users to benefit from the
recycling incentive (the original manufacturers would be willing to sell
them materials at a low price in order to obtain the credit) and would
limit the number of firms able to claim tax credits. However, it would
still be difficult to guard against the double-counting of secondary
materials or the dumping of the materials after the credit were claimed.
The private management of paper and packaging wastes in the commer-
cial and industrial sectors also "diverts" waste materials which could
otherwise end up in the municipal solid waste stream. Since the pricing
of commercial and industrial waste management services is often quantity-
related, the solid waste disposal charge rationale is less applicable in
these sectors of the economy. There are a variety of procedures which
could be used to adjust the charge for the private management of waste
materials in the non-residential sectors, including exemptions and other
approaches similar to those discussed for the recycling adjustment. As in
the recycling case, however, any adjustment for private waste management
would complicate the administration of the charge.
* Franklin Associates, Extra-Industry Recycling Issues (draft report
submitted to EPA), September 27, 1977, pp. 3-5.
64
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OPTIONS
1. Make no adjustments for recycling.
• This would greatly ease administration of the product
charge schemer' but products diverted from the waste
stream would still bear the disposal charge, and cost-
effective recycling would not be appropriately
stimulated.
2. Reduce the average level of the charge to account for the aggre-
gate nationwide savings due to recycling.
• This would entail little administrative cost and would
prevent possible overcharging in the aggregate, but it
would provide little incentive to any firm to increase
its recycling.
3. If revenues are to be returned to municipalities, require for
eligibility that they consider resource recovery MSW management
alternatives and fund cost-effective approaches.
• This would provide an incentive to increase the number
of cost-effective resource recovery programs.
4. Reduce the charge levied on each manufacturer's product by the
percent of post-consumer secondary material in the product.
• This is the approach proposed in S. 1281, and it would
encourage manufacturers covered by the charge to in-
crease their recycling rates, but it would adversely
affect recyclers not subject to the charge.
5. Provide a tax credit or cash rebate to anyone recycling products.
• This would avoid any discrimination against extra-
industry recycling, but it would greatly increase the
potential for excessive claims.
5a. Provide a tax credit or cash rebate to anyone for energy recovery.
• This would extend option 4 to energy recovery.
6. Reduce the aggregate amount of a manufacturer's material sub-
ject to the charge by the amount of secondary material recov-
ered by the manufacturer for use or resale.
• This would allow a manufacturer subject to the charge
to operate as an agent for other (extra-industry) users.
65
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8a. How Large Should Any Recycling Adjustments or Credits Be?
The rationale behind the recycling adjustment is that firms should
not be charged for the management of discarded products which do not enter
the municipal waste stream. However, some secondary materials are recycled
after they enter the municipal solid waste management system. The recycl-
ing of these materials may save the municipality money, but in some cases,
the net collection and processing costs incurred to recover materials or
energy may equal or even exceed the cost of conventional waste collection
and disposal. Allowing manufacturers a tax credit equal to the full
disposal charge for all the materials they recycle would subsidize .those
materials whose recovery is partly financed by the public through its sup-
port of municipal services.
In principle, a recycling adjustment should distinguish between
those products which are diverted prior to entering the municipal waste
st^eam and whose recovery entails no public cost (e.g. a paper drive) and
those which incur substantial public costs (net of revenues from sale)
during the recovery process (e.g. separate municipal collection). S. 1281
does not distinguish between resource recovery methods, and there is no
easy way to distinguish between them administratively.
One approach to this problem would be to limit any recycling credit
to less than the full disposal charge. The amount credited could be equal
to the average nationwide municipal cost savings associated with recycling
activities. This would be inefficient in that some activities would be
overcredited and some undercredited. Privately-financed methods (e.g.
Reynolds or Alcoa-financed recycling centers) would not receive adequate
encouragement, and publicly-financed methods would be subsidized.
Alternatively, an attempt could be made to distinguish between
recovery methods to ensure that materials were credited based on the muni-
cipal savings associated with different recovery methods. The RCC staff
is examining the feasibility of such an approach.
OPTIONS
1. Set the amount of any credit equal to the full disposal charge.
• This is the approach included in S. 1281; it does not
distinguish between recovery methods and subsidizes
them in the aggregate.
2. Provide a credit equal to the average municipal cost savings
associated with recycling.
• This would require,an analysis of actual resource
recovery costs and would not distinguish between more
or less costly recovery methods.
66
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3. Provide a credit equal to the actual cost savings associated
t*H ^V» /^ i ffoTT&r\+
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the formula could be adjusted to improve the economic efficiency and equity
of the national disposal charge scheme.
Revenue-sharing based on a population formula would distribute reve-
nues to municipalities in a manner more closely related to the amount actu-
ally paid by the individuals in these municipalities. Since charge revenues
would accrue as a function of an area's population and average income, a
formula based only on population would redistribute income somewhat from
wealthier to poorer municipalities. Depending on how the revenues were
used (for more local programs or less local tax), this approach could be
slightly progressive relative to existing local revenue-raising mechanisms.
A revenue-sharing program could also be operated with restrictions
on the use of the funds (e.g. for the construction of resource recovery
facilities) or with criteria for eligibility which would be related to
municipal solid waste management practices. This would alter the overall
purpose of the charge system to encourage specific expenditures or environ-
mental protection practices and would increase the administrative cost of
the system. A disadvantage of this option is that mandating the use of
revenues for a specific purpose could lead to the misuse of public funds.
The revenues could also be rebated to individuals through the Fed-
eral income tax mechanism. However, an income tax rebate scheme would
probably be similar in net effect to placing the revenues in the General
Fund, and it would further complicate the tax code.
OPTIONS
1. Transfer revenues to the U.S. Treasury's General Fund for gen-
eral use.
• This would be administratively the easiest approach,
but it would be somewhat regressive from a tax stand-
point.
2. Distribute revenues to state and local governments using the
existing general revenue-sharing program and allocation formula.
• This option would have low administrative costs, but
it would distribute revenues in a way not related to
solid waste management costs.
3. Distribute revenues to local governments via the revenue-shar-
ing program using a formula based on population alone.
• This option would have low administrative costs, would
be slightly progressive from a tax standpoint, and
would relate the revenues to solid waste management
costs.
68
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4. Limit eligible expenditures of the revenues at the local level
to municipal solid waste management services.
• This would increase administrative costs and emphasize
environmental protection or resource recovery.
5. Make a local government's eligibility for the funds dependent
on compliance with Federal waste management guidelines.
• This would convert the initiative to a combination
regulatory/user charge program.
6. Rebate revenues to citizens through the Federal Income Tax
mechanism*
• This would complicate the tax code, and the net effect
might not be very different from just placing revenues
in the General Fund.
10. Should the Introduction of the Charge be Phased in Over Time?
A short implementation period would be required to prepare the tax
regulations on disposal charge (and rebate) eligibility. Additionally, a
phase-in period could be included to ameliorate any possible transitional
adverse economic impacts. Preliminary analysis of the impact of the charge
suggests that a phase-in period of five years would not cause any signifi-
cant adverse impacts.
OPTIONS
1. Phase in the charge over ten years after a one-year implemen-
tation period.
• This is the approach proposed in S. 1281.
2. Phase in the charge over five years after a two-year implemen-
tation period.
• This would provide time for implementation and would
prevent any serious short-run adverse impacts.
3. Make the charge fully effective after two years.
• This would provide time for implementation and would
ensure a rapid response to the product charge incen-
tive.
69
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11. How Should the Charge be Adjusted Over Time?
If the charges are to reflect the actual costs of managing solid
wastes, the charges would have to be revised periodically. S. 1281 pro-
poses that:
The Administrator shall establish a national solid waste
management costs survey or indexing procedure to revise
the base charge periodically to reflect changes in solid
waste management costs. Such periodic adjustments shall
be no more frequent than every two years nor no less
frequent than every four years.
The charge could be adjusted every year, but the costs of munici-
pal solid waste management should not change that much in one year, and
depending on the sophistication of the adjustment process, an annual
adjustment could have significant administrative costs.
OPTIONS
1. Revise the charge every 2-4 years based on a municipal solid
waste management cost survey or indexing procedure.
• This would keep the charge rate related to municipal
solid waste costs and is the approach proposed in
S. 1281.
2. Revise the charge annually based on a municipal solid waste
management cost survey.
• Annual revision would have higher administrative costs
than the 2-4 year revision, but it would keep the
charge more closely related to actual costs.
70
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INDEX ;
PUBLIC COMMENTS ON STAFF BACKGROUND
PAPERS NO. 8 AND 9
1) United States Brewers Association, Inc.
2) International Paper Company
3) Magazine Publishers Association, Inc.
4) Brik Pac Inc.
5) National Food Processors Association
6) Department for Natural Resources and
Environmental Protection
7) County of Cuyahoga
8) MacMillan, Inc.
9) Gino Crocetti, Citizens Union Research
Foundation
10) Paperboard Packaging Council
11) American Can Company
12) American Paper Institute, Inc.
13) Association of American Publishers, Inc.
14) National Solid Wastes Management Assoc.
15) Wegman Engineers
16) The Society of Plastics Industry, Inc.
May 15, 1978
May 15, 1978
May 15, 1978
May 12, 1978
May 17, 1978
May 12, 1978
May 11, 1978
May 15, 1978
May 12,
May 26,
May 25,
May 31,
May 26,
May 18,
May 31,
June 5,
1978
1978
1978
1978
1978
1978
1978
1978
71
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United States. Brewers Association, Inc.
1750 K STREET, N W. WASHINGTON. D.C. 20006
(202) 466-2400
TWX 710-822-9208
May 15, 1978
Ms. Susan Mann
Public Participation Liaison
Resource Conservation Committee
Washington, D. C. 20460
Dear Ms. Mann:
We would like to thank you for Ms. Blum's letter of
April 18, 1978 inviting us to comment on Background Papers
8 and 9 relative to solid waste disposal charges.
While we presently do not have additional inputs be-
yond the material submitted by us on November 17, 1977
(copy attached), we would like to reemphasize our concern
with the "deposit on bounty systems" described on page 13
of the background paper number 8. We are enclosing a copy
of Mr. Peter Stroh's comments on that topic as well as my
own.
We trust this information will be helpful and should
you desire additional material, please let us know.
Codi^lly,
/O. %£AG
HBK/djd
Enclosures
THIS PAPER IS MADE OF lOO* RECUAIMEO WASTE
72
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INTERNATIONAL PAPER COMPANY
SUITE 700, isao EYE ST , N w, WASHINGTON, o c 20006, PHONE 202-785-3666
RALPH w KITTLE. Vice President May 15, 1978
Ms. Susan Mann
Public Participation Liaison
Resource Conservation Committee
401 M Street, S.W.
Washington, D. C. 20460
Dear Ms. Mann:
We are most appreciative of the opportunity afforded by the
Resource Conservation Committee to comment on the Staff papers.
We recognize that these papers are not in the form of recommenda-
tions, and that it is an attempt to evaluate only one possible
approach to the problems of solid waste management. We recognize
further that there has not been a complete and detailed analysis
made to validate many of the positions and assertions that are
expostulated in the rationale.
It would be our hope, of course, that such an analysis would
precede any recommendations that the Committee might make pursuant
to your mandate from Congress.
There are a number of statements and assumptions made in the
rationale that are highly questionable; some are inaccurate and
misleading. Specifically, we suggest the following points in the
staff paper should be reviewed in terms of accuracy and relevancy:
1. Page 3 "High and rising levels of solid waste generation
are the natural result of ... an abundance of
accessible natural resources ..."
The opposite may be true. In the food proces-
sing business particularly, the abundance of
accessible and inexpensive natural resources
(packaging) reduces the total waste in the
municipal stream, and contributes significantly
to the conservation of a scarce and expensive
resource.
2. Page 3 "The amount of the post-consumer solid waste
stream which is not recycled is a useful indi-
cator of the rate of depletion of virgin nat-
ural resources."
73
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INTERNATIONAL. PAPER COMPANY
-2-
This is a spurious argument, at best. In the
paper industry particularly, an analysis of a)
the growing stock vs. the recycling rate over
time and b) the growing stock vs. virgin pro-
duction over time would tend to refute the point.
3. Page 3-4 "Finite natural resources"
The raw material for paper packaging is not a
finite resource. Any analysis of resource
management must recognize the basic principle
of the renewable forest.
4. Page 3-4 "This rapid consumption of finite natural
resources is clearly not in a society's best
interest if materials in the solid waste stream
can be efficiently and economically recycled
and reused..."
This assertion omits the consideration of "best
uses" of resources. It is definitely not clear
that recycling and reuse is in society's inter-
est. Using municipal solid waste as a source
of energy may very well be more in society's
best interest.
5. Page 6 "Greater - than - optimal consumption"
Page 7 "Full cost— would reduce total natural resource
utilization."
There is reason to conclude that if there were
a comparison of disposal costs to costs saved
such as dishwater power and heat, cooking energy,
spoilage and damage, etc., we would use more -
not less - disposables. If standard of living
could be further quantified, there might be a
larger force in favor of disposables. The Com-
mittee further uses the term "optimal" which
strictly speaking means some derivative equal
to zero. A differential calculus analysis
might show a movement to more disposables or
that sensivity to disposal costs is insignificant,
6. Page 7 "Full cost pricing of solid waste management
services is consistent with at least four of
five policy design criteria ..."
No underlying points are offered to substantiate
this flat assertion. In fact, there is serious
doubt that a disposal charge levied against the
74
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INTERNATIONAL PAPER COMPANY
-3-
raanufacturers of packaging products come close
to meeting the "polluter pays" principle. If,
as some suggest, the tax is regressive, it could
hardly be "socially and economically equitable".
Regarding wood waste use in paper, the tax may
decrease efficiency, thus the principle of
improving economic efficiency is not met.
7. Page 13 "No guarantee that a sufficient amount of recov-
ered materials would always be available to rea-
sonable prices"
A product disposal tax would exacerbate this
problem. Creating credits for recycled paper
use could increase the demand, thus increase
the price.
It should be further noted that forcing the use
of recycled paper in order to avoid the tax
would decrease the consumption of wood wastes
from the forest floors and the processing plants.
The result would be not a reduction of total
solid wastes, but a relocation of solid waste.
Beyond these specific points, we would urge again a thorough,
complete, detailed analysis of the actual results that could be
expected from the proposed tax, and that the proper consideration
be given to the total impact on the social and economic problems
that face this country.
If municipal solid waste were to be viewed as an alternative
energy source, available today through existing technology, the
Committee could very well decide to extend their efforts to solving
the institutional barriers that are currently inhibiting our ability
to recover resources in the most efficient, economical and socially
responsible way.
Sincerely,
75
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iMPAjMagazirw Publishers Association, inc.
^~~~^ 1629 K Street A JF. Washington. D. C. 20006 / 1202\ 296-7277
CARPENTER. JR
Senior Vice President/Washington
May 15, 1978
Ms. Barbara Blum
Chairperson
RCC Senior Advisors
Resource Conservation Committee
401 M Street, S.W.
Washington, D.C. 20460
Dear Ms. Blum:
Enclosed are ten (10) copies of the Comments
of the Magazine Publishers Association, Inc. on the
Solid Waste Disposal Charge, which is submitted in
response to your notice of April 18, 1978, soliciting
comments on the staff background papers entitled
"Rationale for National Solid Waste Disposal Charge
Legislation" and "Solid Waste Disposal Charge Design
Issues."
If there are any questions about these comments,
we will be happy to meet with you and your staff or
respond to any telephone inquiries you may have. We
would appreciate being advised of any recommendations
your Committee may make.
Chapin Carpenter, Jr.
76
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COMMENTS OF
MAGAZINE PUBLISHERS ASSOCIATION, INC.
TO
THE RESOURCE CONSERVATION COMMITTEE
ON THE
SOLID WASTE PRODUCT CHARGE
These comments are filed in response to the
Committee's notice issued April 18, 1978 soliciting comments
or suggestions on the staff background papers entitled
"Rationale for National Solid Waste Disposal Charge Legislation"
and "Solid Waste Disposal Charge Design Issues."
The Magazine Publishers Association, Inc. (MPA) is
a trade association incorporated under the laws of the State
of New York. MPA has 160 members who publish 600 consumer
magazines. These magazines account for over 60 percent of
total audited magazine circulation — about 165 million copies
per issue — and for over 80 percent of total magazine
advertising revenues. MPA's members use over 50 percent of
all the paper required by the magazine publishing industry.
MPA is, therefore, representative of a major portion of the
magazine publishing industry.
MPA is opposed to the concept of a solid waste
product charge and to federal legislation that would impose
the charge nationwide. MPA agrees with the statement of the
American Newspaper Publishers Association (ANPAJ, filed
on December 1, 1977 in response to an earlier and similar
Committee inquiry. The basic reasons why the charge is unwise
77
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and should be rejected, as stated by ANPA and concurred in
by MPA, are:
"-It would threaten the free flow of
information and ideas through the timely
publication of newspapers [and magazines] by
imposing a crippling $30 per ton tax on news-
papers' [and magazines'] principal material,
newsprint, and by increasing the possibility
of shortages in vital newsprint supply.
- It would be an inflationary tax, the
burden of which would fall largely on consumers.
- It would be a discriminatory tax, affecting
the paper industry almost exclusively.
- It would be regressive, taxing most severely
those least able to pay.
- It would be inequitable, taxing those persons
who recycle their waste on the same basis as it would
tax those who do not, and charging taxpayers twice
for the same service.
- It would be unworkable; it not only lacks
incentives, it contains disincentives."
MPA endorses the arguments made by ANPA in the remainder of its
Statement and will not repeat them here. Rather MPA will
provide the Committee with factual data regarding the effect
.of a solid waste product charge on magazine publishers, their
subscribers and their advertisers.
Paper is the second largest cost of magazine publishing.
It accounts for almost 20 percent of total operating costs, only
slightly less than the cost of printing and binding. In 1977
the magazine publishing industry used 2,268,000 tons of paper.
Imposition of a $30 per ton solid waste product charge would
78
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cost the industry at least an additional $68 million in paper
costs. Markups that would be added as paper passed through
the distribution chain could double that figure. On a per
copy basis paper now costs over 14 cents per copy. The solid
waste product charge would increase paper costs from 6 to 12
percent — at least a penny per copy and probably more.
Addition of this charge would reduce the before tax profits
of the magazine publishing industry by 20 percent.
The industry could not stand a severe reduction
in profits because it is already a low profit margin industry.
The after tax profit of MPA1s members in 1976, the latest year
for which data are available, was only 3.6 percent. During
the period 1970 through 1976 it has never exceeded four percent.
The industry would, therefore, have to pass the charge on to
its readers and its advertisers by increasing subscription
and newsstand prices and advertising rates. This would have
two adverse effects. First, it would contribute to inflation.
Second, it would restrict and reduce the dissemination of
information, ideas and debate on public issues, because fewer
readers would be able to afford magazines or at least as many
magazines as they currently buy and read.
Quite apart from all the above, the charge is a bad
idea because it attempts > to so.lve a problem by attacking it at
the wrong end. If studies and legislation are necessary, they
should be addressed to the recycling and reuse of paper products.
79
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particularly paper used by the newspaper and magazine publishing
industries. Consideration should be given to grants or loans
or tax incentives to encourage the construction and use of recycling
facilities, rather than imposing an unfair and discriminatory
tax on paper.
MPA, therefore, requests the Committee to find and
to advise the President and the Congress, in the report it will
submit pursuant to Section 6982(j)(4) of Title 42, United
States Code, that the solid waste product charge is neither
appropriate nor feasible as a resource conservation strategy
and that the other alternatives described in the Resource
Conservation and Recovery Act of 1976 should be pursued
instead.
May 15, 1978
80
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BrikPaklnc,
BEVERLY ANN DRAPER
Office Manager
May 12, 1978
Ms. Susan Mann
Public Partjcipation Liaison
Resource Conservation Committee
401 M Street, SW
Washington, DC 20460
Dear Ms. Mann:
This letter is in reference to your April 18 request for comments
from interested parties on the proper pricing of solid waste
disposal costs as treated by the Resource Conservation Committee
Staff Background Papers 8 and 9, both dated April 17.
Although it is impossible, within the limited time available to
us to consider the material which was received April 27, to
comment in great detail, we do want to make the following points:
1. Although not explicitly mentioned in the study, we take it for
granted that the proposed national charge system is to replace
the existing container tax and deposit regulations at state
levels.
2. From Table 2, Page 12, it is not clear how paper/plastic based
milk and beverage container systems would be classified. Com-
posite material containers are not mentioned at all and their
classification must be clearly defined. The majority of the
paper/plastic composite containers are easily compressible and
could not be classified as rigid containers.
3. Of the different options for a charge level (Page 13), our
preference would be number one — a uniform weight-based charge
rate. This approach would be the easiest one to administer and
would not seriously disturb the balance of competition. A
volume related charge rate would mean a serious overcharge of
paper/plastic, easily compressible milk and beverage containers.
4. Our second preference would be a uniform ad-valorem-based
charge (option four). In Sweden, where an affiliated company
group of ours is located, such a charge is seriously considered
as an alternative to the existing unit charge. It would be easy
to administer and offer an incentive to industry for more effi-
cient raw material utilization. It would also rather effectively
penalize undesirable excessive packaging.
BRIK 81
PAK>' 2775 Villa Creek Drive. Suite 165-D. Dallas. Texas 75234. USA Telephone 214 243-5831 Telex 73-0139 T P US DAL Cable BRIKPAK
E-25
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Brik Raking,
Ms. Susan Mann May 12, 1978
5. It is vitally important that a charge system does not block
technological advance and innovation. In its present outline,
the proposed charge system offers too little incentive to
industry for development of energy- and raw material-saving
products. To encourage such development, a charge exemption
incentive should be incorporated, by which a low-energy, low-
environmental-impact product could be partially or wholly exempted
from the charge. This would prove very beneficial, especially
within the sector of packaging, where the potential for improved
resource utilization is very great.
6. It is also important that a charge system be phased in over at
least a five-year period to allow for proper adjustment of any
adverse economic effects.
I'm sure there are other areas in the study we have missed, but the
foregoing represents our major and immediate reflections. As for the
general outline, we find the proposals to reflect a more sensible
approach than the various mandatory deposit laws already imposed by
several states in the beverage container area.
Very truly yours,
Beverly Ann Draper
BRIK
PAK 82
-------
N?R
National Food Processors Association Alfred j stokeiy
1133 Twentieth Street N W, Washington. D C 20036 Chairman
Telephone 202/331 - 5900 JJJ
Charles J Carey
President
\A** i *7 i Q*7fi '^®' SornGis
May i f, lyio Executive Vice President
Ms. Susan B. Mann (WH-563)
Public Participation Liaison
Resource Conservation Committee
U. S. Environmental Protection Agency
Washington, D. C. 20460
Regarding: Comments on RCC Staff Background Papers (BP) No. 8 and 9.
Dear Ms. Mann:
We have reviewed the Staff Background Papers and conclude that:
1. The Committee staff has not responded to our previous comments.
On November 17, 1977, we presented comments on the product charge in our
testimony before the Resource Conservation Committee. Apparently the committee
staff has not considered our comments since neither background paper contains any
reference to the issues and concerns we expressed, nor does any other committee
document known to us.
We believe our previous comments are valid and urge that they be taken
into consideration by the RCC staff. We cannot understand how the RCC can
request comments and then fail to announce any consideration or analysis of their
appropriateness to the subject.
2. The Committee staff has not fulfilled its mandate to investigate ". . . the
appropriateness and feasibility . . . " of imposing "solid waste management charges
on consumer products" (SWMCCP). Instead, the background papers present a
"Rationale" and several "Design Issues" for such charges. Apparently, the com-
mittee staff is convinced that such charges are appropriate and feasible and that
therefore it need not conduct the Congressionally-mandated feasibility investigation.
The feasibility of the product charge depends on the total system outcome,
which the staff background papers do not address. To address fully the feasibility
of the concept, we believe that the following questions should be thoroughly
investigated:
Will the net pressure on natural resources be lessened as a result of this tax?
What kind of impact may this tax have upon inflation and employment?
83
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Ms. Susan B. Mann May 17, 1978
Is there a possibility that in some instances the shift in consumption resulting
from this tax would be to goods for which the natural resource supply is much tighter
than the natural resources conserved by the reduced consumption of goods bearing
the solid waste disposal charge?
Is it assumed that changes in consumption patterns that would result from
introducing such a tax will represent an increase in economic welfare?
These questions must be answered to evaluate properly the feasibility of
adopting a national product charge as a tool for conservation of natural resources.
If the answers to these questions do not point clearly to a positive total net benefit,
then the solid waste disposal charge is merely another hidden tax that will increase
the marketing margin between resources and consumption, and add to inflationary
pressures.
Before clear policy directions can be decided by the committee in relation
to the concept of a solid waste product charge, the committee staff must conduct a
considerable amount of additional research and analysis on the economic feasibility
of the concept.
3. The committee staff has not included in its investigation an analysis of
the societal benefits of consumer products. For instance on page of BP No. 8
(para. 1, sentence 2), appears the following statement: "A market system efficiently
allocates scarce resources when every production and consumption activity bears
its full social cost. " Not only social costs, but social benefits must be taken into
account in efficiently allocating scarce resources.
Food processing, an integral part of which is the containers, serves a valuable
social service by preserving perishable foods when they are plentiful to make them
available throughout the year. Thus, food preservation benefits society and lowers
food costs. Without processed foods, the cost of alternative fresh foods during
drought or winter months would be prohibitive. Thus, in determining the "full
social cost" of a food product, the benefit of its availability during periods when
it would otherwise be unavailable, must be considered.
Likewise, many consumer products, such as food packaging materials, are
time-savers for consumers, or provide protection to products that might otherwise
be lost, damaged, destroyed, or stolen. These functional values also benefit
society and must not be ignored by the committee in its investigation of the "appro-
priateness" and "feasibility" of imposing a SWMCCP.
Another societal benefit of processed foods overlooked by the committee is
the disposal of tremendous quantities of food residuals by industry. Otherwise,
these wastes would be discarded into trash cans and home garbage disposals.
-------
Ms. Susan B. Mann May 17, 1978
Any shift away from processed foods to fresh foods will result in an
increase in the generation of household wastes. For example, if there was a
shift away from frozen orange juice concentrate to fresh oranges, the orange peels
would either go down the garbage disposal or wind up in the solid waste stream.
This would be extremely unfortunate because at the present time about 97% of the
residuals from citrus processing operations are utilized for animal feed. The
same is true for many other foods, such as corn and potatoes. With a dramatic
shift from consumption of processed forms of these foods to fresh, the peelings
and husks would be handled by the consumer as waste. Today, 94 and 90%, respec-
tively, of these residuals are utilized by processors for animal feed.
We do not believe that shifting the solid waste problem from the food processing
plant to the home and then to the municipal solid waste contractor or the municipal
sewerage agency is a proper social goal.
4. The committee staff has not recognized the difference between essential
and non-essential packaging. Food is a non-discretionary item for all households.
It must be consumed in order to support life. In our modern society, food cannot
be marketed without processing and packaging. In the case of heat processed foods
(i.e. canned) the package is an integral part of the process itself. Fruits, vegetables,
seafoods, dairy products, meats, grains and combinations of them require proper
packaging for protection from insects, rodents, and microorganisms that compete
with man on a continual basis for these nutrients. Thus, packaging is essential to
maintain the public health and -welfare. The addition of any tax on food packaging
materials, for whatever reason, will only increase the cost of essential food items.
Purchase of packaged food items is obligatory, so the result of the tax can only be
inflationary.
5. The committee has failed to justify the need to establish SWMCCP.
A. Consumers would be charged twice for product disposal, once when
the consumer product is purchased, and again when it is picked up by local solid
waste management authorities for actual disposal. The committee has failed to
justify why consumers should have to spend $60. 00 per ton, rather than the $30. 00
they now pay. Most individual discarders already perceive their solid waste manage-
ment costs as too high. This cost doubling would occur because the committee has
not recommended using the proceeds from the tax to off-set existing municipal
solid waste disposal fees currently being charged individual discarders.
B. Consumers could have a lower standard of living. As noted on
page 3 (para. 2, sentence 1) of BP 8, ". . . our high and rising levels of solid
waste generation are the natural result of ... a high standard of living. " The
committee has felled to investigate whether consumers wish to assume a lower
standard of living, if such would result from the imposition of a SWMCCP.
85
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Ms. Susan B. Mann May 17, 1978
C. Resource conservation objective probably would not be achieved by
imposition of a SWMCCP. The committee has not persuasively shown that consumers
would alter their purchasing decisions as a result of a SWMCCP. If instead, con-
sumers continued to purchase essential packaged products, such as processed food,
in the same amounts as under existing market conditions, the only result would be
an increase in the cost of consumer products equal to the amount of the tax. Canned
foods serve that segment of the public that must have available on the shelf ready-to-
eat foods that do not require refrigeration or freezer capacity. The committee has
not shown that consumers would choose to purchase substitute products over canned
foods if the excise tax of one-half cent were to be imposed on rigid containers.
Therefore, the committee has not shown that the imposition of such a tax would
conserve resources.
If one assumes that the imposition of the one-half cent tax on rigid containers
were to cause a shift in the production of canned food to frozen, dehydrated, or
where possible, fresh foods, the committee staff has not evaluated how much natural
and capital resources would be required to increase production of the substitute
products; nor has the committee staff taken into account the waste of existing
resources invested in food processing facilities that would be idled as a result of
this shift to substitute products. The committee staff should demonstrate that there
would be a definite improvement in the amount of conserved resources and that this
improvement would be worth the estimated $4 billion in increased costs the consuming
public would be required to pay.
D. Existing market conditions are adequate to minimize the use of
packaging materials.
The below quote is taken from the following publication: The Application of
Technology-directed Methods to Reduce Solid Waste and Conserve Resources in the
Packaging of Non-fluid Foods, page 5-14, Final Report, February 1978, prepared
for the National Science Foundation by Franklin Associates:
"Technological innovation has been a strong force in minimizing packaging
materials used in non-fluid foods. Individual packages have reflected technological
innovation by showing a continuous decline in package weight in recent years. Con-
sumer food purchasing habits have been shifting to types of food which have higher
per unit packaging requirements, however, so that overall packaging per unit food
has been fairly steady. If no governmental action is taken, the trend in non-fluid
food packaging will most likely continue to be steady in terms of packaging per unit
food, or perhaps go down slightly.
"Governmental regulation can also be targeted directly at non-fluid food
packaging. Examples of regulations are mandatory deposits, government purchase
specifications, or consumer education programs. We conclude that regulations of
86
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Ms. Susan B. Mann May 17, 1978
this targeted type will generally produce only marginal benefits, if any, with
respect to solid waste reduction and resource conservation. In fact, continuing
technological innovation along historical lines would probably be more effective
than targeted regulatory activity because regulation generally produces undesirable
side-effects.
"Indeed, it would appear that the free market forces presently at work are
resulting in a continuing decline in the per-unit packaging of non-fluid foods. Even
without governmental action, this trend towards national resource conservation
and waste reduction is progressing. "
6. Conclusion. Based on information available to us from the committee.
there is no rational reason to establish solid waste management charges on consumer
products. If the primary intent of the SWMCCP is to achieve conservation of
natural resources, other alternatives offer greater opportunities for success.
Sincerely,
cc: Packaging Tax Subcommittee
87
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National Food Processors Association Aiired j
1133 Twentieth Streel N W . Washington. D C 20036 Chairman
Telephone 202/331-5900 ESa.22,
Charles J Catey
frestdenl
Mav 17 1978 lre' Someis
way i f, if 10 Executive Vice President
Ms. Susan B. Mann (WH-563)
Public Participation Liaison
Resource Conservation Committee
U. S. Environmental Protection Agency
Washington, D. C. 20460
Regarding: Comments on RCC Staff Background Papers (BP) No. 8 and 9.
Dear Ms. Mann:
We have reviewed the Staff Background Papers and conclude that:
1. The Committee staff has not responded to our previous comments.
On November 17, 1977, we presented comments on the product charge in our
testimony before the Resource Conservation Committee. Apparently the committee
staff has not considered our comments since neither background paper contains any
reference to the issues and concerns we expressed, nor does any other committee
document known to us.
We believe our previous comments are valid and urge that they be taken
into consideration by the RCC staff. We cannot understand how the RCC can
request comments and then fail to announce any consideration or analysis of their
appropriateness to the subject.
2. The Committee staff has not fulfilled its mandate to investigate ". . . the
appropriateness and feasibility . . . " of imposing "solid waste management charges
on consumer products" (SWMCCP). Instead, the background papers present a
"Rationale" and several "Design Issues" for such charges. Apparently, the com-
mittee staff is convinced that such charges are appropriate and feasible and that
therefore it need not conduct the Congressionally-mandated feasibility investigation.
The feasibility of the product charge depends on the total system outcome,
which the staff background papers do not address. To address fully the feasibility
of the concept, we believe that the following questions should be thoroughly
investigated:
Will the net pressure on natural resources be lessened as a result of this tax'
What kind of impact may this tax have upon inflation and employment'
38
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Ms. Susan B. Mann May 17, 1978
Is there a possibility that in some instances the shift in consumption resulting
from this tax would be to goods for which the natural resource supply is much tighter
than the natural resources conserved by the reduced consumption of goods bearing
the solid waste disposal charge?
Is it assumed that changes in consumption patterns that would result from
introducing such a tax will represent an increase in economic welfare9
These questions must be answered to evaluate properly the feasibility of
adopting a national product charge as a tool for conservation of natural resources.
If the answers to these questions do not point clearly to a positive total net benefit,
then the solid waste disposal charge is merely another hidden tax that will increase
the marketing margin between resources and consumption, and add to inflationary
pressures.
Before clear policy directions can be decided by the committee in relation
to the concept of a solid waste product charge, the committee staff must conduct a
considerable amount of additional research and analysis on the economic feasibility
of the concept.
3. The committee staff has not included in its investigation an analysis of
the societal benefits of consumer products. For instance on page of BP No. 8
(para. 1, sentence 2), appears the following statement: "A market system efficiently
allocates scarce resources when every production and consumption activity bears
its full social cost. " Not only social costs, but social benefits must be taken into
account in efficiently allocating scarce resources.
Food processing, an integral part of which is the containers, serves a valuable
social service by preserving perishable foods when they are plentiful to make them
available throughout the year. Thus, food preservation benefits society and lowers
food costs. Without processed foods, the cost of alternative fresh foods during
drought or winter months would be prohibitive. Thus, in determining the "full
social cost" of a food product, the benefit of its availability during periods when
it would otherwise be unavailable, must be considered.
Likewise, many consumer products, such as food packaging materials, are
time-savers for consumers, or provide protection to products that might otherwise
be lost, damaged, destroyed, or stolen. These functional values also benefit
society-and must not be ignored by the committee in its investigation of the "appro-
priateness" and "feasibility" of imposing a SWMCCP.
Another societal benefit of processed foods overlooked by the committee is
the disposal of tremendous quantities of food residuals by industry. Otherwise,
these wastes would be discarded into trash cans and home garbage disposals.
89
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Ms. Susan B. Mann May 17, 1978
Any shift away from processed foods to fresh foods will result in an
increase in the generation of household wastes. For example, if there was a
shift away from frozen orange juice concentrate to fresh oranges, the orange peels
would either go down the garbage disposal or wind up in the solid waste stream.
This would be extremely unfortunate because at the present time about 97% of the
residuals from citrus processing operations are utilized for animal feed. Th e
same is true for many other foods, such as corn and potatoes. With a dramatic
shift from consumption of processed forms of these foods to fresh, the peelings
and husks would be handled by the consumer as waste. Today, 94 and 90%, respec-
tively, of these residuals are utilized by processors for animal feed.
We do not believe that shifting the solid waste problem from the food processing
plant to the home and then to the municipal solid waste contractor or the municipal
sewerage agency is a proper social goal.
4. The committee staff has not recognized the difference between essential
and non-essential packaging. Food is a non-discretionary item for all households.
It must be consumed in order to support life. In our modern society, food cannot
be marketed without processing and packaging. In the case of heat processed foods
(i. e. canned) the package is an integral part of the process itself. Fruits, vegetables,
seafoods, dairy products, meats, grains and combinations of them require proper
packaging for protection from insects, rodents, and microorganisms that compete
with man on a continual basis for these nutrients. Thus, packaging is essential to
maintain the public health and welfare. The addition of any tax on food packaging
materials, for whatever reason, will only increase the cost of essential food items.
Purchase of packaged food items is obligatory, so the result of the tax can only be
inflationary.
5. The committee has failed to justify the need to establish SWMCCP.
A. Consumers would be charged twice for product disposal, once when
the consumer product is purchased, and again when it is picked up by local solid
waste management authorities for actual disposal. The committee has failed to
justify why consumers should have to spend $60. 00 per ton, rather than the $30. 00
they now pay. Most individual discarders already perceive their solid waste manage-
ment costs as too high. This cost doubling would occur because the committee has
not recommended using the proceeds from the tax to off-set existing municipal
solid waste disposal fees currently being charged individual discarders.
B. Consumers could have a lower standard of living. As noted on
page 3 (para. 2, sentence 1) of BP 8, ". . . our high and rising levels of solid
waste generation are the natural result of . . .a high standard of living. " The
committee has failed to investigate whether consumers wish to assume a lower
standard of living, if such would result from the imposition of a SWMCCP.
90
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Ms. Susan B. Mann May 17, 1978
C. Resource conservation objective probably would not be achieved by
imposition of a SWMCCP. The committee has not persuasively shown that consumers
would alter their purchasing decisions as a result of a SWMCCP. If instead, con-
sumers continued to purchase essential packaged products, such as processed food,
in the same amounts as under existing market conditions, the only result would be
an increase in the cost of consumer products equal to the amount of the tax. Canned
foods serve that segment of the public that must have available on the shelf ready-to-
eat foods that do not require refrigeration or freezer capacity. The committee has
not shown that consumers would choose to purchase substitute products over canned
foods if the excise tax of one-half cent were to be imposed on rigid containers.
Therefore, the committee has not shown that the imposition of such a tax would
conserve resources.
If one assumes that the imposition of the one-half cent tax on rigid containers
were to cause a shift in the production of canned food to frozen, dehydrated, or
where possible, fresh foods, the committee staff has not evaluated how much natural
and capital resources would be required to increase production of the substitute
products; nor has the committee staff taken into account the waste of existing
resources invested m food processing facilities that would be idled as a result of
this shift to substitute products. The committee staff should demonstrate that there
would be a definite improvement in the amount of conserved resources and that this
improvement would be worth the estimated $4 billion m increased costs the consuming
public would be required to pay.
D. Existing market conditions are adequate to minimize the use of
packaging materials.
The below quote is taken from the following publication: The Application of
Technology-directed Methods to Reduce Solid Waste and Conserve Resources in the
Packaging of Non-fluid Foods, page 5-14, Final Report, February 1978, prepared
for the National Science Foundation by Franklin Associates:
"Technological innovation has been a strong force in minimizing packaging
materials used m non-fluid foods. Individual packages have reflected technological
innovation by showing a continuous decline in package weight in recent years. Con-
sumer food purchasing habits have been shifting to types of food which have higher
per unit packaging requirements, however, so that overall packaging per unit food
has been fairly steady. If no governmental action is taken, the trend in non-fluid
food packaging will most likely continue to be steady in terms of packaging per unit
food, or perhaps go down slightly.
"Governmental regulation can also be targeted directly at non-fluid food
packaging. Examples of regulations are mandatory deposits, government purchase
specifications, or consumer education programs. We conclude that regulations of
91
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Ms. Susan B. Mann May 17, 1978
this targeted type will generally produce only marginal benefits, if any, with
respect to solid waste reduction and resource conservation. In fact, continuing
technological innovation along historical lines would probably be more effective
than targeted regulatory activity because regulation generally produces undesirable
side-effects.
"Indeed, it would appear that the free market forces presently at work are
resulting in a continuing decline in the per-unit packaging of non-fluid foods. Even
without governmental action, this trend towards national resource conservation
and waste reduction is progressing. "
6. Conclusion. Based on information available to us from the committee,
there is no rational reason to establish solid waste management charges on consumer
products. If the primary intent of the SWMCCP is to achieve conservation of
natural resources, other alternatives offer greater opportunities for success.
Sincerely,
cc: Packaging Tax Subcommittee
92
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Eugene F. Mooney
JULIAN M CARROLL
SECRETARY \$&&a'5sS:&>/ GOVERMOH
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF ENVIRONMENTAL PROTECTION
JOHN A. ROTH
COMMISSIONER
FRANKFORT, KENTUCKY 4oeoi
12, 1978
Ms. Susan Mann
Public Participation Liaison
Resource Conservation Committee
401 M St., S. (f.
Washington, D. C. 20460
Dear Ms. Mann:
In response to Barbara Blum's letter of April 18, 1978, addressed
to all interested persons, I do not favor a national waste disposal charge.
There are several reasons for my position. The first is that some
states are already doing this. This approach is responsive to the needs in
a given state. Secondly, this is no good basis for distributing money
among the states. This results in another federal re-distribution of the
wealth which has already reached an unconscionable level. Thirdly,
administrative costs at the federal level would tend to increase the costs
of such a program to the detriment of all concerned.
Sincerely,
Norman E. Schell, Director
Division of Hazardous Material
and Waste Management
NES:vlr
93
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Commissioners
Robert E. Sweeney
Seth Taft
George V. Voinovich
COUNTY OF
CUYAHOGA
Stephen J Sebesta. County Sanitary Engineer
May 11, 1978
Susan Mann, Public Participation Officer
Resource Conservation Committee
401 M St., S. W.
Washington, D. C. 20460
Re: Opposition to Product Charge
Dear Ms. Mann,
Thank you for this renewed opportunity to express my total rejection of
the Disposal Charge concept. Although I am a member of the Sierra Club and
of the National Coalition on Solid Waste Management, the arguments presented
in the enclosed essay are my own, and reflect no recent contact with my
colleagues in those organizations.
I am writing, therefore, as a member of the staff of the Solid Waste
Management Branch in the Department of the Sanitary Engineer of Cuyahoga
County (Greater Cleveland, Ohio) and reporting on the convictions that have
evolved as I have spent the last year at this vantage point. You may know
that our County is well along in a project that will recover the Btu value
from residential trash, making steam and selling it to a cluster of local
industries.
An important feature of the Implementation Plan that is now nearing
completion has been the review process exercised by a system of successive
committees. Ultimately bonds will be offered for sale. These bonds will be
secured on the basis of a covenant among the County and the 40 or so municipalities
that will be providing the fuel and half a dozen industries that want the
steam. In designing the Letters of Intent and the formulae for tipping fees
and steam pricing we have spent considerable time in discussions of the equity
aspects that must be considered.
The question of "property rights" in the various fields of waste management
agitates many of us. My contention is that the fact of dealing with a "negative
value" makes it essential to carry out a new analysis of what sorts of "profit
motive" ought to be included. One thinks of the interests of a bull dozer
operator regarding the inches of dirt that must be used to cover a landfill, as
an instructive example.
Sincerely yours,
Ellen Knox
Solid Waste Specialist
94
SOLID WASTE MANAGEMENT OFFICE — 75 Public Square. Cleveland. Ohio 441 1 3. (21 6) 623-7545
OFFICE OF CUYAHOGA COUNTY SANITARY ENGINEER
-------
WHY THE PRODUCT CHARGE CONCEPT WOULD SERVE TO
DISCOURAGE RATHER THAN PROMOTE PROPER SWM
{Jf „ <•*'
fr
I After review of the documents you have supplied regarding the
/ proposed Product Charge as a means to encourage the conservation of
the materials, I am supplying the following analysis of why I have
been opposed to this scheme for many years. I hope that my arguments
have evolved with time, and that this "Theory of Negative Value" will
find some interested readers.
Hy opposition to the product charge goes back to Jerry Kretchmer's
efforts in NYC, where we seemed to be encouraging the use of aluminum and
plastic over steel and paper, back in the "penny a pound" era. Most of
my convictions have been refined in successive Bottle Bill campaigns,
so that I rely upon such criteria as:
- Minimum task energy (as Phys. Soc. at Princeton)
- Embodied energy {as aluminum metal can be refabricated
for only 555 additional)
' * - The hierarchy of "l.'hat is Besff'as related to a "diameter"
• ' of the closed loop for the recycling options, each of
h-j> these site specific, material specific, technology
lj specific, but, fortunately translatable in signifi-
cantly useful instances into simple Btu calculations).
WE SHOULD IMMEDIATELY GET RID OF HYBRID (bi-metal 1ic) CAMS, if
only out of compassion for those members of church groups who are, to
this day, trying to separate aluminum ends from steel sides in voluntary
'X can recycling efforts, but also TO PERMIT MORE EFFECTIVE APPLICATION''^ 1 )
aluminum skimming and (2) magnetic recovory from mixed RSW. '"
Here I wish to introduce ny thrce-diroensior.al Flow Chart that is
meant to help present the Theory of.Negative Value that has to be
included in the analysis of the costs, prices and values involved in any
waste disposal scheme. See Figure 1.
^ 3 Materials, lying in the earth's crust, have a value of 0 to which
the successive production processes add increments. For simplicity I
have labeled these stages as EXTRACTION, REFINING, FABRICATION, CQTTLING,
^ DISTRIBUTOR and GROCER; "to serve the exposition of relationships in
choices in Solid Waste Ma nagemerst the chart shows t\/o paths (through D*
and through VI*) in the lower right hand sector, with a myriad of others
conceivable. The activities below the line impose costs upon the general
public as the operations of Collection, Resource Recovery and "Disposal"
reduce the liability of something bulky and srcelly and neutralize it so
that it can, once again, lie inert in the earth's surface, at O1. The
fact that 0 and O1 are not the same recognizes that a great deal of
£ entropy has been added to the universe in the various steps of refine-
j^ ment, dispersal, reconcentration. The cost of transportation, which
'•' .j ' '- - •' ' • '• '• •• 'i "tj i~ *.iu. .-. /J/il»'t«- t ".* ?j H • tjC t'*'tf«
-------
(A Flow Chart for Solid Waste Management issue analysis)
CONSUMPTION
P^
GROCER
DISTRIBUTING
BOTTLING
FABRICATING
RE-USE
SEGREGATE
SEPARATE
MIXED TO RR
MIXED TO DUMP
LITTERING
Ellen Knox
Solid Waste Program
Cuyahoga County Sanitary Engineer
75 Public Square
Cleveland, Ohio 44113
"GETTING A DRINK"
or
THE THEORY OF NEGATIVE VALUE
(or
The Costs of Convenience
or
The Price of Pop
or
What Is Best?)
(WORSE)
May, 1978
-------
(You saw an earlier version of this last October, when I was
sounding off about the superiority of a mandatory refund value for
beverage containers.}'"As^ argument against the product charge is
based on this contention:
CRUCIAL IN THE "COST" OF DISPOSAL IS THE "SELECTION OF DISPOSAL
ROUTE". This choice is made, by the Consumer, at the moment when the
item's value changes from positive (the peak value of a pop bottle is
that moment when it is delivering the chilled beverage; thereafter,
because it is bulky and because it might start to smell, it becomes a
liability, with NEGATIVE VALUE) to negative. The various routes
available range all the liW from reuse to littering (the hierarchy of
these can be elaborated,"obviously) and the costs to the public sector
vary over many orders of magnitude. (Surely someone can supply the
costs of "disposing" of a Sunday Times).
,
I contend that the "cost" of disposing of a Chlqrox bottle,, say
f"^ is going to r.epenci far more on the cultrual and institional factors that
'*# prevail in the community than upon the weight or volume of the jug.
There are people in Greater Cleveland who purchase their laundry bleach "0
,.j ... returnable* (take back the empty; buto a new one filled); not a nationally"
advertised brand name, you can bet. I have never attempted to quantify
the vertical scale on this diagram, although I imagine it might be
possible (and worthwhile, even) for each specific component of the waste
stream.
£ (Earlier I referred to my Flow Chart as 3-D. To expla'n, I use
Time from left to right (x) although this can as well mean succession
of processing steps, or reconcentrating the commodity. Vertically (y)
v*£ I use "value" which may or nay not be expressable in dollars. I do ciLu
"" distinguish between internalized and externalized costs in the upper
right hand sector, since the rising "value" is meant to shovi only the
economist 's "value added" increment. The externalized costs, in the
various kinds of waste management carried out in the "hinterland"
(mine tailings, deep well injection, colonialized populations) don't
-. show up. Some of these considerations, however, will appear when one
^^ conceives of the third axis, (t}j normal to the plane of the paper;
here is where the costs, in waste heat, or increased entropy, would be
.") represented. I hope this is enough elucidation for present purposes.)o
There are three asterisks (*) on the Flow Chart. The first is P*,
which is the Price paid at the check out in the grocery line. (This
Chart evolved for purposes of analysing Bottle Bills, as should be
evident). P* can represent the costs, up to the point of purchase,
-— pretty well. Value is added further as the consumer -to- be carts the
beverage home, and chills it, towards the moment of irresistable thirst
•Lt:; and then its gratification; peak value, or C.
If a "product charge" has been introduced into this system, then
P* should be higher (in dollars) although not in value. (People who
..••} believe in this sort of thing would say that the consumer would but1
fewer bottles of pop if the price went up). The "value" at C would not
be increased, although the costs might have gone up further; making the
gratification a rarer privilege perhaps.
97
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BUT NOTHING IN THIS PAST HISTORY HAS INFLUENCE UPON WHAT THE
CONSUMER NEXT DECIDES TO DO WITH THE EMPTY.
L Now, please comtemplate the two remaining asterisks,. 0* and W*.
/ For a given community the local government can decide what they see as
a reasonable service in SWM to offer to their citizenry. Using tax money,
they collect the trash and carry it "away" (since it takes up space and
might smell) and the cost is the distance downward from the horizontal
(0) line to the D*. (D* meaning Disposal). It is the obligation of
government to make this cost, in the realm of negative value, a reasonable
one, protecting the fastidious from the sloppy, and not unduly burdening
the thrifty with costs imposed by the extravagant.
(The inverted logic of the current "anti-litter" legislation, such
as HB 1171 in Ohio, which is modeled on something that seems to have
been adopted in California, show up in taxing those who are "disposing
properly" in order to raise money to take care of the mess left by those
who "litter").
I note with dismay that these bills are baited with the possibility
of "revenues" to help pay for SV.'M, and it is going to take a high order
of self-control for a city council to decline money that comes offered
as "free". The nibbling is so tiny, in each instance, that it is woe-
fully hard to detect. Only by looking "upstreaV", to figure out who is
p actually unloading a "cost of doing business" from the private sector
onto the public sector, is there any hope of allocating the cost onto
.£ the beneficiary. (This argument applies nicely, 1 contend, to some
issues in Hazardous Waste Management and certainly into the question of
who should pay to store the hot wastes from nuclear power generation).
The final asterisk, which is called W*, means WORSE or even WORST.
This is meant to suggest that there are all sorts of industries whose
livelihood depends upon having the consumer select a longer path for
disposal instead of a shorter one. Mayor Yorty, in his infamous campaign,
promosed the Los Angeles housewives that they never again would have to
separate their garbage. Ah, the entropy of it all.
A conceot from Earth Science: it takes work to mix things. It takes
work to sort things. But, \.-hen things occur already sorted it takes
rather little work to r.aintain this distinction; namely, newspapers, in
a household, can be piled together and reed never get in with the coffe*
grounds (To discuss this elegantly one would want to use either Infor-
mation Theory or Thermodynamics; but the general feeling that there
are better ways to do things amounts to the same conclusion).
Here is the point to state again that my PRIMARY rejection of the
£ Product Charge is that it puts no pressure at 11 upon the consumer to
decide in favor of & better rather than a worse disposal path He may
even oelieve, if he reads the papers and has hoard about a "product
charge that by paying the extra for his selected packaging material
(Cr what not) he has already assumed his proper share of the "costs"
Sn^T^mn^'rlr..^1 J^tifl'edjn selecting the disposal route that is
MOST COflVtHICflT for him, rather than something thrifty. I used this
same argument about the illusion that accompanies the "disposable bottle"
since the poor cus'to-ner, knowing that he has already paid extra for a
Jon-returnable, feels entitled to forget about it as soon as possible.
(Parenthetically, since what rt)am doing is emptying my head of what is
98
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in it at this moment on May 8, 1978, who is going to do anything about
the problem that underage beer drinkers are still tempted to throw empty
bottles out of a car onto a roadsie, rather than have the cop catch them
with illegal booze?}.
£ Let us now try to assess the interest], who want to see D* be a
'\. minimum (this means higher on the page, nearer zero): The poor, the
'^ thrifty, the Service Directors, the City Councils facing their budgets.
See also the stated purposes of RCRA.,
^ / (A').- These relationships are recognized in Congress, of course.
/One could go back to the hearings on .some proposal, considered by Ways
\-\ /and Means (about 1972) when Martha Gfrffiths wanted to use Federal money
i to pay for Resource Recovery Projects. The critics called this a
\ \ "haemor'hage". Looking at this in today's light, Revenue Bonds seem to be
about right, in permitting the accumulation of the necessary capital to
construct a capital intensive processing facility (to "restore the value"
to the trash). Bill Franklin first brought this to my notice at the
meeting in St. Louis, May 1972. Only a shrewd city council can maintain
I a clear vision of what they ought to pay, and what they ought not to!
i
] The groups that support themselves by some transaction in the process
I from converting the trash (at W*) back to a neutral value (O-O1) are the
! container manufacturers (Baron Bich, having prospered from the throwaway
,' Bic pen, is said to be looking at panti-hose as a new line for making
j profits), the trash collectors, the trash haulers, the landfill operators,
It the bulldozer manufacture. On e application of this "Theory of Negative
:i Value" is to help scrutinize those social functions that do not produce,
J'j but rather reduce liabilities.
x The Brewers, who earlier were allied with the container manufac-
turers, are less entrenched. The Oregon experience shows no reduction
in ounces of beer sold through a return to returnables. The Aluminum
,-<•. industry, nation wide, is favoring the mandatory refund as a nest way of
'* getting refined aluninum reconcentrated to make new cans. Supermarkets,
with their notoriously slim profit margins, are anxious about the addi-
tional floor space that would have to be assigned to managing returnable
containers; but nothing stops them from putting a price on the bottles
and the cans that represents the costs of this additional handling,
since they are still below the prices that have to be charged for
containers that cannot be used several times.
Here, as anywhere I can, I wish to add a plug for figuring out how
to protect the small grocery store proprietor in the return to return-
ables. Someone must have noted the danger in letting hin "keep" the
desposits that don't get claimed, since this could lead to a set of
subterfuges so that he would be tempted to find ways to refuse the
refund to orphan containers. But, as a resident of a large ME declining
city, I feel strongly about the role of the small shopkeeper as critical
to supporting neighborhood life.
,, f; There are further implications to be gained fron an examination
^ of this lower right hand sector of the flow chart. This is, after all, the
' site of nuch of "the public trough". If one is minded to view govern-
ment as "little more than a mechanism to accelerate the pouring of
concrete", the functions of restoring-value-to materials-tnat-are-
liabilities make up a let cf the concrete pouring interests, in STP's.
99
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Coo -.
Jc?-
Furthermore, it is against the interest of the bond houses that will
float the issues that pay for a Resource Recovery System Facility to
,
bi-weekly collections on lower income neighborhoods. (!)
This completes my presentation of the Flow Chart as a tool for
analysing the allocation of costs and benefits in SUM. In an earlier
use I showed where the "costs of convenience" appear, and the inconsis-
tencies between what is payable as P* with what costs are transferred
to the public sector. One example is the illusion that attends paying
a higher price for a "disposable" bottle, making the purchaser feel
that he has already acquitted his responsibil ity , in paying this incre-
ment, unaware that this money doesn't ever trickly over to the point
in the system where his extra burden must be dealt with. The negative
area of "convenience" applies where a community will decide whether
is own populace are prepared to cooperate in some Source Segregation
techniques, all of this as "cottage labor" of one sort of or another
that" serves to "restore some value" to the trash, and thereby save the
city money in subsequent SWM. (Marblehead more amenable than Somerville,
for example).
The above considerations, amplified, can be used to show why the
various attempts at "averaging"i proposed for a Product Charge, work
precisely against the stated goals of the legislation. The thrifty are
made to pay extra in some degree, but^should certainly not be extended.
The level of compromise might be adapted to the practice of tying
sewage treatment charges to water consumption bills. And the tidy and
thrifty do, in fact, benefit from having trash barrels are emptied on
a regulat basis, however much might have been salvaged.
Having done ny best to argue against the Disposal Charge, I will
simply hold uy critique of the alternatives discussed in No. Z\ Syste-
matic analysis, based upon thermcdynamic criteria, would do won'ders in
dealing with some of those inconsistencies. I still go back to David
Rose's article in Physics Today, February 1972, for a fruitful approach
to value. I will also send a copy of this manuscript to Mike Dever,
at M.I.T., in hopes of getting on the trail of the kind of work that
I see as required. I haven't been reading the Technology Review recently,
but this is a place where this level of approach has been found in the
past.
Rather than comment on Mo. 9, despite all my marginal notes, I
will here stress my finding that the "cost of disposal for a particular
item" is determined primarily by the decision reached by the disposer,
and only third or fourth order by the nature of the item. I look at
Page 8, Section 3, v;i th dismay, since I differ with the starting
assumptions, vehemently. The fact that we are dealing with "negative
value" distorts assumptions that work in the positive "value adding"
sector of the economy. Services vary. I am also not expanding here
on my thesis that "THERE IS 110 SUCH THING AS EXCESS PACKAGING", in as
much as the supermarket proprietor has made his selection on economic
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grounds, replacing people with layers of stuff.
Tax reform cannot be dodged indefinitely. Barry Commoner's
speech, in Cleveland, for Sun Day, reminded me that one can look
upon the proliferation of the private car and suburban sprawl and hiah
way building programs as no more than manifestations of the need to
have plenty of containers (gas tanks) in which to store the petroleum
that the extractors found it profitable to pump out of the earth's
crust (and, thanks to IRS again, even more profitable to sell below
cost).
Most vehemently, do not sugar this legislative proposal with the
. cjLance__fAr- enough, already. Communities must learn, as soon as oossiblp
y what it is that they are subsiding through .their trash collection and
L disposal budgets.
Ellen Knox
Solid Waste Specialist
Cuyahoga County Sanitary Engineer'.'.'Dept.
75 Public Square, Cleveland, Ohio ' 44113
(Prepared as comment for the Resource Conservation Committee,
regarding the Product Charge Proposals, May 10, 1978)
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MACMILLAN
THOMAS P.. OBUU11, J» REPLY TO
VIPF PRESIDENT UAIIIINCTON OFFICE
I 730 BHODE ISI AVD AVE , MV
WAiniNOTON, D r W3R
202-293-5805
May 15, 1978
Ms. Barbara Blum
Chairperson
Resource Conservation Committee
401 M Street S.W.
Washington D.C. 20460
Dear Ms. Blum:
The following comments are submitted in connection with Background
paper #8 Rationale for Solid Waste Desposal Charge Legislation.
Waste limitations and enforcement would be economically superior
to the government putting a "pretax'on potential waste.
Private enterprise is in a better position to make economic decisions
connected to waste disposal than is government.
This tax conceivably could be interpreted as being a tax on the press
if so, there could be constitutional complications.
Sincerely
THOMAS E. DRUMtt JR.
Vice President
MACMILLAN. INC. 866 THIRD AVENUE, NEW YORK. NEW YORK 10022
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May 12, 1978
COMMENTS ON RESOURCE CONSERVATION COMMITTEE STAFF BACKGROUND PAPER NO. 9
by
Gino Crocetti*
Cnair, Solid Waste Management Subcommittee, Citizens Union Research Fdn.
The Solid Waste Management Subcommittee of the City Planning and
Budget Committee of the Citizens Union Research Foundation of New York
City has been studying the solid waste management problems of New York
City and New York State and the Metropolitan Region. We are concerned
with all aspects of solid waste management from landfill to solid waste
reduction programs.
This concern with the entire gamut of solid waste management issues
makes it difficult for these comments to restrict themselves to the sole
issue of designing a solid waste disposal charge to achieve"proper pricing
of solid waste disposal costs." This is the language of your covering
letter of April 18, 1978. I assume that what is actually meant is that
the issue is one of proper pricing of products so as to reflect their
actual solid waste disposal costs to public bodies. The price of solid
waste disposal costs which could be added to various products appears
to be the fundamentally wrong part of the issue to address. The real
issue is not how to pay for solid waste disposal costs, but the fact
that they have become so large and that they seem likely to become an
ever greater burden on the nation's economy. No one worried about how
to pay for these costs until they became too large.
The significance of this distinction is that if the size of the
total bill is seen as the crucial factor, a product charge will be de-
signed to reduce total solid waste production rather than simply to
fund the current costs in a new way. The theory that the marginal price
rise produced by product charges only designed to cover current solid
waste disposal costs will result in significant market pressures to re-
duce total solid waste production is, I believe, in error.
It is often stated by such analysts as Leonard S. Wegman that the
allocation of a charge to cover solid waste disposal costs is the last
and only missing cnarge needed to make products' prices totally reflect
their actual costs to society. This is not true. Our future costs re-
sulting from current misuse of resources are not reflected in current
product prices. Thus, pricing policies that reflect lost opportunity
costs both in the present and in the future would be needed to close
the gap in current price policies and make prices equal costs. Since
future opportunity costs are difficult, at best, to estimate, it is
reasonable to make policy based on known resource availability and
to encourage efficient use of resources by present "subsidy" which re-
flects our provision for future opportunity costs.
There is the additional danger that to simply fund current disposal
costs will reduce the demand for better solid waste management practices
and thus lead to long-term inefficiency and waste.
I would also like to state that a product disposal charge cannot
be seen as an alternative to outright regulation of solid waste production.
Simply funding current costs, as I note above, solves nothing. The compli-
cated taxing structure needed to internalize the costs will raise the
costs of the disposal process significantly. The only real savings to
be made are by policies which reduce the amount of solid waste which the
municipalities have to handle. As your paper points out, most current
recycling of post-consumer waste is after bulk collection by the cities
which is the most expensive part of the collection and disposal process
lumped as disposal in your cost calculations.
As you point out one of the important selling points of the product
disposal charge is the potential of the charge for encouraging recycling.
* These comments are made individually.
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May 12, 197fa Crocetti Comments on Staff Background Paper No. 9 /
This combining of two goals on one vehicle leads to a paradox of sorts.
There is no evidence to indicate that the marginal reduction in municipal
solid waste disposal costs is linearly related to the quantity of solid
waste. In fact, in larger cities the capital costs and long term pension
costs (often carried on a cash basis as in NYC) will lag behind reductions
in total solid waste quantities in their downward trend. Also, the actual
collection and disposal costs themselves are not linear to quantity and
the continual readjustment of routes and staffing are themselves costly,
though necessary parts of reducing total costs in the face of reduced
demand.
Specific Comments on the Paper;
On page 5 and elsewhere it is assumed that it is proper to exempt
durable goods from inclusion in a product disposal charge because of
their long life. Actually, on the theory that everything which is manu-
factured will eventually have to be thrown away, which is certainly true
of durables, it is proper to charge durables just the same as other
products. Any adjustment should be based on the fact that they are, to
some extent, thrown out in a different manner which might be more or
less expensive than normal refuse. Similarly, there might be some
adjustment of the payout (if any) to cities to reflect the fact that
most of the current durable manufacture will not be thrown out for
several years. The counterargument to that is that there is a large
quantity of durable and non-durable goods in the pipeline now and at
the moment that the charge is instituted there will still be a deficit
of the amount needed to dispose of the goods in use or in stock at that
time. The total disposal cost of the durable goods in stock^is probably
not that much greater than the non-durable goods in stock*and need not
justify an entirely different treatment.(*or in use). Thus the special
treatment, if any, of durables is not only, and maybe not primarily,
to be based on life-span.
If the purpose is to'fund disposal, all things which are disposed
of should be included: grass, books, etc.
If the purpose is to make product prices reflect their currently
unpriced costs, then including only•disposal costs is inadequate. What
is needed is a product tax based on many factors. The advantage is that
one administrative structure could handle many tasks through one additional
paper process.
On page 7 there is a brief discussion of the possibility of having
a charge levied on virgin materials and it is asserted that such a charge
is unrelated to municipal solid waste costs. Current costs are, of course,
the costs referred to, but the charge is a future program and actions which
may affect recycling, resource recovery, etc. are not unrelated to future
municipal solid waste costs.
I agree that the proper place for adjusting geographical differences
in solid waste disposal costs is through revenue allocation and not
through the charge mechanism itself.
The question of where to assess the charge:is probably best made at
the point of fabrication. There are further weaknesses of trying to
assess a charge at the bulk material manufacturing point. Combinations
of packaging materials may be substantially more difficult to recycle
than products made only out of one material. Since resource recovery will
likely be a major portion of the future municipal solid waste disposal
system, this difficulty may significantly affect costs and should be
accounted for. Bi-metal cans are a good example.
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May 12, 1978 Crocetti Comments on Staff Background Paper No. 9 /
On pages 20-21 it is suggested that the charge could be coupled with
a reqxiirement that municipalities fund "cost-effective" resource recovery
operations in order to be eligible for revenues from the program. The only
justification for this approach is that it is an opportunity to add an
incentive to the general requirements of the Resource Recovery and Con-
servation Act to plan for more effective solid waste management. It
would be extremely foolish if we did not take the opportunity to use
the same incentive to require that municipalities foster source reduction
programs, which can include education, and source separation programs
where appropriate (which is most locations). Resource recovery, as is
pointed out elsewhere in the paper, is not itself likely to save that
much money for municipalities. It is simply a better way of coping with
the refuse which is there. In New York City, for instance, it is just
possible that the resource recovery plants will be able to compete with
current disposal practices economically and the main argument for them
remains that they will be much cheaper in the future and that they con-
serve resources generally. The collection charges are three or four or
even seven to ten times the disposal costs (this use of disposal costs is
different than the inclusive usage in the Paper and elsewhere in these
comments). In any case it is source separation and source reduction
which are truly able to save municipalities money and it is these which
should be most encouraged in the early stages.
Naturally this argument presupposes a revenue sharing approach to
the use of the funds generated by a product disposal charge. I favor
such an approach. Even though the effect of such revenue sharing would
be to reduce the property taxes and institute instead a tax which falls
on the population at large in a generally per capita fashion, and is
thus regressive, a properly designed product charge which is based on
the idea of reducing solid waste and diverting it before it enters the
municipal solid waste stream would end up saving much more money for
all citizens (who pay indirectly for most of the property taxes anyway)
than even the lowest income sectors would pay in additional product
costs at the store. The one group for which this would not be true are
those who live on fixed incomes of one sort or another.
Gino Crocetti
652 West 163rd Street
New York, New York 10032
(212) 568-7692
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PAPERBOARD PACKAGING COUNCIL
1800 K STREET. N W . WASHINGTON. D.C 20006 • (202) 872-0180
May 26, 1978
Ms. Susan Mann
Public Participation Liaison
Resource Conservation Committee
401 M Street, SW
Room 2624
Washington, DC 20460
Dear Ms. Mann:
Enclosed is a statement of the written views of the Paperboard Packaging Council
on the Solid Waste Disposal Charge proposal being considered by the Resource
Conservation Committee.
The views given in this statement supplement the testimony by the Paperboard
Packaging Council during the Resource Conservation Committee public meeting
on November 17, 1977.
Sincerely,
A
Spefu*£r A. Johnson
(Vector of Government Relations
Enclosure
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PAPERBOARD PACKAGING COUNCIL
1800 K STREET-. N W . WASHINGTON. D C 20006 • (202) 872 0180
PAPERBOARD PACKAGING COUNCIL
Recommendations on the
SOLID WASTE DISPOSAL TAX
Being Considered by the
Resource Conservation Committee
May 24, 1978
The Paperboard Packaging Council is a national trade association of the
folding carton industry. Members of the Council produce about three-quarters of
the folding cartons used in the United States.
Folding cartons are used to package thousands of consumer products
including medicines, cosmetics, tobacco products, detergents, hardware, sporting goods
toys and games. More than half of the nation's folding cartons are used to
package foods, such as cereal, dried fruit, cake, cookies, crackers, candy, milk
ice cream, frozen vegetables, and other fresh and prepared foods.
Paperboard packaging not only helps customers identify products and brands
but also may provide nutritional information, instructions for preparation, use or
assembly. Further, it often functions as a protective container guarding the contents
against breakage, pilferage, spoilage, contamination, deterioration and other
marketplace or distribution hazards.
Members of the Paperboard Packaging Council recognize that the nation
faces significant solid waste management problems and the Council is committed
to active participation in the development of fair, equitable and meaningful
solutions to the problems of post-consumer solid waste.
PPC Supports Resource Conservation and Resource Recovery
PPC members support the solid waste management concepts of resource
conservation and resource recovery. A combination of the two concepts, which
encompass a wide range cf alternatives, will be required to reach a necessary
and desirable solution to the solid waste management problems.
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Resource conservation efforts can minimize the amount of solid waste
generated while resource recovery efforts can help make the most efficient use of
the nation's natural resources and energy.
Basically, the proposed solid waste disposal tax of $30 per ton on
paperboard, flexible packaging and most other paper products would be discriminatory,
regressive, inflationary, create market dislocations, and create a strong disincen-
tive for resource recovery.
Therefore, the members of PPC urge the Resource Conservation Committee
to reject the concept of such a tax and to attack the problems of solid waste
management through the development of resource recovery centers and through
increased recycling of materials from sources such as newsprint, corrugated
containers, paperboard and other paper where economically and functionally
feasible.
There is little to be gained from discriminatory taxes on certain
packaging products that will not solve the solid waste management problem, but
which will instead merely transfer the composition of waste from packaging waste
to food waste (garbage). In its second report to Congress on Resource Recovery
and Source Reduction, the Environmental Protection Agency noted that food wastes
(garbage) have declined (on a per capita basis) with increased use of industrially
prepared food,-while packaging wastes per capita have increased.
The transfer from garbage to paperboard trash, however, is not merely
an exchange of one type of waste for another type. Modern packaging results in a
significant decrease in post-consumer municipal waste.
It is easy to forget that the benefits of packaging are real and not
simply the symbol of luxury in a wasteful society. By reducing the amount of
packaging used, the solid waste problem can be drastically reduced. However, modern
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packaging of food keeps the bones, peels, pits, innards, shells and other waste out
of the garbage pail. Because of modern packaging methods, the garbage wastes are
kept where they are most productive -- near their sources where they can be and
are processed into a variety of usable products and by-products. If modern
packaging is eliminated, or priced out of the marketplace with a burdensome tax,
there would be an enormous increase in the waste disposal problem.
Take just a single example. In a fresh orange, only 48% is edible, and
52% is rind, membrane and seeds. If the residents of New York City used fresh
oranges for juice instead of that packaged in quart size "milk" cartons (not
concentrated), they would create 106,703 tons of wet garbage instead of 3,000
tons of paperboard trash. Eliminating paperboard waste may reduce one waste manage-
ment problem, but it creates an even bigger garbage disposal problem. It is for
reasons such as this that the members of PPC oppose the proposed $30 per ton tax
on paperboard and other paper products which may enter the municipal solid waste
stroam.
Instead of taxing packaging systems that have been tested and proven
for their efficiency in the marketplace, the Resource Conservation Committee
should concentrate on the development of resource recovery systems to recover
valuable materials and energy from the solid waste stream in areas and regions
where recovery centers are economically and technically feasible.
The National Center for Resource Recovery projects that millions of tons
of news print, corrugated and office waste could be collected for recycling and
that the energy values in solid waste that might be captured are the equivalent
of 220-280 million barrels of oil per year. Efforts to solve the solid waste
management problem should concentrate on methods for stimulating development of
resource recovery centers, rather than on eliminating packaging.
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The Federal Interagency Resource Conservation Committee (RCC) has published
for public comment a staff background paper (No. 9). The background paper
identifies the eleven principal questions (called design issues) on which the
RCC seeks the written comments and suggestions of interested parties. The
observations of the PPC follow each of the eleven design issue questions.
1. What Products Should be Subject to the (S30 per ton Solid Waste
Disposal Tax) Charge?
If the tax is to treat all products equitably, the tax should apply not
just to paper, paperboard, flexible packaging, cans and bottles, but it should be
extended to all products which eventually will enter into the solid waste stream,
including newspapers. Allowing special exemptions for certain products such as
books, jig saw puzzles and similar products would not be appropriate, since these
products eventually end up in the solid waste stream even though they are not
packaging materials.
2. What Types of Social Costs of Municipal Services Should Form the Basis
For the (Tax) Charge?
It would be more logical to reverse the question to inquire what additional
costs would be incurred if the tax is imposed. The stated purpose of the tax is to
internalize the cost of solid waste disposal so that the cost is paid by the
producer of packaging material rather than by the ultimate consumer. However, the
imposition of a solid waste tax would not reduce the cost to the consumer, but would
transfer the waste problem from a small amount of packaging waste to a large amount
of garbage waste in the form of pits, peels, bones, shells and husks.
3. What Pricing Concept Should be Used to Set the Charge (Tax) Level?
Although the RCC staff background paper offers only three options, average
cost pricing, and short-run and long-run marginal cost pricing as the basis for the
charge, an entirely different concept should be considered. The cost of solid
waste management should continue to be paid by the user of the disposal service
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either through user charges or general taxes. This pricing concept automatically
takes into consideration the variations of cost of disposal in different areas or
regions and spreads the cost throughout the entire community which benefits from
the disposal of these municipal wastes.
4. How Should the Charge (Tax) Level be Determined for Specific Product
(or Material) Categories?
In keeping with the answer to design issue question #3 above, it would
be appropriate to impose the tax on-each user of the disposal service — those
who contribute to the municipal solid waste stream. Although the amount any
particular user contributes to the solid waste stream may be difficult to measure,
the charges should be applied on the same basis as other municipal waste disposal
charges -- general taxes or user charges.
5. Should the Charge be Adjusted to Account for Geographical Cost
Variations!
The general tax method described above self-adjusts to account for
geographical cost variations.
6. Where Should ths Charge (Tax) be Collected?
As explained in items three, four and five above, the tax should be
collected from the general taxpayer in each community.
7. How Should Imports and Exports be Treated?
The tax should be imposed on all products, whether domestically manufactured
and packaged, or whether imported. The tax method suggested above automatically
adjusts for imports and exempts exports which do not enter the nation's solid
waste stream.
8. Should There be Adjustments for the Charge (Tax) and/or Credits for
Resource Recovery and Recycling?
8a. How Large Should any Recycling Adjustments or Credits Be?
Ill
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No adjustments would be needed if the tax method suggested in design issue
question four above is used. However, if the $30 per ton approach is used considera-
tion should be given to a credit for the use of recycled materials. The credit
should be equal to the initial $30 per ton charge (tax). The fact that one
packaging firm uses recycled products that did not ever enter the municipal
waste stream while another firm uses recycled materials that are recovered from
the municipal waste stream should be immaterial, since the purpose of the adjust-
ment is to stimulate the use of non-virgin materials. Actually, for the
paper carton industry, the amount of the adjustment will be an insignificant
factor in deciding whether to use virgin or recycled material. The end use
value of paperboard packaging typically amounts to about $800 per ton and the
imposition of a $30 per ton tax amounts to less than 4% of the cost of this packaging
This added cost will be more than off set by other factors, such as the capability
of the paperboard to withstand the stresses of high speed filling machinery, the
printing characteristics of the paperboard and the strength needed to protect
the product during transporation to the retail store and on to the customer's
home.
Although the tax would have virtually no effect on the selection of virgin
or recycled paperboard, the tax would result in a general increase in the cost of
paperboard packaging fr/hich is of course passed on to the consumer in the form of
higher prices for the product). Even recycled paperboard would not escape the
tax on virgin paperboard, since recycled paperboard typically is made from the
recycling of virgin paperboard and other virgin paper products which would be
taxed. Thus the cost of the $30 per ton tax is passed along to the consumer
whether virgin or recycled fibers are used in the paperboard packaging.
Consideration also must be given to the fact that if a credit is given for
the use of recycled materials, the demand for recycled fibers will increase and
as a result the cost of recycled fibers will go up. These increased costs for
packaging materials will in the long-run be passed on to the product purchaser.
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9. What Use Should be Made of Revenues Collected from the Solid Waste
Disposal Charge (Tax)?
If the $30 per ton tax is applied, the revenues collected should be used
to develop and build resource recovery facilities in areas and regions where they
are economically and technically feasible. The real solution to the problem of
solid waste management is not the elimination of packaging wastes, but the recovery
of valuable materials for recycling and for the creation of energy that have
been demonstrated in recovery facilities, such as those in Milwaukee, Wisconsin,
which have produced income for the City to offset the costs of collecting municipal
solid wastes.
10. Should the Introduction of the Charge be Phased-in Over Time?
It will make little difference whether the tax is phased-in over five years
or over ten years. The tax will have only a small impact in increasing recycling,
it will have little impact on reducing the use of packaging, and it will have
little impact on reducing amounts of solid waste. However, huge amounts of
tax income would be generated, and the cost of the tax would be passed on in the
form of higher prices to the consumer.
11. How Should The Charge (Tax) be Adjusted Over Time?
The tax should be decreased over a phase-out period of five to ten years.
Because of the huge amounts of tax income that the tax would generate, funds to
construct resource recovery facilities in major urban areas would be provided in
a short time and once the construction costs are funded, the tax should be eliminated
PPC Members Oppose Solid Waste Disposal Tax Concept
Members of the Paperboard Packaging Council are committed to active
participation in the development of meaningful solutions to the problems of post-
consumer solid waste, and support the solid waste management concepts of resource
conservation and resource recovery. However, members of the PPC oppose the concept
of a solid waste disposal tax that:
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— creates a strong disincentive for resource recovery since a municipality
could merely choose to have its present system of waste disposal --
primarily landfill — underwritten by the Federal government through
a tax on packaging materials, rather than get into the business of
resource recovery.
~ is inflationary and would probably cost the paper industry $1 billion
a year which would be passed on to the consumer,
— is discriminatory because it would tax paper in all forms while other
materials would be taxed only when used as packaging,
— is regressive, since its heaviest impact would be on low income
families.
— creates market dislocations and favors lighter materials, and
— creates a shift to products utilizing depletable resources and/or
imported petrochemicals.
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American Can Company
Judd H Alexander American Lane, Greenwich, Conn 06830
Senior Vice President 203-552-3233
May 25, 1978
Ms. Susan Mann
Public Participation Liaison
Resource Conservation Committee
401 M Street, S. W.
Washington, D.C. 20460
Dear Ms. Mann:
Thank you for the opportunity to submit comments on the two background
papers prepared by staff on the subject of the solid waste disposal charge.
At the hearings in November, I testified on behalf of my company and sub-
mitted a substantial collection of data covering some of the inequities
developed by the proposed disposal charge. Naturally, I was disappointed
to see so little of this laboriously collected data utilized by the Resource
Conservation Committee staff in developing their position papers. However,
I have been encouraged by the public remarks of Mr. Stephen Plehn, Deputy
Assistant Administrator for Solid Waste, who has stated EPA's belief that
no resource conservation policy should be implemented until a specific
proposal has been developed, analyzed and shown to be practical, fair and
cost effective.
The attachments to this letter will present detailed comments on the draft
papers as an assistance to the staff in assessing the options on this complex
issue.
Please note that my company is a major manufacturer of metal cans, paper,
paper cartons, flexible packaging, plastics and plastic packaging. Further,
we are a major recycler of aluminum, tinplate, forest waste, lignin and
paper. Finally, we are the operators of the Milwaukee Municipal Solid
Waste Resource Recovery System. We do have considerable expertise on the
subject under consideration. We hope our comments will be helpful.
Yours very truly,
11
JUDD H. ALEXANDER
zx
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May 25, 1978
American Can Company Comments
on Resource Conservation Committee Staff Background Paper No. 9
A twelfth major design issue should be added to the 11 identified
by the staff. The 12th issue is: Should adjustments be made for products
disposed at no public cost? The disposal charge as it is presently con-
stituted would apply to many products that never reach the municipal
waste stream. For example, much paper and plastic is used as industrial
packaging and its disposal is the responsibility of the industrial sector.
To my knowledge, this is all accomplished at private cost. Should not
this portion of paper and plastic production be exempt? Further, at
least 90% of commercial solid waste is carried by private cartage and
50% is disposed at private cost (source: Franklin Associates). Surely
you are not suggesting that municipal services for commercial waste be
supplied free? Should not, then, the substantial quantity of paper,
plastic and containers used by stores, restaurants and offices, disposed
of at private expense, also be exempted from the disposal charge? Tn
fact, substantially more than half the paper is disposed at private
expense. If the disposal charge is placed on all paper prodcuts, the
redundancy exposes the charge as a simple excise tax. How about
exemptions for the 25% of the aluminum beverage containers that are
recycled outside of the municipal waste system? It is not sufficient
to give them a recycling credit because the recovered metals are often
used for other aluminum products which are not taxed.
Issue 1 - Products to be Charged
It is obvious that the stated objectives of the charge can be
achieved only if the tax is applied to everything in the municipal waste
stream. As soon as you use administrative expediency as an excuse for
selectivity, you destroy the cost internalizet
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Once you take out this water the remaining products in the waste come
closer to 110 million tons annually than your figure of over 140 mil-
lion tons. Your Table 1 shows that the tax would fall on less than
49% of the products in the waste. The inequities inherent in Issue
No. 13 prevents the objective of internalizing the cost of waste.
Now what do you do? Have two systems?
The concept of minimizing the number of establishments serving
as charge collection points is administratively logical, but it suggests
an anti-bigness bias. Could the can industry, for example, avoid the
tax if it broke itself down into many small plants? I assume this is
why fragmented industries such as textiles were exempted. In our
recycling operation in Milwaukee it is far easier to recover packaging
materials and to process them effectively than it is such non-taxed
items as bedsprings, appliances, cable and pantyhose.
Under your options on Issue 1, should you not exempt toilet tis-
sue, building paper, books, etc.? Certainly, they are not part of
the municipal waste stream. And how about the many other products
that are used and disposed industrially?
You do not propose to tax food even though it is an important
component of both the solid and liquid waste streams. Why not apply
"let the polluter pay" principles here? Obviously, this too would be
impractical and regressive.
Issue 2 - Social Costs
When you detail the other social costs should not you also
detail the social credits? For example, food packaging has helped
reduce the time required for food preparation by two-thirds in just
one generation. It has preserved food, cut waste, reduced pilferage
and lowered costs. Before you develop programs that try to dis-
courage the use of food packaging, don't you have to measure the
social advantages it has brought? Does it not offer pluses for society
as well as minuses? Do you measure only the minuses?
Are you confusing the issue when you get into such things as
the desire to neutralize the tax advantage of virgin materials?
Surely you recognize that the capital gains treatment for timber was
extended by Congress for the particular purpose of increasing timber
growth. It has been very successful. If you are going to try to
neutralize that as part of the solid waste program, what will you
substitute as the timber growing stimuli? Or, perhaps, this is another
complication beyond the scope of this limited purpose charge.
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If you try to charge the products based on the disposal cost,
would you not need to standardize both the collection and disposal
systems? The cost of pickup varies by curbside, Scottsdale bins,
plastic bags, street congestion and local labor rates. Some products
that represent an advantage in resource recovery systems may be a
disadvantage in landfills, and vice-versa. Don't you have to project
the collection and disposal profiles of the future to arrive at these
costs?
I was pleased to note that you recognize the competitive nature
of the liquid container industry and used the same tax for aluminum,
plastic, steel, and glass. However, you did not apply that same wis-
dom to other competitive products like shrink wrap and corrugated.
There, you will give a substantial advantage with your tax program to
the light weight materials with no consideration for the other social
values.
I also note the proposals consider taxing all beverage cans at
half a cent each even though six states have deposits which, theoret-
ically, remove all of their cans from the solid waste stream. Surely,
you will want to make an exemption for a percent of the container
company's production going to those states. I'm not quite sure how
you should apply this exemption or credit because we don't know what
states our cans will be sold in at the time of manufacture. However,
some of the deposit states require special markings on the container
and with some extra bookkeeping and an audit procedure this could be
accomplished. I hope you will not again choose the administrative
expediency of taxing these products unfairly just to make the job
easier for the collectors.
On Page 7, the $1 billion litter figure is highly questionable,
particularly ?".n view of the fact that the 50 states spend only $47 mil-
lion directly on litter. We know there is substantial extra cost by
local government and by private citxzens and private employees (janitors,
supermarket clerks, etc.), but Mr. Samtur's figure sounds like a guess.
If you are going to try to cover the litter costs, does this mean you
will be giving money back to those businesses and citizens who police
their own properties and neighboring streets?
I was concerned by your comment on the imposition of a tax to
reduce the cost of excessive import dependence. In the case of boCh
aluminum and steel, local supplies are plentiful but foreign supplies
are cheaper. Is it your intention to force local sources even if it
drives up the price of these metals to the American consumer? Have
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you considered the impact on the economy of Jamaica if you tax away
their bauxite, or on Canada if you block out their newsprint? This
problem is particularly touchy on metals because you are using solid
waste arguments to disrupt international business even though only about
6% of the national production of these two metals becomes part of the
municipal waste stream. How do you structure impacts on ore prices
so that it falls only on the portion which makes the products with
which you are dealing?
Issue 3 - Pricing Concept
On Page 9, you are involved in a long discussion about how to
value the savings that you get in waste reduction from the tax. There
has been no agreement in RCC studies or other respected reports that
any significant reduction will be achieved. For example, with the
professionally developed estimate that the tax would bring about a
reduction in paper in the waste is the equivalent of less than 1% of
total waste, no discernible cost saving would be achieved.
Issue 4 - Charge Level for Products
You have analyzed effectively the dramatic discrimination that
occurs with each of the options available to you. The one missing
ingredient is the failure to consider compactibility. For example,
products like cans when flattened would have a cost dramatically dif-
ferent than those presented in your Table 2. A waste disposal charge
based on value does eliminate the dislocations to in-place jobs and in-
place investment caused by either a weight or volume tax. However,
the inflationary and redundancy effects discussed earlier will remain.
In your discussions of options you have done an excellent job
of pointing out the deficiencies of each. In No. 4 you have the
potential to broaden it to all products in the waste but you wind up
with a sort of national sales tax in the process. You show a concern
that this method would not improve resource utilization efficiency
even though you have given no indication that any of the others would
either.
Issue 5 - Geographical Cost Variation
I was pleased to see your recognition that taxes of this type
may cause some income redistribution. Since this point is of such
interest to the Administration, it would be well to point out the
nature of the income redistribution. The tax falls disproportionately
on small towns and rural citizens because the average tax will exceed
their current cost. Conversely, city dwellers will have a higher per-
cent of the products in their waste taxed because their waste is more
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package oriented, and their newspapers are generally larger. You
should also point out that lower middle income citizens are the
heaviest consumers of many heavily packaged food products such as
soup, stew, canned vegetables, pot pies, TV dinners, beer, and soft
drinks. And, since half of packaging is food packaging, low income
people spend a much higher percent of their income for food than do
the well-to-do. Your proposed tax discriminates ?gainst these low
income groups.
s
I was amused by your comment that "the associated loss of
economic efficiency must be accepted as an inherent drawback of the
disposal charge scheme." Actually, it doesn't have to be accepted
as a drawback. The whole scheme can be rejected on that solid basis.
Issue 6 - Location of the Charge
Once again you make the statement that to place the charge at
the wholesale distribution stage would be highly undesirable from an
administrative standpoint. Must administrative convenience always take
precedent over the consumer's interests? The fourth option is to place
the charge at the last level, retail, rather than the first. That is
the X7ay most sales taxes are handled and it is the least inflationary
approach. It does have the disadvantage, however, of exposing to the
public that they are being double charged for services for which many
of them already pay. You would also have difficulty with small town
voters who may recognize the unfairness of the average charge basis.
On option 4, are you really saying you don't have a good
solution now but if given enough time you may be able to come up with
one? This is a key part of the tax proposal, it should not be left
hanging until after the tax is passed.
A fifth option on placing the charge would be to place ic on
the disposer for all commercial waste. Franklin Associates have
identified this portion as 39% of municipal waste and that approxi-
mately 77% of the collection and disposal cost is already internalized.
It would be a simple matter to raise this to 100% by administrative
fiat. Immediately, this would internalize 39% of the waste accurately
and fairly without the disruptive by-products and inequities of the
other options.
Issue 7 - Rebates for Exports
I don't know how you would handle rebates for export products
if the tax were placed at the base material or fabricator level. We
sell cans for seasonally packed products. These may be harvested in
June and all are canned at that time. It may be 8 to 10 months later
when the canner gets an overseas order for part of his production.
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AC Chat point who do you rebate the tax to? Does it go to the canner
or does it come back to the can supplier? Presumably, the can sup-
plier has already passed or attempted to pass through the higher cost
of the tax, but competitive pressures may make this impractical with
certain accounts. You may find yourself rebating money to people who
never paid it in the first place. The alternative is for you to keep
the money even though the cans will never become part of the domestic
solid waste stream. Both solutions appear to be unsatisfactory.
Issue 8 - Credits for Recycling
In Issue No. 8 you face again the question of "rebate to whom?"
I like your concept that the tax on products which do not enter the
stream should be rebated, but I caution that the quantity will be sub-
stantial and the administration chaotic. Rebates should apply to export
products, recycled products, industrial products, deposit products and
it should really include most commercial products as well. Then there
are such things as toilet paper and cigarette paper and paper that is
used to start the fireplace or insulate Che attic or that is disposed
on the farm. We estimate that more than half of the paper produced
does not become part of the residential waste stream. Should not that
portion earn rebates? If the rebates are due on over half of the paper
taxed, you will have two administrative expediency choices. You can
either forget the rebates, or you can forget the tax. And since you
have such a high interest in administrative expediency it seems that
the latter choice may be the least bureaucratic.
Page 24-1 was disappointed that your discussion of recycling
credits did not reflect the testimony from major recyclers in the paper
industry which indicated that competition for recoverable fiber would
tend to drive the price of recycled up to the level of the credit,
adding to the inflationary impact of the whole program. Once again,
you have available to you a study done by a well known contractor for
the paper industry to determine the impact on recycling of a $30 charge.
The effect is negligible. The problem is that the tax increases demand
without increasing supply. I am concerned that this whole-paragraph
or section is based on a simplistic view of the cost and motivations
for recycling.
You went over a possible credit for recycling into energy
rather quickly. Actually, in most resource recovery operation, the
energy value for both paper and plastic exceeds the tipping fee of
the waste so that a $10 to $15 a ton rebate would be intellectually
appropriate.
For metal and glass recycling, you have failed to cover either
a method or value system for rebating for recycling. Since the charge
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is to be applied at the fabricating level, is the recycling credit
given there or at the mill? The tax rate proposed is about $250 a
ton for aluminum cans, $95 a ton for steel and $19 a ton for glass
containers. I assume you mean for the credit to reflect this differ-
ence. If the credit is given to the mill, they can recycle the
recovered material into the most economic use (the tax falls on only
5% of steel production, but non-taxed products may be more efficient
users of recovered metal). But then, how does the fabricator who paid
the tax on a product that did not reach the waste stream receive his
rebate?
How do you handle rebates for 12 tablet aspirin tins and 5 gal-
lon cans recycled into steel? The half cent tax on the aspirin tin
is $500 a ton and the tax on the large can is $20 a ton, but the value
of the steel made from either container is the same.
Issue 9 - Use of Revenue
You make the statement that the product prices which affect
consumer and producer decisions on material use would be based solely
on the charge rate. This is a gross simplification. It ignores com-
petition, multipliers, and penny rounding. It also ignores the dis-
crimination that most of these proposals cause between materials of
different weights. I wonder if anyone can predict accurately what will
be the impact of the decision of several million market makers and the
consumer1 s response. We can all agree that there ij! an inflationary
impact. Perhaps Mr. Straus and Mr. Bosworth would be best qualified
to determine its effect on the American people. Have they been con-
sulted on this proposal?
I am moderately disturbed by the suggestion that the simplest
mechanism for dispersing the funds is to channel them into the U. S.
Treasury's general fund. You suggest that waste management would still
be financed at the local level but individuals would benefit in the
aggregate from disposal revenues because the revenues would allow an
extension of federal programs or reduction of other federal taxes.
Aren't you missing one point here? Where are these taxes coming from?
Aren't they coming from the same people to whom you plan to give the
money back? It seems to be that Uncle Sam will be reaching into the
left-hand pocket to take money which he will then put back in the right-
hand pocket after skimming off some on the way to cover administrative
overhead. How can you possibly suggest that the consumer would benefit
from such a program? You are right. It is regressive. It is also in-
efficient.
The options available in this section are intriguing. You have
gone to all the trouble of raising this money and you really don11 have
any practical way to use it except to give it back to the people from
\7hom you raised it in the first place. Can you really sit there in
Washington and decide for the minicipality how they may best fund their
waste collection and disposal processes? Do you not need studies which
identify the disposers of taxed products by economic level? Without
this data, you do not know what redistribution you are accomplishing.
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Issue 10 - Phase in Time
This issue, too, is complicated. A two-year phase-in serves
the regulators but not the producers of taxed products. In fact, of
the options, No. 3 is the most disruptive to in-place jobs and in-place
investment. Surely, this concern deserves consideration.
Issue 11 - Adjustments Over Time
Page 29 - In the two options offered here on adjusting the
charge, are you not designing a self-fulfilling prophecy? Can you
imagine the difficulty municipal governments will have in negotiating
with their sanitation unions when the union people know that higher
costs will bring higher revenue-sharing? How can the municipal
negotiator resist? Does not this whole program take away the incentive
from municipalities to manage their costs most effectively?
Conclusion
I apologize for offering so many criticisms. Actually, I
think this is an excellent report. It begins to reveal many of the
complexities and the weaknesses of the disposal charge concept. Let
the polluter pay may be a valid concept for industrial users of air
and water resources; but in cases like sewage and solid waste, the
polluter is all of us. Disposal charges may be an enticing theoretical
dream, but a careful examination exposes the flaws. Taking the least
faulty of each design option, it is still impossible to develop a
disposal charge that is not inflationary, regressive, discriminatory,
disruptive and ineffective.
The concept should be abandoned because it is unfair and
impractical.
# # * # # #
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May 25, 1978
American Can Company Comments
on Resource Conservation Committee Staff Background Paper No. 8
Introduction
My concern with the Introduction is the assumption that the
proposed disposal charge will save "scarce and valuable resources".
Actually, the proposed tax falls primarily on one fiber (wood) and
three minerals (iron, aluminum and silicia). The fiber, obviously,
is both renewable and plentiful. The nation continues to grow more
wood than it consumes and the potential for increasing this growth
rate within the confines of the United States is substantial.
As for the minerals, all three are present in the world and
in the United States in vast quantities. The three comprise 19% of
the earth's crust. Almost one-third of Minnesota's vast area consists
of 25% iron, whereas the average waste disposal site has an iron con-
centration of only 7%. In fact, all four resources are so plentiful
that the value of the raw material is extremely low. I am afraid the
public and your researchers have been confused by the cost of products
made from these materials as opposed to the cost of the raw materials.
A carton for ice cream or a can for peas may sell for$1,000 a ton or
more, but the cost of the fiber and the iron from which they are made
is less than $20 per ton, less than the proposed tax. The difference
between the $20 and the$1,000 is made up by capital, labor, energy,
and transportation. It is misleading to assert that this proposal
deals with "scarce resources". There may be scarce resources in the
waste stream (eg. copper, chromium, zinc) but none of them are covered
by this proposed- charge.
It is true that energy is a component of all extracted and
manufactured products. However, simplifications can be misleading hero,
too. EPA's study by Research Triangle Institute en the relative cnci^y
cost of beverage containers shows that refillable bottles use less total
system energy than do steel cans. But, the same report also shc-./s that
refillable bottles on a 10-trip basis use nearly double the petroleum
required to manufacture, fill and distribute canned beverages. A
Resource Conservation Bill designed to reduce total energy could save
plentiful energy sources at the expense of scarce and expensive supplies.
This appears to be inconsistent with the Administration's goal of reducing
oil imports. At the least, it deserves further study.
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In addition Co wood, minerals and energy, there are other
resources impacted by the charge under consideration. For example,
packaging is to be taxed; yet packaging plays a recognized role in the
conservation of food. If the Bill were to be successful in reducing
the amount of packaging and an increase in food waste resulted, the
impact on our resources (including food) would be negative and the
impact on solid waste could also be negative. The research of
Professor Rathje at the University of Arizona shows that about 15%
of unpackaged fresh food is discarded in residential garbage, whereas
only 3% of packaged processed food is lost in the waste stream. In
addition, there is substantial spoilage of fresh, unpackaged food in
distribution with an impact on industrial and commercial waste.
Statement of the Problem
I disagree with the contention that this proposal differs from
a revenue raising excise tax because it is based on the cost of managing
a public service. This point is invalidated because the proposed tax
is selective and discriminatory. And, of course, you are applying
national averaging to a local cost. Since more than half of all
packaging is devoted to food and beverages, it may be well to include
a reference to a recent study conducted for the National Science
Foundation on packaging for non-liquid foods. This valuable work shows
that food packaging has increased at a rate below population growth
for the last 15 years. Since food packaging is one of the principal
products to be taxed, the per capital decline in food packaging is
significant information which the RCC staff should consider in its
assessment of options.
I question the statement that the national trend is toward
"substantial future increase in solid waste generation". Actually,
waste generation declined in both 1974 and 1975 and barely returned
to the '73 levels in 1976. This four year period does include an
economic downturn, but I suspect we will have economic downturns in
the future as well. Certainly, it would be more accurate to say the
national trend shows a slowing of the rate of increase in solid waste
generation.
When your staff drew this comparison I believe they failed to
include the impact of the sharply higher energy costs in recent years.
If the premise of the disposal charge is valid, that a $30 a ton penalty
will discourage product use, the charge is unneeded because higher energy
costs have already supplied that impetus.
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Page 4 deals with the current charge methods for solid waste
collection and disposal. The Hissing ingredient here is perspective
and scale. Would it not be well to point out that the national cost
to collect and dispose of residential vraste is only $11 per capita and
that the necessary upgrading recommended by EPA will add but 60$ per
year to this figure? The relatively low cost of waste collection and
disposal argues against the imposition of a complex and bureaucratic
tax system designed to recover such small amounts of money, particularly
since so many smaller communities have already internalized the cost
of waste pickup through their direct charge procedures.
Your paper makes much of the fact that a consumer product's
disposal is often not considered at any decision point in the product's
production and consumption life cycle. Your assumption is that the
addition of this charge will have a significant effect on the choice.
Once again, you offer no perspective on the disposal cost compared to
the selling price of the product or the service value it performs. We
submitted data to show that the through system value of most packaging
products for consumer goods ranged between $1,000 and $5,000 per ton.
Disposal charges would have minimal effect on product use decisions.
For example, a study made for the paper industry shows that this $30
a ton tax would impose a burden of nearly $2 billion annually on the
paper industry and would result in a reduction in solid waste of less
than 1%. Does the result justify the cost?
Your paper claims an advantage for having the solid waste cost
of products included in the sales price of each product. That is a
fine theory, but, of course, it is illusory. The solid waste cost of
individual paper and packaging products is almost always a fraction of
a cent. There is no way a fraction of a cent can be accurately reflected
in the price of consumer products. Unfortunately, due to the profit
multiplier effect and penny rounding, the consumer is apt to pay more
as a result of the tax than the government collects fron it. This
inflationary impact deserves further study.
You suggest that under fall cost pricing consumers may shift
their purchasing more towards low waste items such as returnable con-
tainers. Surely, you recognize that they don't pay full cost either.
Currently, in non-deposit states retailers sell beverages in returnable
containers and in one-way containers at the same gross margin in spite
of the substantially higher costs in space, labor, and time entailed in
the double handling. Perhaps if this cost were fairly charged, users
of refillable bottles would be induced to switch to single service con-
tainers. After all, retailers under deposits must handle the containers
126
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one at a time, whereas a sanitation worker deals with the containers
in 40 pound lots. The retail collection system for used containers
may be 30 times more expensive than the solid waste system.
I question your statement on Page 7 that full cost pricing is
consistent with at least four of the five policy design criteria.
The fact that the disposal charge is applied selectively and cost
averaged makes it inconsistent with Nos. 2, 3 and 4.
s
On Page 9, your chart is misleading because it fails to
indicate the selectivity of the chart. For example, the national
disposal charge does not base the price on the quantity of material
discarded. This would be true if garbage consisted only of the taxed
items or if the tax was universally applied. As a package maker, I
should be pleased to see that you felt the only way to meter garbage
was with plastic bags, but I suggest that reusable containers can also
be used successfully as a metering device avoiding the 7c charge. This
is done in a number of communities. Specifically, check Tacoma's
successful program. A direct charge for solid waste service is the
most efficient system and it is workable in most small communities.
On Page 10, the last sentence states the advantage of the tax
is that it brings about the national goal of improving natural resource
utilization efficiency. At the very least, this is highly questionable,
and at best the result is minimal. What we are dealing with here is
the imposition of a bureaucratic and administratively expedient dis-
ruption of the market place with minimal results. How can this study
make such a positive statement? Surely, it is open to grave quescion
as to its factual foundation.
At the bottom of Page 11, you pose a most interesting question.
"How high must you raise the prices for consumers today to conserve
material resources for future use?" This question is particularly
difficult when you are dealing with such plentiful resources. Perhaps
you should show when the U. S. will run out of iron or aluminum or
fiber with the tax and without it. I think you would find that the
difference between the taxed system and the natural market force system
is infinitesimal when.measured against the many centuries of supply
available.
On Page 13 I was pleased to see the recognition that deposit
or bounty systems may be a more expensive way to manage waste than
existing municipal systems. You also note that deposits are not
appropriate for products that are seldom littered. I will also add
that it is not the quantity of litter that is important; it is the
percent of the product that is littered. For example, if the cost of
running the deposit system is 3c a container and only 3% of the containers
are littered, then the cost of removing each container from litter is
$1.00. Once again, this is a terribly more expensive way to manage
waste when other alternatives are available to the municipalities.
******
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/\. • k rican Paper Institute, inc.
ibig Massachusetts Avenue N \\ Wnshmmon DC zuiim
I2O2) 067 8«7B
May 31, 1978
Ms. Susan B. Mann
Public Participation Liaison
Resource Conservation Committee (WH-563)
401 M Street, SW
Washington, D. C. 20460
Dear Susan:
The American Paper Institute appreciates the opportunity
to present comments on the two background papers (#8 and #9)
which were sent out by Ms. Barbara Blum on April 18. We,
moreover, truly appreciate your granting us an extension of
time to prepare our response to these documents inasmuch as
they were considerably delayed in reaching us.
First, let me state that the API sincerely hopes that
these comments will receive the RCC's careful consideration.
We testified in Washington, Cincinnati and Portland last
November, pointing out in specific detail, the inequities and
infeasibilities of the solid waste excise tax proposal. Our
comments that follow, will be concise, depending on our previous
testimony for detail.
Review of Background Paper #8
The conceptual problem with the solid waste disposal tax
begins with the "Statement of the Problem" in Background Paper
#8. The problems identified here either do not exist, or to
the extent they do, the solid waste disposal tax would in no
significant way provide a solution.
The first paragraph of the "Statement of the Problem"
implies that there has been a dramatic increase in packaging
materials in municipal solid waste in the last 20 years and
that this has exacerbated the municipal solid waste problem.
This is not the case. The report entitled "The Application
of Technical-Directed Methods to Reduce Solid Waste and Con-
serve Resources in the Packaging of Non-Fluid Foods", prepared
by Franklin Associates, Ltd., for the National Science Founda-
tion, documents that packaging, far from contributing to the
solid waste disposal problem, helps to ease it. When foods are
processed and packaged, the rinds, husks, bones, fish heads
and other putrescribles do not impact the municipal solid waste
system but are left in rural areas as fertilizers or feed for
cattle. The NSF report shows that packaging considerably reduces
the impact on the municipal solid waste stream. Its judgment
is that packaging is efficient and useful to society.
128
SrnuiM; i/ic pnl|» (/•'(« ' iintl /«i;« ihminl nufcsm/
-------
Ms. Susan Mann
May 31, 1978
Throughout Background Paper #8 are statements that the
disposal tax will "reduce total natural resource consumption"
or "improve natural resources utilization." There is also the
implication that a national solid waste disposal tax would
significantly alleviate the solid waste stream by encouragement
of source reduction and recycling.
The solid waste disposal tax will not reduce total'natural
resource consumption or improve resource utilization by any
meaningful amount, nor will it, to any significant extent,
ease the impact on landfills or reduce the number of trees cut.
The problem which brought about the Resource Conservation
and Recovery Act of 1976 was the lack of available land for
disposal of solid waste in many urban and suburban areas. A
solid waste tax on the paper industry will not create any
significant decrease in the local volume of products reaching
the solid waste stream nor will it result in a major improve-
ment in natural resource utilization.
A study presently underway for the Paper Industry by
Franklin Associates, Ltd. and International Research and
Technology indicates that, with a ten year phase-in, in the
first full year of implementation, paper industry recycling
would increase by only about 1.5 million tons over the base line
projection. Since by that time the solid waste stream is
projected to be about 176 million tons, this would represent a
decrease in solid waste of only 8/10ths of 1% as a result of
paper recycling stimulation due to the disposal tax. Franklin
Associates and IR&T also estimate that the diminishment of
demand below the base line projection due to a solid waste tax
would be about 700,000 tons in the tenth year of the tax. This
would represent a decrease of about 4/10ths of 1% in municipal
solid waste. The total reduction is 1.2% of the solid waste
stream. When such miniscule "benefits" are weighed against the
social and economic disruption the tax will cause, there is
little justification for implementing the tax.
We consider it unlikely that plastic usage will be seriously
affected; in fact, much of the paper diminution of demand will
actually be a shift from paper and paperboard to plastics
(principally substitution of plastic shrink wraps for corrugated
boxes) and plastic for paper in flexible packaging. Plastic,
of course, is energy intensive while paper comes from a renew-
able resource. Paper is biodegradable while plastic is not.
The "Rationale for a National Solid Waste Disposal Charge"
states that consumers would "shift their purchasing toward
low waste items". The solid waste tax would not, in the great
majority of cases, provide any opportunity for the consumer
to make "a decision to consume". The solid waste tax in a
typical package containing frozen peas or potato chips or a
pound of butter would be only a fraction of a cent. By the
129
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Ms. Susan Mann
May 21, 1978
time this is passed through and reaches the super market shelf,
this may result in increasing the cost of the product less
than a penny. With the many other factors which create signi-
ficant increases in the price of packaged food, the consumer
would never be able to identify this "penny increase" as result-
ing from the solid waste tax and therefore make a buy or not
buy decision; and, of course, the more valuable the product,
the less the relative effect. The tax will merely be another
increment in the general inflationary impact which daily is
hammering the consumer.
Nor would it have a major effect on timber resources.
In the West, trees are cut primarily for lumber and plywood.
Chips, from which paper is made, are a residual output. Lesser
demand only increases residues left in the forest. In all
likelihood in a decade or two little timber will be cut just
for paper production in any part of the country, except as
thinnings or by marginal, small land owners.
Background Paper 18 states that a solid waste disposal tax
would be consistent with the "polluter pays" principle. This
would not be the case. This solid waste tax as proposed would
not really internalize the cost of solid waste collection and
disposal. To accomplish that, costs should be borne directly
by the waste discarder through local charges or local taxes.
As Dr. Richard Posner, economist from the University of Chicago,
commented in his testimony to the RCC on November 17, 1977
concerning solid waste product charge legislation, "There is
no reason in principle why garbage collection cannot be priced
efficiently, thus eliminating any solid waste externality. If,
because of the nature of government, municipal agencies are
incapable of charging cost-based prices for garbage collection,
it seems unlikely that the federal government could institute
and administer an efficient system of product charges either".
This would be a double tax, at least at the outset. Thirty
percent of households and 90% of commercial establishments
already pay directly for the collection and disposal of solid
waste through private hauler charges or some form of local tax.
The solid waste disposal tax would be regressive. The
heaviest impact of this excise tax would be on lower income
families. These families spend a much greater portion of their
income on packaged foods and other necessities which use paper
than do the higher income levels.
The disposal tax would also be inflationary. With a
ten year phase-in, a $30 per ton tax in the first year it is
fully implemented would mean a tax of $2.6 billion on the
paper industry which becomes part of the paper cost structure,
and after markups of 50 to 100 percent, as it is passed through
the distribution chain, would add $4 to $5 billion to the con-
sumer's annual burden.
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Ms. Susan Mann
May 31, 1978
Finally, President Carter has pledged to simplify the
tax system and not make it more complicated and burdensome —
certainly not to add a new tax which is both inflationary and
regressive. We find it hard to believe that the RCC would
recommend to President Carter and the Congress this new excise
tax, particularly when President Carter has committed his Ad-
ministration to an all-out war against inflation and has
stated that his Administration would not support any new taxes
during 1978.
Review of Staff Background Paper #9
Design Issue #1: What products should be subject to the
charge?
The first sentence under this section accurately describes
what should be done; namely, the charge should be levied on
everything entering the municipal solid waste stream. The
discussion then goes on to explain the difficulties of imposing
such a broad charge and concludes that the ease of identifying
paper and packaging materials makes them the logical candidates
for the solid waste tax. It is difficult to understand why
food wastes, furniture, and the miscellany of items that wind
up on the garbage heap should be excluded from the "internalized"
cost of disposal.
Moreover, in figuring percentages as to how much of the
municipal waste stream would be covered under the various options,
the report fails to take into account that less than half of
paper produced enters the municipal solid waste stream. In
1976, the Paper Industry produced a total of 64.2 million tons.
15.3 million tons of this was recovered as waste paper for re-
cycling, export and other uses. 9.2 million tons went into
permanent usages, such as books, permanent files, building and
construction papers, etc; 3.7 million tons were sewered, went
into cigarette papers, or were disposed of in home incinerators
or rural private disposal areas. Of the 36 million tons re-
maining, an estimated four million tons went into industrial
solid waste handled at factories, plants, etc. This left
approximately 32 million tons, or about half of the total paper
produced which actually impacted the municipal solid waste
stream.
If a tax is to be levied, it should be levied on all com-
ponents of the solid waste stream.
Design Issue #2: What types of social costs of municipal
services should form the basis for the
charge?
While it is true that the overall costs of seeing a product
through from its creation to its ultimate removal include more
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Ms. Susan Mann
May 31, 1978
than the cost of manufacture and distribution, the question
still remains as what is the best way to take care of the
steps beyond those where the individual buys the products.
If it is to be a tax on the products sold, then a national
sales tax to accomplish that would be a better way to go than
the discriminatory actions that are implied by this solid
waste tax. It is obvious that if all the costs of litter and
direct costs of existing municipal solid waste management are
to be incorporated in the price, then it should not be on
only a portion of the garbage that is generated by individuals.
We note the reference to "tax advantages" for virgin materials.
Our testimony in coming hearings will document our position,
that this is an insignificant factor in inhibiting recycling.
We do not agree with any of the options. Any distribution
must encourage the most cost-efficient system, locally
appropriate to the community. Money in excess of this would
reward inefficiency and would not be in the public interest.
Design Issue #3: What pricing concepts should be used
to set the charge level?
The question of marginal cost pricing is interesting but
somewhat academic in this case. The matter deals primarily
with short run savings associated with municipal waste re-
duction; if one were to look at the items that were packaged
and relate them to the income distribution of those who buy
these packaged items, one would find that the ability to pass
on a marginal price large enough to reduce the volume of
municipal waste would be horrendously high, if appropriate at
all.
If average cost pricing is to be the means for establish-
ing the solid waste tax, why not leave the present system in
place which requires local governments to take care of their
local requirements. If subsidies are to be granted to low in-
come areas to help them meet their solid waste management
problems, then it should not be done by increasing the cost of
packaged items to low income people who are heavy users of such
items. A system within the grants-in-aid programs could be
devised so that funds could be earmarked for solid waste manage-
ment. If done through the normal general revenue-grant-in-aid
programs then all citizens would foot the bill. Although not
as disciplinary as local taxes, the grants-in-aid route has
advantages over a solid waste tax. As the above indicates, we
do not favor any of these options.
132
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Ms. Susan Mann
May 31, 1978
Design Issue #4: How should the charge level be
determined for specific categories?
All of these options contain inequities; however, we
favor the weight basis as the most practical method of imposing
such a tax.
Design Issue #5: Should the charge be adjusted to
account for geographical cost variations?
Inasmuch as solid waste is a local issue with local im-
pacts, any equitable disposal tax should be local-area-specific;
although the Background Paper dismisses this Option (#3) as
being "not administratively feasible", as we discussed above,
either local taxes or a general revenue-grants-in-aid program
would accomplish this.
Design Issue #6: Where should the charge be collected?
Placing the tax at the producer level invites a pass-
through, with little effect upon consumption. Individuals will
respond to higher prices by simply asking for more claim checks
to goods in the form of higher wages.
The tax should be placed on the consumer whose demands
generate the solid waste. By recognizing and admitting their
contribution to the growing solid waste stream, residents will
have to participate in the solution of the problem. If a
simple means for solving solid waste problems is desired, it
already exists.
Local taxes take care of local consumption habits, local
garbage handling facilities, and involve the citizen in conser-
vation efforts as well as other areas of decision making that
affect values and standards of living.
Local taxes used for garbage disposal are an equitable,
controllable and efficient means of dealing with the problem.
They appropriately apply to all garbage.
The report states, "Placing the charge at the wholesale
or retail distribution stage in the product's life cycle would
be highly undesirable from an administrative standpoint."
The complexity of the administration of the program is
simply in the minds of the developers of the program. Just
looking at the flow diagram in Figure 1 shows that the most
obvious point to make the collection is at the point of consump-
tion, or final use and this is tantamount to the local sales
taxes that are prevalent all over the nation.
133
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M ;. Susan Mann
Ma.y 31, 1978
The problem is more in the allocation of receipts by the
local governments. If the national government were to decide
to preempt this area of local decision making, then a national
sales tax is an obvious way to provide the funds for such
national activities. If a national program is desired, then it
should truly be a national effort, and not a convoluted budget
that attempts to isolate obvious areas where a tax would be
relatively easy to impose and to collect without regard to
equity or the achievement of desired goals.
If the aim is to finance better solid waste management,
then a program should be designed to do that and it would not
be a discriminatory type program such as the one that has just
been designed.
If the aim is to discourage use of products, then the price
adjustments that are required in the packaging forms to achieve
such an end would be so large as to create a tremendous, in-
flationary spiral that would impact those in the lowest income
brackets most heavily.
Design Issue #7: How should imports and exports be
treated?
The import/export problems in administering this tax would
be considerable. Whichever options are followed, problems would
be created in world trade. Under the GATT Treaty we cannot
indirectly subsidize exports by charging less for paper abroad
than here. Moreover, this tax would discriminate against Cana-
dian newsprint since their mills cannot economically get U.S.
post-consumer waste. This may involve a violation of our in-
ternational obligations by placing a new non-tariff barrier on
imports.
The tax could subsidize foreign printers. Since printed
materials from overseas would not be taxed, it would create an
incentive to have educational and other communications materials
printed abroad, rather than printed here where the paper - which
is a major part of the cost of the job - would have the added
cost of $30 per ton.
The above problems are reflected in Options #2 and #3,
which we would favor. Options #1 and #4 would set up further
inequities in that they would tax paper which goes abroad
which does not impact the solid waste stream and would exempt
imported paper which does impact the solid waste stream. In
effect, it would make the domestic manufacturer subsidize the
solid waste disposal costs of the foreign product.
134
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Ms. Susan Mann
May 31, 1978
Design Issue #8: Should there be adjustments to the charge
and/or credits for resource recovery
and recycling?
The second sentence of this section is key: "Accordingly,
if a product does not enter the municipal solid waste stream
no charge should be levied on it". As discussed under Design
Issue ttl, many paper items, which under the Hart Bill would be
taxed, do not enter the municipal waste stream. As we noted,
it is estimated that less than 50% of the paper produced in
1976 actually entered the solid waste stream.
This section states that the simplest approach would be to
reduce the amount of the disposal charge to account for the
total municipal nationwide savings due to recycling activities.
If the aim is to increase the recycling of materials, then
a better program can be devised that would be aimed at achieving
these results. Studies on recycling potential indicate that
there are many stages in the process of collecting waste and
reusing it where some form of tax incentive or special assistance
could improve the economics of recycling. The solid waste tax
approach injects the national government as a collection agency
to receive huge amounts of money and distribute them in a highly
discretionary manner, changing rules wherever it is convenient
and wherever the administrative problems can be reduced. An
increased rate of recycling is a desirable goal for many reasons
including fears over limited resources. But the paper industry
is not in that category. Trees are a renewable resource; the
industry has been stepping up its investments in timberlands and
increasing its productivity both in terms of yield and harvest.
The industry has also been increasing the proportion of recycled
material in the manufacture of paper and paperboard wherever
product quality and productive capacities of individual manu-
facturers permit.
The need to increase the recycling rate in paper is mini-
mized by the continuing renewable supply of primary material,
but manufacturers are not insensitive to the changing economics
of waste use or to social pressures. The hope for increased
recycling rests upon the ability to make the economics of re-
cycling more attractive than it now is in the paper industry.
This requires more stable prices for waste paper which in turn
would suggest that new means be found for stabilizing the re-
lationship between a steady growing supply and the volatile
demand dictated by the market place. Incentives that can offset
the effect of these volatile prices on the incomes of the
smaller recycler would be useful. The larger producers will
increase their use of waste paper and old corrugated wherever
the economics so dictate.
135
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Mi. Susan Mann
May 31, 1978
Nowhere in this section is there consideration of giving
a credit for manufacturing paper from forest residues and wood-
making wastes. These wastes would, if they were not utilized
by paper mills for their fiber content, be left in the forest
or outside the saw mills to adversely impact the ecosystem.
It seems logical that if a paper mill gets credit for using
post-consumer waste which would otherwise impact an urban
solid waste stream that it should also get credit for using
forest wastes which would be left on the forest floor and
slow down the cycle of forest growth. We believe any acceptable
option should include use of forest residuals.
Design Issue #9: Use of the Solid Waste Disposal Charge
To transfer the funds into the general revenues would
merely swell government spending programs at the expense of
those in the lower income brackets. To assume that other taxes
would be reduced to offset this negative impact on selected
groups in the population is naive. Retired workers, who pay no
taxes or social security and whose budget allocation to packaged
goods is high, would be severely disadvantaged. A major adjust-
ment to the tax mechanism would be needed to offset this impact.
To add the revenues to existing revenue sharing programs
would not solve the solid waste problem since the local govern-
ments could use the funds in a discretionary manner and the
recipients of such funds would not necessarily be the ones
with the solid waste problem.
To distribute revenues on the basis of population alone
would penalize communities which make efforts to conserve,
recycle and in many ways act responsibly in light of their local
solid waste needs. Fostering responsible individual behavior
should be an aim of government programs and this approach would
do just the opposite.
Option #4 is the least inequitable solution, but it should
be so designed as to encourage cost efficiency, and not reward
high cost uncontrolled solid waste disposal operations.
Design Issue #10: Should the introduction of the charge
be phased-in over time?
In our review of Background Paper #8, we discussed some
of the economic impacts of a solid waste disposal tax with a
ten year phase-in. These impacts would be doubled with a five
year phase-in. Option #3 would create extreme intra- and inter-
industry market dislocations. We favor Option #1.
Design Issue #11: How should the charge be adjusted
over time?
As more and more cities go to resource recovery and mine
the energy and materials values in solid waste, there will be
136
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Ms. Susan Mann
May 31, 1978
at each of these locations income to balance against the costs
of solid waste collection and disposal. In the not-too-distant
future, city after city will be making money on its garbage,
and this must be taken into account in cost surveys, and in
setting the taxing level.
* * * *
To sum up our position, the suggested program would not
significantly reduce the volume of solid waste, would cause
little increase in recycling, would not meaningfully reduce
total natural resource consumption. As a method for fi-
nancing solid waste disposal, it would not be equitable, and
it would not encourage efficient, economical solid waste
management.
Thank you once again for the opportunity of presenting
the Paper Industry's comments on Background Papers #8 and #9.
If members of our industry or the API staff can be of further
assistance to the members of the RCC or its staff in its de-
liberations, please let me know.
d J. Wiechmann
or
Affairs
Environmental
RJW:js
137
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Association ol American Publishers, Inc.
1707 L Si reel, NW. Suite -480
Washington. D C 20036
Telephone 202 293-2565
Townsend Hoopes
President
May 26, 1978
Resource Conservation Committee
401 M Street, S.W.
Washington, D. C. 20024
Dear Sir:
The Association of American Publishers has read with interest the draft report
of the Resource Conservation Committee (identified as Staff Background Paper
No. 9) of April 17, 1978. We are pleased to note that option 4 on page 5 is
"Exempt specific products from the charge (e.g., books)."
As we have argued previously, we regard the exemption of books from any solid
waste disposal charge as absolutely vital to the survival of the publishing industry.
If such a charge were added it would become impossible for publishers to provide
school books at a price within the purchasing power of the schools and the students.
We sincerely hope therefore that you will maintain in your planning a full exemption
for books.
Sincerely,
Ji ft^y-A iTsv
Townsend Hoopes
138
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1 120 CONNECT oil I «"ENUF. N iV • SUIiLO-V • V. •jH.Nf-rwJ Of 2f]fi.'>
iELEPHJ'jr. I2C?'6?? JGU
May 18, 1978
John Robinson, Executive Director
Resource Conservation Committee
Staff
U.S. Environmental Protection
Agency
401 M Street, S.W. (PM-221)
Washington, D. C. 20460
Dear Mr. Robinson:
The National Solid Wastes Management Association appreciates this
opportunity to comment on the staff background papers Nos. 8 and 9,
released on April 18, 1978 and to share our thoughts on the proposed
product disposal tax.
We are disappointed and concerned that the background prepared for the
Resource Conservation Committee does not address the directive of
Section 8002 (j)(D) of RCRA to study the "appropriateness and feasibility
of employing as a resource conservation strategy and imposition of solid
waste management charges on consumer products...." The documents
prepared for the Committee are an unbalanced review of the issues
involved in trying to make a product tax work rather than a critical
examination of the basic question of whether the tax would be appropriate
or feasible in the first place.
From our review of the available research, there is no justification for
enactment of a consumer consumption tax such as the proposed "product
disposal charge."
The entire argument for the product disposal tax rests on the assumption
that the pricing changes induced by the tax will change consumer con-
sumption patterns and thus effect resource conservation. There is no
empirical evidence to sustain this assumption. EPA Deputy Assistant
Administrator Steffen W. Plehn, in fact, told the Forest Industry
Advisory Council meeting in Boca Raton, Florida, on February 10, 1978,
that "the product charge is estimated to have only limited waste
reduction effects (perhaps 1.5 to 2.5 million tons per year)...."
Moreover, a Columbia University study of refuse collection costs done
for the National Science Foundation found no evidence that pricing
affects consumption of solid waste services. The Columbia researchers
concluded that even where consumers paid a varying fee according to the
139
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Mr. John Robinson
Ma- 6, 1978
level of their service, there was no impact on the quantities of waste
being generated (E. S. Savas, The Organization and Efficiency of
Solid Waste Collection, D. C. Health and Company, 1977, page 85).
No research to date indicates that the pricing approach will improve
resource conservation. But, even if further research should reveal that
this approach can stimulate resource conservation, the rationale and
product design discussions in papers Nos. 8 and 9 suggest that the
present system of pricing solid waste services is superior to the
proposed product disposal tax.
Today's system of solid waste service pricing does a fairly good job of
matching prices to "exact costs." Regulatory protection of the environ-
ment mandated in RCRA will further assure that the full social costs of
disposal are borne by the disposal site operator and passed on by him to
his customers (or borne by local taxpayers). For most commercial and
industrial accounts, the price charged the customer effectively matches
the cost of providing the service. Similarly, the price is determined
by the cost of service in the 39 percent of the communities in the
country where private haulers make collection arrangements directly with
householders. Even in the remaining communities, pricing of solid waste
services is directly related to the cost of providing service at the
municipal level; that is, municipal collection and disposal costs are
reflected in either budgets or in service contracts with private waste
management firms. Customers or taxpayers, in these cases, pay a varying
rate according to community disposal costs.
This pricing system is more efficient than the proposed product disposal
tax. Paper No. 8 concedes that "the national disposal charge is some-
what inefficient because it does not vary as the local cost of solid
waste management varies." Sensitivity is further diluted by employing
national averages and exacting the charge on manufacturers rather than
on consumers directly. The net result of a product disposal tax would
be less exact than the pricing system already in effect for municipal
solid waste management services. It completely misses the stated
objective of the proposal.
Furthermore, no research is offered to support the assertion in paper
No. 8 that local user fees "provide an incentive for illicit dumping."
We doubt that research would confirm such a statement. Illicit dumping
is a gross form of littering that results from the inconvenience of
available disposal service and is unrelated to the costs of solid waste
service. On this point, the simplistic design of Table II on page 9 of
paper No. 8 betrays the shallowness of its analysis. Rather than ask
which alternatives encourage littering, why not turn the question
around: "Does each system encourage litter reduction?" The product
disposal tax fails this test absolutely.
The product disposal tax is a misguided approach to resource conservation.
Its appropriateness and feasibility are unjustified, its assumptions
untested and conjectural, and its design so compromised by administrative
requirements as to render invalid its touted impact as an incentive for
140
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Mr. John Kobinson
May 18, 1978
resource conservation. The objective of requiring consumers to pay the
full social costs associated with environmentally sound disposal of
their wastes can be achieved through implementation of RCRA. In a draft
environmental impact statement released April 21, 1978, EPA calculated
that the cost of full compliance with the Act's land disposal regulations
will add about $667 million to the nation's solid waste management
costs. Since the objective of internalizing costs will be achieved
under the present system, there is no justification for burdening the
consumer with an additional $2 billion a year excise tax the benefits of
which are undocumented and in considerable doubt.
While we can find no justification for consideration of a product
disposal tax, we would be remiss in not offering our views on how such a
system might be designed to maximize its goal of matching prices with
"exact costs" of waste management. Nothing in these further comments
should be construed to suggest that we feel evidence exists which would
justify implementing the system at all. We offer these comments on the
specific questions raised in paper No. 9 despite our hope that the
Resource Conservation Committee will insist on documented evidence of
the appropriateness and feasibility of the proposal. We expect that, if
the Committee examines that justification, there will be no need to
examine the design issues at all because the entire project will be
abandoned as infeasible.
1) What products should be subject to the charge?
If the tax is to be adopted, all products entering the municipal waste
stream should be subject to the charge (except recycled materials
discussed below at No. 8). Limiting the charge to two-thirds of the
volume is inefficient and discriminatory because the charge becomes
unrelated to the volume of refuse being generated and becomes an excise
tax on packaging and other selected materials. Exemption for durables
is especially unjustified. Durables will require disposal eventually,
and, since disposal will be delayed, disposal costs will undoubtedly
increase during the product's life. It might even be argued that
durables should be charged a greater disposal charge, not exempted from
it. Additionally, bulky wastes such as major appliances and furniture,
and other durables with special disposal requirements—rubber tires, for
example—entail greater disposal costs—hardly in keeping with exempting
them from the tax altogether. We recognize that charging all products
presents administrative problems; but if more products are not charged,
any advantage claimed by the product disposal tax over the present
pricing system is forfeit.
2) What type(s) of social costs or municipal services should form
the basis for the charge?
If there is to be such a tax, any product charge should be based on the
cost of providing environmentally acceptable service. The EPA has
already calculated the costs of implementing the upgrading procedures
required under RCRA in its April 21 environmental impact statement.
-------
M: •_ . i Robinson
May 18, 1978
3) What pricing concept should be used to set the charge level?
Marginal costs should be the basis for calculating the total costs of
service as the only efficient economic basis for such a calculation.
Because average cost pricing sacrifices sensitivity to individual waste
generation it negates any advantage which the product disposal tax might
claim over the present system. An accurate long-run pricing based on
marginal costs is possible when a municipality contracts with private
industry for all residential service. The price quoted by the private
contractor exactly'reflects his cost. Municipal costs, on the other
hand, are not always apparent. For example, the Columbia University
study referenced in paper No. 8 also found that, on average, for cities
using municipal crews to collect residential refuse "the actual cost was
30 percent greater than the cost shown in the budget for that service."
(page 200) Short- or long-term, however, the Committee should be given
empirical data on refuse collection costs. The costs — the capital
costs of equipment and facilities, the number of workers employed amount
of time which it takes to service each pick-up — are relatively unchanged
when the amount of refuse is decreased by only a matter of several
percentage points as would be expected under a product disposal tax.
Companies would need the same number of trucks, maintenance facilities,
crews and time on the routes to collect the refuse. The only marginal
savings would be, possibly, on fewer trips to the landfill and on
disposal charges paid on a per ton or cubic yard measure.
4) How should the charge level be determined for specific product
(or material) categories?
If the tax is to be adopted, to be fully efficient, it should be based
on the amount of disposal cost which the particular item will require.
Although volume measures may be superior to weight and per unit charges
called for in S. 1281, the discrimination among materials is too extreme
and unrelated to the actual disposal costs of the materials. The way
the system works right now is better. Costs are assigned—and priced—
on an account-by-account basis for the most commercial and industrial
customers and for privately-collected residences and on an aggregate
basis, community-by-connnunity, for contract- and municipally-collected
customers.
5) Should the charge be adjusted to account for geographical cost
variations?
It is inconceivable that a charge purporting to assign "exact costs" for
product disposal could fail to distinguish between the varying costs of
disposal from locality to locality. Environmentally-sound disposal
practices entail different methods, hence costs, necessitated according
to a host of technical reasons. In addition, some communities have more
efficient waste management systems than others. If an average figure is
used, consumers in communities with efficient systems will be forced to
subsidize their less efficient neighbors. This approach would lemove
142
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Mr. John Robinson
May 18, 1978
both the equity and the incentives for efficiency in the present pricing
system. Today, local disposal charges are directly related to local
costs. Sacrificing equity for administrative ease, once again, sacrifices
economic efficiency.
6) Where should the charge be collected?
If the purpose of the product disposal tax is to assign costs to products
so that each consumer product bears its "exact" total "social" cost,
then placing the collection of the charge early in the production/
distribution system totally frustrates the intent of the product disposal
tax. Collection of the tax early in the production/distribution system
makes good administrative sense only if it is the purpose of the tax to
generate revenues. Solid waste services today, of 'course, have the
advantage of exacting the service charge directly on the waste generator
or his local elected representative.
7) How should imports and exports be treated?
There must be a mechanism to treat imports and exports equitably. It
would be unfair to ask U.S. manufacturers to absorb a cost representing
final disposal costs for their exports since they will be disposed of
abroad. Similarly, it would be unfair to ask U.S. manufacturers to pay
a disposal tax and compete against imports which will be disposed of in
this country if those goods did not also have to pay the same tax. At
present, of course, disposal charges are levied on the amounts of wastes
actually disposed of, no matter where they were manufacturered, eliminating
any inequity on this count.
8) Should there be adjustment to the charge and/or credits for
resource recovery and recycling?
If the tax should be implemented, there should be an adjustment or
credit to reflect materials and energy which can be recovered from the
waste stream to maximize economic efficiency. Otherwise, the impact of
the product tax on consumer prices is likely to be so negligible,
especially when consumers' minds are so numbed by the continuing on-
slaught of inflation, that it would produce no shift in consumer buying
habits — an aim of the product disposal tax. Every effort should be
made to make the credit as comprehensive as possible to include "extra
industry" recycling and energy recovery. Setting the amount of the
credit, of course, would represent another of those government
interventions into the private market where not even the wisdom of
Solomon could produce an equitable result.
If, as Steffen Plehn told the Forest Industry Advisory Council in
February, the major resource conservation benefit of the product disposal
tax is in its promotion of markets for recycled materials, the EPA
should be recommending a simple extension of tax credits for manufacturers
who use recycled materials rather than a cumbersome and inequitable tax
on consumer consumption.
143
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th . John Robinson
y .y 13, 1978
9) What use should be made of revenues collected from the solid
waste disposal charge?
The total impact on consumer product pricing which may be expected from
a product disposal tax would occur no matter what is done with the
revenues derived from the tax. Any distribution plan should be weighed
independently to determine its merits. Resource conservation can be
furthered through tax credits to recycling industries or their customers,
but this can be accomplished, as mentioned in response to Question 8
above, by adjustments to the product disposal tax collection system and
need not be a separate subsidy with the proceeds. Care should be taken
to avoid a subsidy program which would dislocate the present collection/
disposal system or hamper its efficiency. Any distribution of product
disposal tax revenues to governmental units will have a negative impact
on private service providers. Since the present system seems to be
operating well without a direct federal subsidy, we strongly urge that
the revenues raised by any product tax which might be levied, be
channelled to the general fund or returned to taxpayers as an individual
tax credit.
10) Should the introduction of the charge be phased in over time?
While phasing in any product disposal tax which might be enacted over a
period of time would soften its impact, the adverse impacts of such a
tax would be mitigated only slightly.
11) How should the level of the charge be adjusted over time?
The level of the charge, if one should be enacted, should be reviewed
periodically, not only to see that it reflects disposal costs, but to
see if it is achieving modification in production or consumption which
warrant the enormous administrative overhead the system would entail.
In conclusion, after a careful review of the papers and related available
research, we find no justification for a product disposal tax. No
evidence has been presented that validates the basis assumption that
pricing solid waste services according to their total "social" costs
will have the effect of encouraging greater resource conservation.
Serious doubts, on the other hand, cloud the other basic premise that
the product disposal charge—compromised as it would be by a string of
administrative short-cuts—could improve the present system of assigning
consumer prices in accordance with costs. We strongly oppose imposition
of a new $2 billion a year consumer consumption tax on the questionable
and undocumented rationale presented in support of this proposal.
Very truly yours,
•~7^—
'4£X^^&Lx_
/ / /
Eugene J. Wingerter
Executive Director
EJW/vr
144
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Weqman
*^rMf^iiurrn
ENGINEERS
Leonard S. Wegman Co. Inc. 100 East 42nd Street, New York. NY 10017 Telephone 212 661 -4210
LEONARDS WEGMAN PE GEORGE R SCHEVON PE JOHN TEARS IS RICHARDT FELAGO PE
LEMBU KALD PE HENRY LIEBMAN PE W OWEN GRAHAM
WALTER R SMITH. PE HARRY LEIBOWITZ R A DONALD N WEISSTUCH PE
ROGER G BURNS PE MAURICE M FELOMAN PE HERBERT MANDElBAUM PE
Consultant
May 31, 1978
Susan Mann
Public Participation Liaison
Resource Conservation Committee
Environmental Protection Agency
401 "M" Street, S.W. (WH-563)
Washington D. C. 20460
Dear Susan:
Fred Smith suggested I give you my comments on resource
conservation committee background papers 8 and 9 of April 1978.
Tax Exempt Sources of Solid Waste:
I find no emphasis on tax exempt sources of solid waste,
such as hospitals, schools, parks, highways, religious
institutions, government buildings. All are primary sources
of solid waste, but are generally exempt from property taxes.
Thereby they unfairly burden non-exempt tax payers by
requiring the non-exempt sources to, in effect, pay for the
load the tax exempt sources impose on solid waste costs.
Some 40% of real property in New York City is exempt
from paying real estate taxes.
A product disposal charge (PDC) would ensure that tax
exempt producers of solid waste would pay a share of solid
waste management costs. Given the political difficulty of
obtaining any local tax revenue from such exempt sources,
a product disposal charge is perhaps the only way in which
solid waste costs caused by activities in the tax exempt
sources can be recovered. Such cost recovery would, of
course, relieve those who pay real estate taxes of a growing
portion of their tax burden
145
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jmon
ENGINEERS
Returning PDC Revenue to Local Government:
The simplest form of channeling the revenue back to the local
government responsible for solid waste management is by direct
population measurement. The accumulation of disposal charge
revenue and its distribution to local government could then be
handled by a private management firm, avoiding establishment of
a new government agency.
To receive its share of PDC revenue, the local government
could file a statement of its precise solid waste management
responsibilities. Where such responsibilities are less than
complete, pro-rata reductions in the distribution would leave
more funds for those with greater responsibilities. A
further restriction should require recipient local governments
to be limited to using such distribution only as a supplement
- to their present solid waste management budgets - rather than as
a substitute for such budgets.
I enclose a copy of a recent article on the subject of product
disposal charge, and I would be happy to expand on any aspect.
Sincerely,
LEONARD S. WEGMAN CO. INC.
Leonard S. Wegman, P
Chairman
LSWrvet
Enclosure
146
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SHOULD
WE TAX
VIRGIN
MATERIALS
TO FINANCE
WASTE
DISPOSAL?
a debate
for the affirmative,
Leonard Wegman
for the negative,
Richard Posner &
William Lancles
The product charge, a federal virgin-materials
tax to finance waste disposal, has been around as
a concept since 1970. Only recently has it gained
wide attention. It was featured in EPA's Fourth
Report to Congress last summer, m an argument
written primarily by EPA official Fred Smith, Jr.
The RCRA-created Resource Recovery Commit-
tee, a Cabinet-level task force, is studying the pro-
duct charge, and it is before Congress as a bill
sponsored by Senator Gary Hart (D-Colo.). The
idea began life as the "penny-a-pound" fee - an
excise on most virgin commodities, to be rebated
to cities on a revenue-sharing basis. It's now up to
$30 per ton, or 15 cents per pound Nothing's safe
from inflation.
The product disposal charge (PDC) is based on
the concept that the cost of collecting and
disposing of an article (after it is discarded and
becomes solid waste) should be built into the ar-
ticle's original purchase price. Handling the
discarded product is as much a part of its cost as
is its original manufacture and shipment.
The PDC has been tentatively set at 1.5 cents
per pouna, or $30 per ton, to be paid into a na-
tional fund by the producer who last prepares the
article for consumer use. From that national fund,
money would be distributed per capita to
municipalities, with minimal paper work. A
manufacturer retains the option of reducing the
$30 per ton PDC cost to him by using recycled
materials, and also by decreasing the weight of
his product.
At an assumed product usage of one-half ton
per U.S. citizen each year, the fund would yield $3
billion, permitting a payment of $15 per capita
(less two per cent or so for administration). A city
of 500,000 people would receive some $7,350.000
annually toward its solid waste management
costs.
The basic arguments for a PDC are that:
• Municipalities face constantly increasing
costs for solid waste services, resource
recovery, mandated environmental con-
trols, wages and operation. Revenue
directly related to waste quantities is
needed to pay these charges.
147
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Most solid waste management costs are
now extracted out of general municipal
revenue -largely the property tax, which
bears little or no relation to waste quan-
tities. When the cost of an article's
disposal is internalized into its original
price, a path for the equitable payment of
disposal services is provided.
Cities need to plan long-range for waste
management equipment maintenance and
replacement, and for commitments
related to building and operating resource
recovery plants. Regular payments from
the PDC federal fund will permit orderly
planning, free from the uncertainties of
property tax yields and the demands of
their municipal services.
Collection and disposal of a discarded ar-
ticle is an integral part of the article's
cost, just as the cost of raw materials,
manufacture, shipping, sales and the like.
Manufacturers also need a simple
economic incentive to recycle and reduce
their use of virgin materials. Under the
spur of PDC, a manufacturer makes a
business decision as to how much recycl-
ed materials he wishes to use. In effect,
the PDC system says to him, "If you want
to use recycled materials you need not
pay the PDC. If you expect the city to
dispose of your discarded products, you
pay the PDC."
• The manufacturer has an incentive to
make a lighter product because the PDC is
calculated on the product weight.
Cities have historically handled solid waste
along with police, fire and educational services.
Why the need for a new source of money for solid
waste?
Municipal solid waste conditions have changed
radically in the last 40 years:
Solid waste has increased from a one-to-two
pound rate per person per day, to a current five-to-
six pounds per person per day. Single-service
usage, supermarket shopping, frozen foods, are
all post-World War II phenonema. Anything that
saves labor is welcomed by the public, without
regard for the ever higher quantity of solid waste.
Traditional landfill disposal of municipal solid
waste is no longer feasible in land-short
metropolitan and suburban areas. Complex and
costly plants are needed as replacements.
The public demands high cost pollution-free
collection and disposal systems.
Long-term resource recovery contracts require
long term commitments by a city to pay an
escalating service fee. Private investors need
assurance of a dependable source of funds.
Beleaguered mayors and municipal councils lack
The basis for most discussions of federal pro-
duct charges is a bill proposed by Sen. Gary Hart
(D.-Colo.) which, for reasons unclear to us, singles
out rigid containers (mainly bottles and cans) for
much harsher treatment than other components
of the solid waste stream. Whereas the proposed
charge for paper and flexible packaging materials
is 1.3 cents per pound, the charge for rigid con-
tainers is point-five-cent per container. For this to
be equivalent to the per-pound charge on flexible
packaging materials, a rigid container would have
to weigh an average of 6.15 ounces, which is
much more than one typically weighs. This
discriminatory treatment of the rigid container
has not been justified in terms of differential
costs of collection and disposal.
In addition, the Hart bill is riddled with arbitrary
exceptions, including such delicacies in the solid
waste stream as junked autos and the solid waste
produced by sewage sludge. In fact, it appears
that the proportion of solid waste actually subject
to the product charge under Hart's scheme would
be substantially less than 50 per cent. The exclu-
sions are not only unjustified; they are
economically harmful. If there is a garbage collec-
tion and disposal externality which justifies
Hart's product charge (more below), it is plainly
not limited to the items his bill would tax.
The precise amount of the tax on beverage con-
tainers imposed by the product charge depends
on the number of containers produced each year.
If mandatory deposit legislation were also
adopted. The number of containers produced an-
nually would be smaller than at present (putting
aside the problem of "counterfeit" can produc-
tion), because returnable bottles are, of course,
used more than once. But plainly we are talking
about a tax of several hundred million dollars.
The economic case for such a tax is propound-
ed in Appendix B to the EPA's recently issued
Fourth Report to Congress on Resource Recovery
and Waste Reduction. As we shall demonstrate.
Appendix B is replete with economic errors and,
148
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PRODUCT
CHARGE
DEBATE
CON'T
from an economic standpoint, fundamentally un-
sound.
The EPA assumes that there is an externality --
a social cost -• because those who generate solid
waste do not pay for its collection and disposal.
But in areas served by private scavengers, there is
no externality: the scavenger will not charge less
than the cost to him of collecting and disposing
of his customer's garbage.
It is alleged by the EPA that municipal garbage
collection service is frequently priced below cost
(or not "priced" at all). This yields the familiar
syllogism: government adopts uneconomical
policies, therefore there must be more govern-
mental intervention to correct the inefficiencies
of those policies.
There is no reason in principle why garbage col-
lection cannot be priced efficiently, thus
eliminating any solid-waste externality. If,
because of the nature of government, municipal
agencies are incapable of charging cost-based
prices for garbage collection, it seems unlikely
that government can institute and administer an
efficient system of product charges either.
The Fourth Report states (page 89) that con-
sumers have no economic or market incentive to
consider solid waste collection and disposal
costs when making their purchasing decisions.
This is incorrect. Even where no charge is levied
for garbage collection (or where the charge is
completely unrelated to the amount or disposal
costs of garbage), the consumer has an incentive
to avoid buying products which generate a lot of
garbage. He must store his garbage between pick-
ups and he must carry it to the point of collection.
He is therefore not indifferent to its bulk and
weight-as is evidenced by the demand for gar-
bage compactors and kitchen-sink "disposalls."
Whenever there is a market demand for
recyclables the consumer has incentives both to
segregate and return these components of the
garbage and to switch to products that generate a
recyclable component that he can sell. Finally, to
the extent that the consumer is (or could be)
charged by his garbage collection service for the
cost of collection and disposal, he has (or would
obtain) a strong incentive to substitute products
that generate less garbage.
Even assuming that consumers lack an ade-
quate incentive to economize on their production
of garbage, it does not follow that a federal excise
tax on products which are thought to generate a
significant fraction of solid wastes is an
economically sound solution.
Since the social costs of solid waste collection
and disposal are almost always incurred within
the state in which the garbage is produced
(Chicago's solid wastes aren't hauled to Nevada
for disposal), there is no basis for a federal rather
than a state product charge. Moreover, a uniform
federal charge set equal to the average social
cost of garbage collection and disposal
throughout the United States will distort incen-
tives, possibly in every state, because of the
regional variations (i.e., high in densely in-
habitated areas, low in sparsely inhabited ones).
In states where the true social costs of solid
waste collection and disposal were below the na-
tional average reflected in the uniform federal
charge, the charge would create economic
the luxury of earlier years, when funds were ade-
quate, to easily apportion property tax revenues
among competing police, fire and sanitation
demands.
In the face of all these challenges, a city must
still look to the property tax for its primary
revenue.
But major generators of solid waste - schools,
parks, hospitals, churches, temples, museums,
streets, expressways, government buildings and
the like - do not pay a property tax. In many cases,
their purchases are exempt from sales taxes. Nor
does the tax on a specific property in itself bear
any relation to the quantity of solid waste which is
149
emitted from that property, which waste the city is
expected to handle expeditiously. If the property
tax is a fair measure for indeterminate police and
fire services, it is certainly not a fair measure for
readily quantified solid waste services.
"If the property tax is a fair measure for in-
determinate (city) police and fire services, it is
certainly not a fair measure for readily quantified
solid waste services."
A rational funding system which logically ap-
plies the cost of services is needed. Hence a PDC,
simply based on weight of the items in solid
waste, rather than an inequitable and unrelated
dependence on the assessed valuation of real
property.
-------
misallocation by overpricing products relative to
their true solid-waste social costs; and in states
where the social costs of solid waste were below
the national average, the product charge would be
insufficient to correct the assumed social under-
pricing of the product.
There is no basis in economic principle for
believing that a product charge is an efficient
method of cost internalization relative,say.to a tax
on household garbage output (measured perhaps
by the number of garbage cans the household
puts out for collection each week). Suppose (as is
quite plausible) that the most efficient method of
conserving the resources employed to collect and
dispose of certain types of garbage is the home
compactor or sink disposal!. A household gar-
bage tax would create an incentive to adopt such
devices. A product charge would not, for the
household which by installing a compactor or
disposall reduced the social costs of collecting
and disposing of its garbage would still have to
pay the same product charge (in the form of a
higher price for cans, boxes, and so on) as
households that did not adopt these economizing
methods.
"If government (is) incapable of charging cost-
based prices for garbage collection, it seems
unlikely (it) can institute an efficient system of
product charges, either."
Finally, the Fourth Report argues that a product
charge would not only improve efficiency in the
pricing of products which generate garbage, but
yield substantial revenues to the government.
These goals-improving efficiency and generating
public revenues-are in fact incompatible. Imagine
as an extreme case that the charge was so effec-
tive in shifting consumption to products and
packages that are cheap and easy to dispose of,
and hence would not be subject to the charge or
would be taxed at a low rate, that the tax base
shrank dramatically. The tax would then be a suc-
cess from the standpoint of altering the allocation
of resources, but it would generate little revenue.
Imagine at the other extreme that the tax had little
or no effect on patterns of production and con-
sumption, perhaps because the costs of
substituting products yielding less or less costly
solid waste were prohibitive. Then the tax would
generate substantial revenues, but it would be a
failure in terms of its environmental purpose,
altering production and consumption to reduce
the social costs of solid waste. In sum, the suc-
cess of the charge in raising revenue would be a
measure of its failure from the standpoint of en-
vironmental policy.
A federal solid waste product charge cannot be
justified on economic grounds on the basis of pre-
sent knowledge -- whether considered by itself or
as a supplement to a federal mandatory deposit
law. Considered together, these measures involve
a $2 billion or more addition to American con-
sumers' annual tax burden. Excise taxes are nor-
mally considered a regressive (affecting the poor
more than the well-to-do) and disfavored form of
taxation. A $2 billion addition to existing federal
excise taxes cannot be considered a trivial altera-
tion in the public finance of the nation. •
Leonard S.
Wegman, (left)
chairman of
Wegman Co., a
New York firm of
consulting en-
vironmental
engineers, is
generally credited with fathering the product charge
concept. He is also mayor of Kings Point, New York.
Richard A. Posner is a law professor at the University of
Chicago. William A. Landes (photo not available) is a
economic professors! University of Chicago. Their arti-
cle is based on research conducted for the National
Soft Drink Association, a trade group. Posner reports
that he seldom actually uses the dour academic expres-
sion captured in this photo.
If the PDC is to help municipalities defray the
cost of solid waste management, the measure of
the PDC magnitude should be consistent with the
measure of solid waste management. Weight has
come to be accepted as the best measure of col-
lection and disposal effort.
Solid waste is a heterogeneous material with
many components - paper, glass, metal, wood,
textiles, rubber, synthetics, food waste, vegata-
tion, dirt, concrete, and combinations, ranging
from a loose pile to a heavily compacted mass.
The best plane of reference is weight. While there
may be fair differences of opinion as to the com-
bustibility, rate of decomposition, value as
salvage and the like, there can be no disagree-
ment on the physical weight of the individual arti-
cle or of the mass of solid waste.
The PDC concept calls for the charge to be
assessed by the one who last prepares the article
for consumer use. It becomes a simple task to
note the weight of the shipment for purposes of
assessing the PDC.
In the EPA Fourth Report to Congress (August
1977), the PDC is based on a container unit which
may be more readily applied, logistically -
especially if, as stated in the EPA study, 80 per
cent of all solid waste may be so measured for
PDC assessment.
Under the EPA plan, appliances, automobiles,
furniture, clothing and other like items having
relatively infrequent rates of discard, would be ex-
empt from the PDC.
In any event, the PDC container-unit translates
from the weight basis of an article. The container-
unit method has the advantage of overcoming ine-
quities which may result from applying weight to
150
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YES!
an article of low retail value; for example, a Sun-
day newspaper. The EPA variation of applying the
PDC only to containers, excluding newspapers
and magazines, nicely bypasses the issue of
disparate weight-to-value ratios.
Is not the PDC just another tax leading to more
big government? Any money collected by a
government agency Is naturally viewed as a tax.
But consider the precise role of the PDC. The life-
cycle of a product begins with its design, then
manufacture, shipping, warehousing, and delivery
to the consumer. But the product remains with the
consumer only for limited periods of time. He
discards it when it no longer serves its intended
purpose. The city must collect and dispose of it.
Hence, the beneficiary of the article, namely the
consumer, should pay a price which reflects all
the article's costs from design through disposal.
Now the total cost is truncated-in that the con-
sumer, in effect, transfers the essential cost of ar-
ticle disposal to a burden on property tax
revenues. Is it any more equitable to expect the
property tax to provide for the cost of shipping the
article from the manufacturer to the retail
distributor?
As a matter of tradition and convenience, the ci-
ty collects and disposes of the article. The city
could charge a toll for that service. In actuality, it
would be utterly impractical to asses individual
charges on discarded articles, or even on the
mass as a whole. It is also impractical for a coun-
ty or state to assess the disposal charge, because
of the herculean administrative steps needed to
determine whether an article was manufactured
within or outside the state, and the probability of
disparate charges between one state and another.
Nationally, however, all good subject to the
PDC (which are not exported) would be assessed.
The federal government's role is merely that of a
convenient distributing point, by which the PDC
fees from the manufacturer are paid to the city,
which performs the essential disposal action in
the product's life cycle. Only minimal accounting
steps are needed -• not the kind of applications
and interviews for the conventional federal grant
process. The national fund could just as easily be
administered by a private company on a fee basis.
What would the PDC mean, for example, for
New York City?
The 1978 operating budget for the City Depart-
ment of Sanitation is $271 million. Under PDC, at
a population of 8,000,000, New York would receive
$120 million annually. With no strain on its hard-
pressed treasury, the city could undertake an ex-
tensive equipment replacement program and pay
the debt service (or long-term tipping fee) on ma-
jor resource recovery projects. The city would be
able to match its environmental protection needs
to the financial realities of the times D
Reprinted Irom Waste Age - March 1978
151
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"fj
X
The Society of the -
Plastics Industry, Inc.
sfl
355 Lexington Avenue Ralph L. Harding, Jr.
New York, New York 10017 President
(212)5739400
June 5, 1978
Ms. Susan B. Mann
Public Participation Liaison
Resource Conservation Committee
401 M Street, S.W.
Washington, D.C. 20460
Dear Ms. Mann:
The Society of the Plastics Industry appreciates the invitation to
comment on Staff Paper No. 8 of the Resource Conservation Committee
sent with Ms. Barbara Blum's cover letter of April 18, 1978.
After reviewing Staff Paper No. 8, the Society of the Plastics Industry
is of the opinion that comments we filed with you on December 1, 1977
on the product charge concept address most of the concepts presented
in the present Paper. A copy of those comments is attached.
Again, we appreciate the opportunity to comment on this Staff Paper.
We hope that the Resource Conservation Committee will continue to
encourage the fullest possible public participation in its activities.
Sincerely,
Ralpb L. Harding, Jr.
RLH: gm ^-- ''
Attachment
cc: Ms. Barbara Blum
Chairperson, RCC Senior Advisors
152
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jo.
Tho Society of the "
Ploslics Industry, Inc. -" •* •'
355 Le/snplon Avenue Ralph L. Harding, Jr.
New York! New York 10017 President
(212)5739400
December 1, 1977
Ms. Susan B. Mann
Public Participation Liaison
Resource Conservation Committee (WH-463)
401 "M" Street, S.W.
Washington, D.C. 20460
Dear Ms. Mann:
The Proposed Solid Waste Product Charge included in Appendix B of the Fourth
Report to Congress on Resource Recovery and Waste Reduction has been carefully
reviewed by the Society of the Plastics Industry, Inc.
SPI feels that the objectives sought cannot be achieved by a Federal Solid
Waste Product Charge as envisaged by EPA staff documents and/or Senate Bill
1281. If the charge were to be imposed, it would be a regressive tax, would
cause inefficiency, would inevitably fall unevenly and inequitably on many
products and would not encourage municipal resource recovery. Therefore, we
are opposed to the Federal Solid Waste Product Charge.
The Society of the Plastics Industry is a Corporation organized under the
Not-for-Profit Corporation Law of the State of New York. Its 1300 member
companies and individuals and 49 operating units include those who supply raw
materials, process or manufacture plastics or non-plastics products; engineer
or construct molds or similar accessory equipment for the plastics industry;
and engage in the manufacture of machinery used to make plastics products or
materials for all types. SPI is the major national trade association of the
plastics industry. The majority of its members are the processors and con-
verters of plastics resins into end products which represent 75% of the dollar
volume of sales of plastics in the country; SPI's membership also represents
95% of all plastics materials and machinery manufactured in the U.S.A.
The Proposed Solid Waste Product Charge states three basic purposes:
1) Influencing consumers to consider solid waste costs in purchasing
decisions;
2) Motivate solid waste reducing actions by producers through redesign
for weight saving and development of products with greater use of
recycled materials;
3) Provide economic incentives to cormunities 1hrough government
subsidies for improved solid waste and resource recovery operations.
153
-more-
-------
Ms. Susan 3. Mann
December 1, 1977
The SPI is opposed to the current concept of Federal Solid Waste Product
Charge because of the following:
(a) The Proposed Federal Solid Waste Product Charge is a regressive
tax. Studies have shown that the lower income familes generate
more solid waste.
(b) The proposed tax would create little incentive for consumers to
make their purchasing choice based on waste generation. However,
the cost to consumers resulting from the imposition of such a
tax would aggregate to a national garbage tax of $2 to $4 billion,
depending upon where in the production/distribution cycle the tax
is imposed. As recommended by the Resource Conservation Committee
Staff, placing the tax at the beginning of the production chain,
could result in a cost/profit multiplier effect giving rise to a
higher price to the consumer. If applied at the end, of the dis-
tribution chain, the cost of administrating the program would
seriously erode projected revenues.
(c) The highly competitive nature of the packaging industry already
motivates producers to use the least possible amount of materials.
For example, the current light-weight 65 gram high density poly-
ethylene gallon milk container weighed 90 grams some five years
ago. Every segment of the packaging industry can provide similar
examples.
(d) The Solid Waste Product Charge would unfairly tax those communities
using private garbage pick-up and disposal with each household or
commercial establishment paying the cost individually. Dual
txation would also result in those municipalities that charge
individauls for solid waste disposal, rather than using general
tax revenues.
(e) The cost effectiveness of a Federal Solid Waste Product Charge in
achieving solid waste reduction has not been adequately demonstrated.
It should be quantified and shown to be beneficial before the
introduction of such charges.
(f) It is literally impossible to establish the cost of disposal for .
all individual components of solid waste. Additionally, these
costs vary widely from community to community. Thus, equality and
equal treatment cannot be achieved if such charges are applied on
a national basis. An incentive for each municipality to adopt the
most efficient solid waste disposal or resource recovery system is
not proviHp.d-
154
-more-
-------
Ms. Susan B. Mann
December 1, 1977
(g) As new proposed, the product charge unfairly discrimantes
against various raterials in rigid packaging and does not
reflect the real cost of disposal. For example, the proposed
1/2C per rigid container implies the same disposal cost for
an 83 gram plastics 1/2 gallon soft drink bottle that is
compactable, burns with energy output and leaves no residue,
as compared toits glass counterpart weighing almost 1135 grams
which is neither compactable nor cumbustible. Another
example is the 65 gram plastics gallon milk bottle. If
taxed at the proposed l/2c per unit rate, it would, be equiva-
lent to $70 per ton product charge. Yet this compactable
container, with its high recoverable energy content, costs
no more to dispose of than a 120 gran paper container which
would be taxed at $26/ton.
(h) • The concept of solid waste product charge makes the erroneous
assumption that packaging increase solid waste, when in many
instances, just the opposite is the case. For example, it
would take seven loads to transport the oranges equivalent to
the orange juice in one load of frozen concentrate. Further
complicating the solid waste issue, is the fact that about 60%
of a fresh orange would be discarded as pulp and rind on which
no charge would be levied. A reduction in packaging in this
instance would increase energy consumption, cost of production,
and the amount of solid waste, and would result in the loss of
the animal feed and fertilizer now produced from the orange
peels and pulp at source. Numerous other examples of how
packaging effects a reduction of solid waste can be cited.
(i) It is doubtful that a solid waste product charge will increase
recycling appreciably. The economic factors that mitigate
against recycling cannot be overcome by the exemption from a
fraction of the proposed product charge by using recycled material.
Furthermore, the proposed charge does not provide for a credit
for energy recovery from basic materials such as plastics, a
form of recycling.
The SPI submits that these are adequate reasons for rejecting the Federal Solid
Waste Product Charge concept as now proposed in S.1281.
Ralph L. Harding, Jr
155
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STATUS REPORT ON COMMITTEE WORK PROGRAM
INTRODUCTION
At its meeting last December the Resource Conservation Committee
established a set of priorities for remaining subjects to guide the staff
work program for 1978. These priorities respond to the Committee's legislative
mandate and the preliminary results of its work. Accordingly, the
priorities for staff research and analysis are as follows:
. First priority; policy areas in which the Committee may wish
to consider recommending new legislative initiatives—especially
with respect to post-consumer solid waste.
. Second priority; evaluation of existing Federal policies
for which the Committee may consider recommending changes.
. Third priority; preliminary investigation of areas that are not
presently well-developed but which the Committee considers important
subjects on which to report.
. Fourth priority; background investigations considered necessary
for the Committee to make useful recommendations for future
research.
In addition the Committee has agreed to sponsor a Resource Conser-
vation Conference to explore the nation's goals and values relating
to natural resource conservation.
The major part of the staff work and that of the Committee during
the past six months has been directed at the First Priority items
listed above. The major emphasis has been the design and evaluation
of the solid waste disposal charge. The following paragraphs provide
a summary status review of major project activities of the Committee
and an estimate of completion dates.
It should be emphasized that, with the exception of conclusions
on the subject of design of beverage container deposit legislation
presented in the Second Report, the Committee has not yet reached
any conclusions or policy judgements, nor has it made any recommendations
on the issues under evaluation.
156
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STAFF ANALYSIS ACTIVITIES
First Priority Policy Areas
The evaluation of several policy proposals which the Committee has
identified as possible subjects for new legislative recommendations
is highest on the list of Committee priorities. These proposals relate
to solid waste management and resource conservation. The six high-priority
policy study areas include national beverage container deposits, a
national solid waste disposal charge, local solid waste user fees,
resource recovery subsidies, deposits/bounties for durable and hazardous
products, and a national litter tax.
1. National Beverage Container Deposits. The staff analysis of beverage
container deposits, roost of which was presented in the Committee's Second
Report to the President and Congress (January 1978} is now essentially
conplete. Subsequent to the Second Report, the staff conducted an
analysis using the Research Triangle Institute computer model to estimate
the effect of different return rate assumptions on solid waste and other
impact categories.
A draft of that sensitivity analysis has been distributed for review
by irembers of the Committee. A comparison between the impacts of beverage
container deposits and the solid waste disposal charge remains to be
conducted pending completion of the quantitative work on disposal charges.
2. Sol id Waste Disposal Charges. Working papers have been completed for
the rationale and design options for a solid waste disposal charge (product
charge) with revisions based on public comments. During the past three
months the staff work in this area has focused on: (1) the benefit/cost
model, which will be used to estimate quantitative impacts on prices,
materials, solid waste generation, and recycling, and (2) an analysis of
the institutional structure and cost factors in solid waste management.
In this latter area, a staff background paper providing an overall des-
cription of solid waste management services in the United States has been
completed. This includes information on quantity and composition of waste,
collection arrangements, service levels, disposal methods, cost determination,
cost components and financing mechanisms, and has been included in this
Third Repoct.
Some important changes have been made in the benefit-cost model. These
changes should be completed within the next month. It is expected that the
revised computer program should give better estimates of the impacts
of a solid waste disposal charge and should also be useful in evaluating
several of the resource recovery subsidy options.
157
-------
The analysis of solid waste management costs in the United States
is essential to any estimates of the economic impact of disposal charge,
user fee, and recycling subsidy policies. The staff has been developing
methods for estimating the marginal costs of solid waste collection
and disposal, to determine what reductions in waste quantity mean
in reduced costs to municipalities. Those cost savings, as a result
of changes in the amount of waste generated per household, provide
the basis for any fee, as well as the size of the fee — either as
a local user fee or a solid waste disposal charge. They also provide
a basis for estimating the economic benefits of any solid waste reduction
or increase in recycling.
To quantitatively evaluate marginal cost the staff has initiated two
separate studies. One study uses a process engineering model in which
estimates are made of the long-run reduction in costs based on an
engineering simulation of the collection process. That study will
be completed soon. The second approach is a statistical analysis
of data obtained in the Columbia University survey of solid waste
management. Preliminary results of this study have produced inconsistent
estimates. More work is planned which will probably take six to eight
weeks to finish. At that time the final cost-benefit analysis can
be completed.
The end product of the studies in the solid waste disposal charge
area will be a staff background paper analyzing benefits and costs of
applying the concept. This paper is scheduled for Committee distribution
by September 1.
Work is also continuing on other desion issues involved in product
charges, including: (1) a comparison of weight versus volume as the
best measure of solid waste management costs, (2) administrative costs
of product charges, (3) options for distributing the revenue and
(4) methods of treating imports and exports to minimize international
trade impacts.
3. Local User Fees. Plans for analysis of local user fees were ex-
panded considerably after public comments indicated an interest in that
as a possible alternative to product charges. Staff work has thus far
focused on formulating design issues and exploring available data and
methods for evaluating resource conservation potential. Work scheduled
for the summer includes evaluation of Federal policy options in this area
as well as attempts to develop potential quantitative impact estimates.
A staff paper is scheduled for completion by late summer.
4. Resource Recovery Subsidies. Initial work on identification and pre-
liminary evaluation of alternative subsidy proposals has been completed. A
staff paper presenting policy design issues and preliminary non-quantitative
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evaluation should be finished by the end of July. A quantitative evaluation
of impacts will be undertaken only on selected subsidy options.
5. Deposit/Bounty Polic ies for Durable gnd Hazardous Products. This
work is in the developmental stage and will be acconplished primarily
under contract during the next four months. The intent is to explore
the application of various deposit and bounty concepts applied to specific
(non-beverage container) consumer products that present either special
disposal problems or opportunities for resource recovery.
6. National Litter Tax. Interest has been expressed regarding the prac-
ticality and desirability of extending the State litter tax concept (as
applied in Washington and California, and under consideration elsewhere) to
the national level. A consultant report reviewing the literature and
covering data and policy questions relating to litter is under staff
review. A staff paper based on this and other existing recent data
and State program evaluations will be developed by the end of Septenter.
Second Priority Policy Areas
Second priority policy areas for Committee consideration relate to
the evaluation of existing Federal policies that may be contrary to re-
source conservation objectives or unduly impede resource recovery
activity. In this area the Committee has chosen to focus principally
on current natural resource tax policies and Federal transportation
policies.
The primary responsibility for evaluating how federal tax laws and
regulations affect the use of natural resources and recycled materials
has been with the Treasury Department (under PL 94-568). A Treasury
study of the impact of the tax policies will provide the major input
to the Resource Conservation Committee in this area. After a staff
review of that study, the Committee will determine if further work on
tax policies is needed. Treasury representatives report that a first
draft of the report is now complete.
The Committee staff is currently developing a contract for a
survey of how federal transportation policies affect natural resources
and recycling. A staff paper on this subject is scheduled for completion
in November.
Other Policy and Background Subject Investigations
The analytical work in these areas will be handled primarily by small
contracts and Committee staff but will not receive the same in-depth treat-
ment as the higher priority subjects. Elements of these investigations
are now being scheduled and the work should be completed by late fall.
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The issues include (1) direct product regulation, (2) a national
severance tax, (3) the inplications of federal government research and
development for resource conservation, (4) industrial solid waste,
(5) other post-consumer solid waste sources and (6) hazardous solid waste.
RESOURCE CONSERVATION CONFERENCE
A national conference to focus policymakers' attention on resource
conservation issues is now scheduled for later this year. The purpose of the
conference is to assess the value to American society of the conservation
of natural resources, explore ways to define resource conservation
objectives, and evaluate how conservation relates to other societal goals.
To keep the proceedings manageable and to encourage productive
dialogue, the conference will be limited to approximately 75 participants.
In addition to major addresses and papers, there will be three small-group
discussion sections. The Brookings Institution has agreed to be a co-
sponsor of the conference and carry out all management and administrative
responsibilities. In this capacity, Brookings will invite Members
of Congress and the executive agencies as well as representatives
from business, labor, the academic community and the general public.
Each member agency of the Resource Conservation Committee will send
three participants.
The Committee will publish a report on the conference, including
both prepared papers by invited speakers as well as a summary of the
proceedings and conclusions reached by the working participants.
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APPENDIX TO THE THIRD REPORT
The Resource Conservation Committee is committed to
involving the public in its decision-making. As part of
this commitment, the Committee sought both oral and
written comments from the public. Three public meetings
were held by the Committee to obtain public input on
solid waste disposal charge legislation—November 17, 1977,
in Washington, D.C.; November 18, 1977, in Cincinnati, Ohio;
and November 21, 1977, in Portland, Oregon. A copy of the
Committee's letter announcing these public meetings and
inviting public input is attached. The transcripts of
these public conferences are not included in this Appendix.
However, they are available upon request from the Office of
Solid Waste, U.S. Environmental Protection Agency, Cincinnati,
Ohio 45268. The order numbers for these publications are as
follows:
November 17, 1977 Public Meeting—Washington, D.C. (SW-30p)
November 18, 1977 Public Meeting—Cincinnati, Ohio (SW-31p)
November 21, 1977 Public Meeting—Portland, Oregon (SW-32p)
Each document contains the speakers' oral presentations,
their complete written statements, and other statements
received from the public for inclusion in the record.
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{RESOURCE
COMMITTEE
October 20, 1977
Svcrttuy el Commwn*
Dear Participant:
Swnfaiyof Later
W MWIMI Shmn
CAtimun Council on
Ernironrmnnl Outlity
BMCMtw
The Resource Conservation Committee is the cabinet level
interagency committee set up under Section 8002(j) of the Resource
Conservation and Recovery Act. It is responsible for studying and
making recommendations on a wide range of resource conservation
policies.
The Committee will make recommendations to the President and
NOH.sTAiuro«YMEMBeiw ^g Congress later this year on the desirability and possible design
c££T~ of solid waste product charge legislation. We would like to include
o/jcowwrAfwo/i the puttie j,n ^5 decision-making process and are soliciting your
views on this potential legislative initiative.
We have scheduled three public meetings in November to gather
pertinent information about the solid waste product charge initia-
tive. The meetings will begin at 9:00 a.m. at the following locations!
November 17, Washington, D.C.
November 18, Cincinnati^ Ohio
November 21, Portland, Oregon
These meetings will provide interested parties an opportunity
for a brief oral presentation. The qusstions in the enclosed list
highlight the issues for which we seek public comment. We request
that your presentation address these questions and any issues
you feel should be brought to the Committee's attention. If you
are unable to attend or wish to provide the Committee with more
detailed comrrents, we encourage you to submit your views in writing,
with the assurance that they will receive equally complete considera-
tion by the Committee.
To assist us in planning this meeting, please let us know if
you will attend. Your response, in addition to any comments and
questions, should be directed to: Susan B. Mann, Public Participa-
tion Liaison, Resource Conservation Committee (WH-463), 401 M Street,
S.W., Washington, D. C. 20460, (202) 755-9145.
Sincerely yours,
Barbara Blum
Chairman, Senior Advisory Group
Enclosure
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Resource Conservation Committee
Solid Waste Product Charge Legislation
October 20, 1977
The term "solid waste product charge" refers to a fee or
excise tax levied on consumer products or packaging which would
provide sufficient revenues to cover their disposal and other
external costs. At the present time, the disposal of consumer
products and packaging is generally a municipal government service
financed through property taxes or fixed- periodic charges paid
by users of the waste disposal service. The tax or fee paid by a
user often is not related to the cost of disposing of individual
items. Consequently, a product's disposal costs do not affect the
decision-making process when a product is being produced or
purchased.
If a product's disposal cost is a significant portion of its
value at some point in the production and distribution chain, its
incorporation could affect the type and amount of resources used
in consumer products and packaging. Depending on how it is
designed, a solid waste product charge could bring about increased
materials recycling and could lead to the conservation of energy
and natural resources.
1. What should the Resource Conservation Committee recommend
regarding the potential development of legislation which levies
a solid waste product charge on consumer products and packaging?
Must a product charge be levied at a national level to be
effective? Should State and local governments be urged to
promote the concept?
2. What alternatives to product charges could accomplish similar
results? What are the relative impacts on pollution and energy
and materials consumption of these alternatives?
3. How, if at all, should product charge legislation relate to
Federal, State or local beverage container deposit requirements?
4. What are the social aspects and consequences of product charge
legislation? What sectors of society would be affected?
5. What are the economic consequences, both positive and negative,
of resource conservation as it relates to product charge legis-
lation? Should there be compensation for economic losses and,
if so, how should this be accomplished?
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6. What ace the environmental impacts, both positive and negative,
which nay occur as a result of product charge legislation?
For what products could such charges significantly affect
resource use?
7. Is additional research on this subject necessary or desirable
prior to a legislative proposal? What should such research
focus upon?
8. What are the key elements that should appear in product charge
legislation?
9. What products or types of packaging should be included in a product
charge requirement? What special problems are associated with
putting a charge on particular products?
10. What should the size of such a charge be? Should it vary by
product? What product characteristics (e.g., weight, volume,
value, etc.) should be used as the basis for the charge?
11. At what point in the production/distribution system should the
charge be levied? How does this affect the impact and the
administrative problems associated with the charge?
12. Should the amount of the product charge be reduced in relation
to the amount of recycled material in the products covered
by the charge? If so, by how rcuch?
13. Should the product charge be phased in over time? If desirable,
should phasing be by product category or by the magnitude of
the charge?
14. How should the revenues raised by the charge be used? If used
to offset public disposal cost outlays, how should they be
distributed?
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INDEX
The index that follows is an alphabetical listing of
the organizations and individuals who made presentations
and submitted papers at each of the public meetings.
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PUBLIC MEETING - NOVEMBER 17, 1977
Washington, D.C.; SW-30p
Judd H. Alexander
Senior Vice President
American Can Institute
Steven Burkes
National League of Cities
U.S. Conference of Mayors
Jack L. Cooper
Director, Environmental Affairs
National Canners Association
A. Blakeman Early
Environmental Action
James S. Evans
Senior Vice President
Media General, Inc.
Garden State Paper Company
Charles Felix
Director, Environmental, Health and Public Affairs
Single Service Institute
Norris Hershon
President
National Barrel and Drum Association
Henry King
President
U.S. Brewers Association
Louis Laun
President, American Paper Institute
Joseph Lupton
Private Citizen
Roger McClure
Sierra Club
Jerry Powell
Private Citizen
Thomas Mitchell
Glass Packaging Institute
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Professor Richard Posner
Dr. William Landes
University of Chicago Law School
National Soft Drink Association
Neal Potter
Chairperson, National Association of Solid Waste
Subcommittee Montgomery County Councilman
National Association of Counties
William W. Sadd
President, Glass Packaging Institute
James W. Shields
Chairman of the Board, Judd's Inc.
Printing Industries of America
Mark Sullivan
National Wildlife Federation
Philip H. Taft
Director, Tire Retreading Institute
St. Clair Tweedie
Director, Public Affairs
Paperboard Packaging Council
Marchant Wentworth
Research Director, Solid Waste Project
Environmental Action Foundation
Thomas White
City Councilman, Greenbelt
Private Citizen
Dr. Anthony Yezer
Assistant Professor of Economics, GWU
Public Interest Economic Foundation
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PUBLIC MEETING
NOVEMBER 18, 1977 - CINCINNATI, OHIO (SW-31p)
Rod Edwards
American Paper Institute
Haynes Goddard
Professor of Economics
University of Cincinnati
John Tracey
American Paper Institute
Nelson E. Wittman
Assistant Vice President
Government Relations
Dubois Chemicals
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PUBLIC MEETING
NOVEMBER 21, 1977 - PORTLAND, OREGON (SW-32p)
Sam Bowman
Glass Packaging Institute
Jeremy Brott
Santa Rosa Recycling Center
Thomas C. Donaca
Associated Oregon Industries, Inc.
Thomas Ethan
Northwest Food Processors
Steve Hoke
University of Oregon Survival Center
Robert Keesee
Senior Economist
Government Affairs
Georgia-Pacific Corporation
Valerie Lee
Department of Environmental Quality
Ray W. McDuffee
Lincoln County Solid Waste Commission
Kevin Mulligan
Portland Recycling Team
Paul Norr
Metropolitan Service District of Portland, Oregon
i Bob Packwood
U.S. Senator for Oregon
Joseph Rippee
Potlatch Corporation
Judy Roupf
Oregon Recyclers
Fred A. Stickel
Oregon Newspaper Publishers Association
Robert Swanson
Sierra Club
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Carol Todd
University of Oregon Survival Center
Vern Wheelwright
R.V. Wheelwright Co.
Brian Wilson
University of Oregon Survival Center
Robert N. Witter
Weyerhaeuser Company
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