Implementation Plan For The Resource Conservation Committee: First Report To The President And Congress Of The United States Mandated By The Resource Conservation And Recovery Act Of 1976 (Public Law 94-580)


First Report to the President and Congress of the United States
Mandated by the Resource Conservation and Recovery Act
of 1976 (Public Law 94-580)

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THE RESOURCE CONSERVATION AND RECOVERY ACT
OF 1976
Section 8002(j)
of
Public Law 94-580
"(j) Resource Conservation Committee.—(1) The Administrator
shall serve as Chairman of a Committee composed of himself, the
Secretary of Commerce, the Secretary of Labor, the Chairman of the
Council on Environmental Quality, the Secretary of Treasury, the
Secretary of the Interior, and a representative of the Office of Man-
agement and Budget, which shall conduct a full and complete investi-
gation and study of all aspects of the economic, social, and
environmental consequences of resource conservation with respect to—
"(A) the appropriateness of recommended incentives and dis-
incentives to foster resource conservation;
"(B) the effect of existing public policies (including subsidies
and economic incentives and disincentives, percentage depletion
allowances, capital gains treatment and other tax incentives and
disincentives) upon resource conservation, and the likely effect
of the modification or elimination of suoh- incentives ana disin-
centives upon resource conservation;
"(C) the appropriateness and feasibility of restricting the
manufacture or use of categories of consumer products as a
resource conservation strategy;
"(D) the appropriateness and feasibility of employing as a
resource conservation strategy the imposition of solia waste man-
agement 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 nonrecycling or
uncontrolled disposal of such product; and
"(E) the need for further research, development, and demon-
stration in the area of resource conservation.
"(2) The study required in paragraph (2) (D) may include pilot
scale projects, and shall consider and evaluate alternative strategies
with respect to—
"(A) the product categories on which such charges would be
"(C) appropriate criteria for establishing such charges for
e&
actions such as recycling which would reduce the overall quanti-
ties of solid waste requiring disposal; and
"(E) procedures for amending, modifying, or revising such
charges to reflect changing conditions.
"(3) Tne design for the study required in paragraph (2) (D) of
this subsection shall include timetables for the completion of the study.
A preliminary report putting forth the study design shall be sent to
the President ana the Congress within six months following enact-
ment of this section and followup reports shall be sent six months
thereafter. Each recommendation resulting from the study shall
include at least two alternatives to the proposed recommendation.
"(4) The results of such investigation and study, including recom-
mendations, shall be reported to the President and the Congress not
later than two years alter enactment of this subsection.
"(5) There are authorized to be appropriated not to exceed
$2,000,000 to carry out this subsection.
ate state in the production of such consumer
levy such charce;
(D) methods for the adjustment of such charges to

reflect

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IMPLEMENTATION
PLAN
FOR THE
RESOURCE
CONSERVATION
COMMITTEE
First 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
April 1977
Printed on recycled paper

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RESOURCE
CONSERVATION
COMMITTEE
TMC FSOCRAL INTIRAOSNCV COMMITTKB HTA0LISHCD UNOCR PUBLIC LAW M-MO
401 M Svwt. t.VV„ Wmhlwfww, O.C 30—0
AtMnMrMor, Environmandl Protection Afloncy
To the President and the Congress:
JUN 9 1977
iKKrapa
Sacmaiy of Commana
CmH 0. Andn*
Sacrwtmry of It* Intwrkx
P. Ray MmM
Sacritaiy of Labot
Sacrttaqr ot tt» Tr—tury
Charts* Wmiwi
CMnnan, Council on
Enyironmantal Quality
OMoa of Uanagamant
andBudgat
NON-STATUTORY MEMBERS
Council
of economic AOrtaort
I hereby transmit for your consideration the first
report of the Resource Conservation Committee, which was
established under Section 8002(j) of Public Law 94-580.
The law directs this interagency Committee to conduct a
two-year study and make recommendations to the President
and Congress on a broad range of resource conservation
policies. This report presents the framework for the
Committee's activities over the next 18 months; subsequent
reports will follow at six-month intervals.
As Congress has strongly indicated by including the
heads of a range of executive departments and agencies on
the Committee, the issues in resource conservation are
far-reaching, and the policies the Nation settles upon
for the years ahead in this area will affect every citizen
in a number of ways. The special significance of resource
conservation for the prevention of environmental problems
was recently emphasized by attention to the work of the
Committee in the President's Environmental Message. The
Committee thus approaches its assigned task with respect
for its magnitude but also with recognition of the increasing
need to arrive at informed, balanced decisions at the
national level to help assure sensible utilization of our
natural resources.
As the report makes clear, it is our intent to
solicit wide public participation in the work of the
Committee. A draft of this implementation plan was
reviewed by various public and private interest groups.
Their comments are included as an appendix to this report
and will help to guide our further work. We will, of
course, especially appreciate your comments and suggestions.
Respectfully submitted for
Committee,
ource' Conse/\)ati

M. Costle
Enclosure

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THE RESOURCE CONSERVATION COMMITTEE
DOUGLAS M. COSTLE, Chairman
Administrator, Environmental Protection Agency
JUANITA M. KREPS, Secretary of Commerce
Alternate: Sidney Galler, Deputy Assistant Secretary
for Environmental Affairs
CECIL D. ANDRUS, Secretary of the Interior
Alternate: Joan Davenport, Assistant Secretary for Energy and Minerals
F. RAY MARSHALL, Secretary of Labor
Alternate: Ernest Green, Assistant Secretary for Employment and Training
W. MICHAEL BLUMENTHAL, Secretary of the Treasury
Alternate: Lawrence Woodworth, Assistant Secretary for Tax Policy
CHARLES WARREN, Chairman, Council on Environmental Quality
Alternate: J. Gustave Speth, Member, Council on Environmental Quality
ELIOT CUTLER, Office of Management and Budget
NINA CORNELL, Council of Economic Advisors*
* A representative from the Council of Economic Advisors was invited by
the Chairman to participate in the work of the Committee, in recognition of the
interaction between economic and conservation policies.

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CONTENTS
Section	Page
I. INTRODUCTION 	1
II. COMMITTEE BACKGROUND 		4
Work of Prior Commissions		4
The Resource Conservation Committee 	6
III.	PRINCIPLES AND APPROACH FOR POLICY STUDIES ....	7
Rationale of Resource Conservation and Recovery Policies ...	7
Principles, Guidelines, and Criteria for Policy-Making 	13
Approach to Policy Development and Evaluation	15
IV.	THE STUDY PLAN	18
Range of Policies to Be Reviewed	18
Committee Work Plan	19
Reports and Schedule	26
V.	BUDGET AND STAFFING 	29
REFERENCES	30
APPENDIX 	31

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IMPLEMENTATION
PLAN FOR THE
RESOURCE
CONSERVATION
COMMITTEE
First Report
to the President
and Congress of the United States
Mandated by the Resource Conservation and Recovery Act
of 1976 (Public Law 94-580)
lIUii The Resource Conservation and Recovery Act, enacted October 21,
1976, established an interagency Resource Conservation Committee to
conduct studies and prepare reports to Congress on materials policy
issues over a two-year period (Section 8002j of P.L. 94-580). The
Administrator of the Environmental Protection Agency chairs the
Committee, which includes the Secretaries of Commerce, Labor,
Treasury, and Interior; the Chairman of the Council on Environmental
Quality; and a representative from the Office of Management and
Budget. Although not specified in the law, the Chairman of the
Committee also invited the Council of Economic Advisors to participate
because of the obvious emphasis on economic incentives in Congress'
charge to the Committee.
The Committee is to conduct "a full and complete investigation
and study of all aspects of the economic, social, and environmental
consequences of resource conservation." Resource conservation isT
defined in the Act as "reduction of the amounts of solid waste that are
generated, reduction of overall resource consumption, and utilization of
recovered resources."
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The Committee is to examine a range of policy issues including:
"(A) the appropriateness of recommended incentives and
disincentives to foster resource conservation;
11 (B) the effect of existing public policies (including subsidies
and economic incentives and disincentives, percentage depletion
allowances, capital gains treatment and other tax incentives and
disincentives) upon resource conservation, and the likely effect of
the modification or elimination of such incentives and disincentives
upon resource conservation;
"(C) the appropriateness and feasibility of restricting the
manufacture or use of categories of consumer products as a
resource conservation strategy;
"(D) 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 products, final
disposal and any social value associated with the nonrecycling or
uncontrolled disposal of such products; and
"(E) the need for further research, development, and
demonstration in the area of resource conservation."
The objectives of the Committee are to: (1) develop and evaluate
selected policies affecting the efficiency with which our society uses
materials; (2) involve all major interests in the formulation of these
policies; (3) present these findings and opinions to Congress in a series
of policy reports which will express the preferred options and
consensus recommendations of the Committee. These policy reports will
be submitted to Congress at six-month intervals according to the
mandated reporting schedule.
This is the first Cabinet-level committee to address national
materials conservation policy issues, and the Congressional mandate for
this program suggests that much interest and significance will be placed
on the activities of this Committee. Moreover, since the Committee
represents a broad spectrum of government agencies, its conclusions
and recommendations should reflect a broadly based administration
consensus. It is also clear from the legislation itself that Congress is
requesting specific guidance as to what role, if any, .government should
play in the materials conservation area.
This report is the first of four mandated by the Act. It presents
a study plan for the work that will be carried out by the Resource
Conservation Committee. Although the language of the Act is somewhat
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ambiguous regarding the required scope of the initial study plan called
for under Section 8002(j)(3), the Committee has decided that this report
will provide a framework for the overall resource conservation policy
work. The solid waste management charge concept is dealt with as part
of the overall plan, but no separate detailed discussion is included in
this first report. However, this plan does call for product disposal
charges to be reported upon in the October 1977 report. Any addi-
tions, deletions, or modifications to this plan will be transmitted to the
President and the Congress in the subsequent reports of the Commit-
tee.*
Section II presents a brief historical overview of the Committee's
mandate. Section III discusses the philosophical background and
principles that the Committee will follow in developing and selecting
conservation policies. Section IV presents the specific plans for
activities and the proposed work schedule. Section V presents a brief
discussion of budget and staff issues. The section is brief because
budget and staffing decisions have not yet been resolved.
Administrator Costle, acting in his capacity as Committee Chairman,
directed EPA's Office of Solid Waste to provide initial staff and funding,
and to act as a focal point for coordinating the participation by the
other Committee members. This decision has permitted this first plan to
be prepared; however, the preliminary plans of the Committee staff
indicate that up to $2 million and 25 person-years of effort will be
required to fulfill the mandate of the Act. This is consistent with the $2
million limit authorized by Congress for the Committee, but the actual
organization, funding, staffing, and allocation of effort are uncertain at
this time. The Committee will advise the President and Congress as
soon as these decisions are made.
" The President's Environmental Message was presented on May 23,
after this report had been completed for printing. In his message the
President, in addressing the work of this Committee, stated that:
I am asking the Committee to accelerate its study and
within six months present to me its first recommendations
which are to address the use of solid waste disposal charges
(levies on materials and products which reflect the costs
associated with their ultimate disposal).
The original schedule as presented in this report called for the
Committee to present its initial conclusions on the solid waste disposal
charge and other financial incentive approaches by October. The Presi-
dent has thus instructed the Committee to accelerate its evaluation and
review so as to make recommendations by that time.
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II.
COMMITTEE
BACKGROUND
The joint values of resource conservation and environmental pres-
ervation have been recurring themes in American political philosophy.
Periodically, the nation becomes concerned over the dwindling reserves
of our natural resources and the resulting scars on the earth's surface.
And this concern raises again questions as to what steps should be
taken to ensure wise use of our natural resources. This section
reviews several prior efforts to formulate a national conservation policy
and concludes with a brief legislative history of the Resource
Conservation Committee itself.
WORK OF PRIOR COMMISSIONS
Since World War II, Congress has sought advice on materials policy
issues on four occasions. The first of these occurred in 1952 shortly
after the outbreak of the Korean War.l President Truman, concerned
over possible shortages of strategic materials, established the
President's Material Policy Commission, better known under the name of
its chairman as the Paley Commission.
In 1970, Congress began to consider the proper role of materials
policy as it related to the problems of municipal solid waste. As a
result, the National Commission on Materials Policy was established,?
The legislation setting up this Commission was Title II of the Resource
Recovery Act of 1970. This Act amended the Solid Waste Disposal Act of
1965 and for the first time required EPA to consider recycling as a waste
management strategy. Thus, the linkage between waste management
and material use is of long standing.
The third Congressional request emerged from the unusual
economic conditions that characterized the U.S. economy in 1973-74,
involving unexpected and dramatic short-term scarcities throughout the
economy. This phenomenon coincided with the "energy crisis" and led
to a fear of material shortages. The collective impact of these two
events induced Congress to establish the National Commission on
Supplies and Shortages to investigate the question of why shortages of
materials were occurring and to determine what steps might be taken to
improve the efficiency of the materials-use system. The final report of
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this Commission, Government and the Nation's Resources, was pub-
lished in December 1976.
The work of the National Commission on Supplies and Shortages
provides a base on which the Resource Conservation Committee can
build. The Commission placed great stress on ensuring that current
policies are consistent with a policy of efficient materials use. The
Commission also noted that, in the current market, the price of
materials does not reflect the full costs of their use.
The Commission made several recommendations in the area of
recycling policies. In particular, it generally opposed the Federal
funding of systems to recover energy or materials from waste, whether
by means of grants, loan guarantees, or price supports, as
unnecessary and not cost-effective.
In the area of existing fiscal policies, the Commission was unable
to acquire sufficient information to make any specific recommendations
regarding the capital-gains treatment of timber; however it did discuss
the percentage depletion allowance on minerals. The Commission stated
that, in the absence of compelling evidence for its continuation, the
percentage depletion allowance for minerals should be repealed. The
Commission also opposed the creation of any new tax subsidies for the
consumption of recycled materials.
The Commission considered what steps might be required to ensure
that the market costs of materials and products would reflect the true
costs to society of their use. Specifically, they recommended that the
Government take steps to internalize the cost of disposing of materials.
Among the recommended means of accomplishing this were mandatory
deposits on beverage containers, excise taxes on nonreturnable
containers, and product disposal charges on other consumer packaging
and paper.
In addition to these specific recommendations, the Commission also
stressed its belief that materials will be used most efficiently when
decisions about their use are based upon true costs. The Commission
rejected the concept that recycling was a good per se, and instead
placed its reliance on the outcome of the market process once all
existing biases are removed and total costs have been reflected in
materials prices. The relation of these principles to those adopted by
the Resource Conservation Committee are discussed in this report at
greater length in Section III.
Each of these recommendations will need review by the Resource
Conservation Committee in its early discussions.
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THE RESOURCE CONSERVATION COMMITTEE
The Resource Conservation Committee, established by of the
Resource Conservation and Recovery Act of 1976, can thus be viewed as
the most recent of a series of efforts by Congress to obtain specific
advice on conservation policies. The Senate Public Works Committee
Report on the original Senate version of the Resource Conservation and
Recovery Act provides some indication of the intent of Congress in
establishing this Committee:
An effective Federal program to deal with solid waste may not
consist wholly or even primarily of State grants and technological
research and demonstrations. Information upon which to base
non-technological programs is meager, however. In order to widen
the range of alternatives available to the Congress in the future,
the Committee directs the Administrator, together with certain
other cabinet-level officers, to study the effect of various
regulatory and tax or product charge schemes on decreasing
amounts of materials discarded and reducing amounts of natural
resources consumed .a
The report went on to note that Congress desired detailed information
to provide a basis for determining the most effective Federal role in
guiding resource use and disposal.
The original Senate version of the Resource Conservation and
Recovery Act section establishing the Resource Conservation Committee
provided for only one report at the end of two years. The final version
of the law modified this schedule to provide for reports on conservation
policy issues every six months, presumably so that the findings of the
Committee would not be delayed.
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This section reviews several reasons for concern over resource
conservation, discusses the philosophical principles that the Committee
will follow, and outlines the approach that will be taken by the
Committee in developing specific proposals.
RATIONALE FOR RESOURCE CONSERVATION AND RECOVERY POLICIES
As President Taft noted many years ago, there are a great many
people in favor of conservation, no matter what it means. Virtually
everyone is against waste and supports the principle that materials
should be used as efficiently as possible. In this section of the report,
four reasons for concern over conservation issues are considered: the
impacts of an ever-increasing flow of materials on the environment,
some problems related to a laissez-faire market system, distortions
arising from past governmental policies, and the evolution of our
national objectives and philosophies relative to resource use. Different
interest groups may place very different values on these various
rationales for conservation.
Material Flows, Economic Growth, and the Environment
U.S. households, commercial enterprises, and governments
currently generate over 145 million tons of solid waste annually, of
which about 9 million tons are recycled.* These "post-consumer" waste
figures include the usual types of domestic and office papers,
packaging materials, textiles, household durable goods, garbage, and
yard wastes typically collected by city and private haulers. They do
not include an additional 5 million tons of municipal sewage sludge, 15
million tons of junked autos, and perhaps 30 million tons of demolition
debris which should also be included in the post-consumer waste
category. Among these latter categories, only the metal components are
currently salvaged for recycling.
These post-consumer wastes measure the annual "throughput" of
the economy's material flow system of production and consumption and
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have approximately doubled over the last two decades, growing much
more rapidly than total population. As such, these residuals are the
source and substance of the traditional problems of solid waste
management:
Their collection and disposal cost society several billion
dollars per year;
Part of these material residuals are littered, causing a visual
and public-health nuisance, and creating additional collection
costs;
The disposal of these residuals by incineration, open
dumping, and inadequate landfilling is a major source of
environmental degradation of land and water resources.
As reflected in the Congressional Findings preamble to the
Resource Conservation and Recovery Act, it is also becoming
increasingly recognized that the rising quantities of post-consumer
waste are highly correlated with both the quantities of pollutants
generated at earlier production stages and with the quantities of natural
resources required to maintain our rising standard of living. In our
present economic system, the sequence of material flows—from virgin
material extraction through final product consumption—is best
characterized as a high-throughput, once-through system. Very large
amounts of resources are required per dollar of national product and
relatively low amounts of these resources are recovered at the present
time.
A high rate of post-Consumer solid waste generation combined with
a low rate of recycling thus necessarily implies high rates of Virgin raw
material and energy demands. Similarly, it implies high rates of
industrial waste generation and pollution in the virgin material
extraction and processing sectors, as well as ecological disruption from
mining and harvesting of virgin resources.
For a system also characterized by a high rate of economic growth,
as our system has been, natural resource exploitation and environmental
degradation potentials multiply very rapidly, doubling and redoubling
in just a few short decades. The resulting pressures on the
environment, on domestic natural resource supplies, on international
trade balances, on the economy in general, and on waste management
agencies in particular have all been recognized by Congress in the
passage of the Resource Conservation and Recovery Act.
In this context, resource conservation measures--defined to
include increased efficiency in the use of materials and energy,
reductions in the material intensivenesss of final consumption, and the
reclamation and reuse of waste materials—promise a degree of relief
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from all of these interrelated problems. EPA has documented the
availability of numerous technologies and technical approaches in the
fields of resource recovery and waste reduction in its four reports to
Congress under the Resource Recovery Act of 1970.* However, most
projections suggest that only very modest increments of resource
recovery or waste reduction are likely to take place in the economy over
the foreseeable future in the absence of major Federal policy measures.
Some will regard such projections as positive proof that the market
system cannot operate properly on its own to undertake the socially
desirable resource conservation methods and, therefore, will argue for
major Federal intervention. Others would regard this conclusion as a
logical and valid confirmation that the market system is working well
and argue, therefore, that the types of problems listed above are in
fact non-problems during the next decade or two. The Resource
Conservation Committee intends, as discussed elsewhere in this report,
to take a more balanced view than represented by either of these
positions.
Role of the Market System and Market Failure
Historically, the United States has relied primarily on the market
system to allocate resources and thereby to determine the rate and
pattern of natural resource extraction, product manufacture, and
consumption. This free-market system has been tremendously produc-
tive and extremely efficient in satisfying the private wants of American
consumers. The market operates on the basis of the profit incentive,
and relies on a complex and decentralized system of market prices and
competitive market checks and balances. These market incentives
create strong motivating forces for technological and commercial
innovation in material extraction and processing, material applications,
product designs, and in the marketing and distribution of products.
The market also facilitates maximum individual freedom of choice.
* Recovery includes any of the following: (1) materials recycling
or returning a waste material into a similar raw material form, such as
newsprint from old newspapers or aluminum alloy from beverage
containers; (2) conversion of a waste into a new material or a different
form, such as compost from wastepaper or road surfacing aggregates from
glass or rubber; and (3) energy recovery or conversion of organic waste
into steam or a substitute for fossil fuel. Waste reduction (or
prevention) includes: (1) changing product designs; (2) altering
consumer purchasing, waste generation, and disposal patterns in order
to reduce the material requirements per unit of product or service; (3)
increasing product lifetime; (4) substituting reusable products and
containers for disposable or single-use items; (5) reducing consumption
of a particular product or material.
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Nonetheless, most students of the economy would agree that a
laissez-faire marketplace may fail to ensure optimal social welfare.
Numerous problems such as pollution and congestion phenomena,
common-property resources, monopoly, etc. may cause the market to be
inefficient. These problems are quite significant in a complex,
metropolitan, highly inter-dependent society such as the United States.
Most students of the economy would also agree that a proper—and
indeed essential--role of government is to ensure that these barriers to
an efficient marketplace are corrected.
From an environmental protection and material conservation per-
spective, the major concern here would appear to be whether or not the
prices of all goods and services include the full social costs of pro-
duction, including the full costs of waste management and environmental
degradation associated with them. To the extent that prices do not
reflect all of these costs, there is an implicit subsidy or stimulus to
greater production and use of the materials and products than is
justified. This produces an anti-conservation bias in the market. The
result is an increased flow of materials as well as a failure to allocate
adequate resources to pollution control, waste reduction, and resource
recovery activities.
Until quite recently, the American economic and political systems
exhibited a general disregard for environmental degradation. This was
equally true for the mining and processing industries and municipal
solid waste disposal. With respect to the former, environmental damage
costs were borne mainly by society in general or by "third parties"
rather than by the specific industry and its customers whose joint
economic decisions gave rise to the environmental damage. For this
reason, market prices for materials failed historically, and in large part
still fail, to measure the full social costs of production and use, thus
providing inaccurate price signals for allocating resources.
At the other end of the material flow sequence, post-consumer
solid waste residuals have also created "external" environmental damage
costs in the form of aesthetic blight, air pollution, and groundwater
contamination. These have not been accounted for in community solid
waste management budgets, nor have they been reflected back to waste
generators as an inherent part of the total "life cycle" cost of using and
disposing of material goods. This is another example of an implicit
subsidy for increased material consumption.
Of equal or greater significance, however, than the environmental
costs of post-consumer waste disposal is the fact that three-fourths of
U.S. communities finance their total solid waste management systems out
of general tax revenues (mainly property taxes) rather than through
user fees. This means that most households, and many commercial
enterprises as well, never see a specific bill or charge of any kind for
this service, as they do, for example, for electricity or other public
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utility services. Of the cities that do employ disposal fees (user
charges) to finance solid waste services, most charge lump-sum amounts
regardless of quantities handled.
Such practices, involving the undercosting or the non-charging of
the total economic costs, make the service appear costless to those
utilizing them, and has the overall effect of minimizing or negating any
possible economic incentive towards reducing waste generation on the
part of producers and consumers or encouraging private resource
recovery options. (This problem is significant since EPA estimates
national average waste collection and disposal services cost about $30
per ton.)
Market failures or imperfections of this type have long been recog-
nized by economists. The issue here is not whether the free enterprise
system in general is an efficient mechanism for allocating resources.
Rather, it is whether, in the particular cases of environmental pollution
and post-consumer waste material flows, the free market is adequately
structured to produce and transmit the most appropriate price signals
to the demand and supply sides of the markets. It is by no means clear
that present policy approaches adequately address these issues in an
efficient or equitable fashion, and this will be a matter for study by the
Committee.
Past Public Policy Distortions
Even beyond the market failures noted above, EPA and others
have concluded that a number of historical practices and policies of
government have inadvertently tended to distort the economy further in
the direction of greater material flows, more pollution, increased solid
waste disposal problems, and a less efficient overall use of our natural
material and energy resources than the market system would otherwise
have produced.
These distortions range from certain elements of Federal tax policy
to aspects of municipal solid waste management accounting practices.
Federal tax subsidies to virgin materials, including percentage depletion
allowances for mineral extraction and capital gains treatment of timber
harvesting, and direct subsidization of mineral and agricultural
research and development have historically reinforced the tendency
towards inexpensive virgin raw materials. It is argued that this
encourages more material and energy use and attendant environmental
problems than would have occurred under a more conservation-oriented
(neutral) public tax or investment policy.
Another set of issues can be raised concerning local government
accounting practices which appear often to understate the full costs of
solid waste services. For example, municipal and county solid waste
accounting systems often segregate land and equipment costs in
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separate capital accounts from the waste collection and disposal
function. Thus, interest and amortization costs may not be included in
the solid waste budget. A second factor is that foregone property tax
revenues from processing and disposal sites are not counted as a
community cost attributable to the waste management function. In
addition, public land and equipment purchases in the solid waste field
are typically financed by low-interest, tax-free public sector bonds
(the differential interest rate subsidy being paid by other taxpayers in
higher Federal taxes).
All of these accounting and budgeting factors contribute to making
local solid waste services appear less costly than they really are. This,
in turn, leads to inadequate incentives to the local decision makers to
explore and develop resource recovery alternatives to disposal.
A full evaluation of these and other possible distortions of the
economy introduced by governmental policy will constitute an important
part of the Committee's work.
Changes in National Objectives and Philosophies
It is quite possible that the national mood is changing to favor a
more conservationist attitude toward the use of natural resources and
the environment. Much has been written about the conservation ethic,
and "environmentalists" and "conservationists" are listened to much
more attentively today than in times past.
What may be happening is that natural resource conservation and
environmental protection are in a real sense becoming objectives in
themselves. In the economist's jargon, natural resources and the
environment may be assuming the status of "consumption goods" to be
valued for their own sake rather than merely as productive assets or
means to the ends of other consumption goals. This would imply that
conservation and environmental protection measures would have a social
value, in and of themselves, over and above any other value
attributable to improvements in economic efficiency more conventionally
defined. What such a value might be could presumably not be
determined by conventional techniques of economic benefit analysis.
Because such "consumption" values are, by definition, philosophical or
psychic, they must be determined through some means of public
preference rating or polling to determine our collective willingness to
pay the economic costs of conservation over and above what can
otherwise be justified.
The Resource Conservation Committee is not ready at this time to
accept the principle that conservation for conservation's sake should be
the major basis for policy formulation. Increased resource conservation
and environmental protection will inherently involve economic costs in
terms of other recognized consumption and investment wants that would
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have to be sacrificed. In addition, they may well involve disruptions
for many industries, regions, and economic groups. For these reasons,
economic cost and equity criteria must still be applied in these areas.
Nevertheless, the Committee recognizes the increasing importance of
conservation and environmental ethics. The Committee will solicit
through its Public Participation activities advice on what role these
values should play in the Committee's overall work.
PRINCIPLES, GUIDELINES, AND CRITERIA FOR POLICY-MAKING
There are a number of basic principles, criteria, or general social
values that might serve as guidelines in formulating public policies for
resource conservation. The Committee feels it essential in this initial
report to make explicit, as a general statement of philosophy, those
principles and values that it considers most important both in assessing
resource conservation and recovery policies and in recommending
alternatives that will be in the greatest public interest. Without
attempting to rank these criteria in order of relative importance and
recognizing that these criteria will frequently be in conflict, the
Committee proposes to follow the principles listed below throughout its
work.
1.	Free-market principles. To the maximum feasible extent,
conservation policies should not interfere with the free choice of
producers, consumers, and local governments to make decisions in
a decentralized fashion. This criterion is consistent with the
broader democratic philosophy of freedom of choice and also
represents our basic faith in the private market system as the
primary mechanism for allocating society's resources. Adherence
to this principle does not imply a blind faith in the status quo,
however. Certain shortcomings in market structure (e.g.,
monopoly) and the absence of effective private market mechanisms
to provide for certain public goods (e.g.} environmental amenities)
allow a valid corrective role for government consistent with,
indeed essential to, the efficient and equitable functioning of the
competitive private enterprise system.
2.	The "polluter-pays" principle. In simplest terms, the polluter-
pays principle means that whoever is responsible for pollution
(environmental damages) should be charged the costs of
preventing, controlling, or correcting these damages. Although
there are exceptions to any rule, this principle states that
pollution costs should neither be subsidized by taxpayers in
general nor borne directly by those exposed to the pollution.
For pollution related to industries or products, it should be
emphasized that the concept of "polluter" refers not only to the
industry in question but also to the particular consumers of that
13

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industry's products as well. In effect, the "polluter-pays"
principle means that those producing and consuming pollution-
associated products pay. It is unlikely that pollution control costs
assessed on the producer will be totally or even largely absorbed
out of "excess profits." Under some market conditions, such costs
will to a substantial extent be passed along to consumers of these
products. In the long-run the extent of the pass-through will
depend upon the availability of less-wasteful products and less-
polluting technologies and the actual value placed on that product
by the consumer.
The basic proposition that the polluter should pay has been
enunciated in some detail by the Organization for Economic
Cooperation and Development (OECD) and accepted as a basic
principle of pollution control by all OECD nations including the
United States. OECD adopted this concept to ensure equitable
international trade policy in a period when pollution control costs
are becoming an increasingly significant part of total product
price.
According to most environmental economists, the principle that the
polluter should pay (rather than society in general) is consistent
with the general precepts of efficient pollution control. It also
establishes a fundamental precept of equity by asserting that those
responsible for activities giving rise to pollution do not possess
inherent property rights to freely use the environment as a waste
disposal medium.
3. Social and economic equity. Implementation of any significant new
policy will, if effective, engender changes. Often such changes
will be more beneficial to some groups than to others. The short-
term consequences of a specific conservation policy might be that
specific industries, labor groups, and geographical regions of the
nation would experience "windfall" gains and/or losses. For
example, some consumer groups may find their living costs rising
much more rapidly than others. In the longer-term, major shifts
in economic opportunities may occur.
Such questions relate to the distribution of costs and benefits (as
opposed to their total magnitudes). Often equity issues are the
major features which determine whether a specific proposal will be
accepted or rejected. For example, any scheme that is seriously
regressive—that is, that imposes a disproportionate burden on the
poor—is unlikely to receive serious consideration. The purpose of
emphasizing this criterion is not to argiie against change. Change
is necessary and essential if progress in conserving resources and
in improving the efficiency with which materials are used is to
occur. Rather, the issue is that in developing, evaluating, and
recommending conservation policies, it is essential that the
14

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Committee consider how the interests of various groups will be
affected. If serious equity problems appear with a specific
proposal, efforts can be made to minimize or reduce these problems
by redesigning the policy. For example, the introduction of the
policy could be stretched out over a period of time to reduce any
transitional dislocation problems. Alternatively, certain groups
could be exempted from the requirements. In still other cases,
society might compensate groups negatively affected by the policy
directly or might impose special taxes on groups enjoying unearned
windfall profits.
4.	Economic efficiency. In broadest terms, economic efficiency may
be defined as the situation in which society gets the most of those
goods, services and environmental benefit it desires within the
constraints of existing resources and technology. Developing
efficient policies requires that one compare total social benefits
with total social costs to ensure that society does not sacrifice
more goods and services than are justified by the benefits of the
policy.
Concern with economic efficiency is essential, since the
benefit/cost framework requires explicit attention to the question of
whether a particular policy proposal can improve the general economic
welfare of society as a whole. So long as resource recovery and other
conservation approaches involve reallocation of economic resources from
other industries or products, there will be costs as well as benefits,
and both require evaluation, according to the principle of economic
efficiency.
5.	Administrative feasibility and cost. Policies should ideally be
simple enough to be understood by parties involved in
implementation and compliance. A conservation policy should not
require information or data that cannot be acquired at reasonable
cost. From a practical viewpoint, the total cost of administration
and enforcement for both public administrative agencies and
private parties should be small compared to the benefits derived.
The Committee will explicitly assess these administrative costs for
any policy proposal considered.
APPROACH TO POLICY DEVELOPMENT AND EVALUATION
The principles outlined above are insufficient in themselves to
provide unambiguous policy direction. Often, analysis highlights the
fact that one principle or impact must be traded off against another.
Policy development, evaluation, and selection is a complicated and
delicate process involving a blend of philosophical principles, economic
theory, and quantitative assessments of the proposed measures. The
Committee recognizes that quantitative estimates often tend to dominate
15

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and obscure other selection criteria and therefore will endeavor to
insure that principles and theory receive due consideration.
Ultimately, political values and processes will play the deciding role.
Recognizing the difficulties involved in policy development, the
Committee proposes the following approach:
1.	Build on Previous Interagency Work. To ensure relevance and
encourage knowledgeable debate, the Committee intends to build on
previous interagency work on materials policy issues, such as the
final report prepared by the National Commission on Supplies and
Shortages and the forthcoming report by the Treasury Department
on recycling incentives.
2.	Design Specific Policies. Policy reports frequently suffer because
they discuss policy alternatives at a level that is too abstract. At
a relatively early stage in the evaluation of each policy area,
specific and detailed proposals need to be designed before any
substantive quantitative analysis or public review process can
begin. Indeed, grappling with detailed design issues is, in itself,
a major aspect of policy development. Much of the effort of the
Committee will go into this proposal design effort.
3.	Utilize Quantitative Analysis Methods. Although the Committee
has few illusions about the degree of quantitative accuracy
possible with existing methods and data, it still intends to evaluate
alternative policy proposals using cost-benefit or other quantita-
tive procedures wherever practical. To achieve this, the
Committee may devote resources to developing and improving the
existing data base as well as to improving current estimating
procedures. The intent is to ensure that the decisions of the
Resource Conservation Committee are made in as logical and
accurate a fashion as practicable.
A wide range of alternative policy proposals will be evaluated.
Conservation proposals will be evaluated to determine whether they
will improve the efficiency of the overall allocation of resources.
Attempts will also be made to measure the distributional aspects.
The Committee will attempt to estimate for recycling the specific
effects on the cost of materials, on the quantities of waste
generated and disposed, on materials and energy requirements,
and on environmental variables.
Measures of other areas of benefit or cost impacts such as labor
impacts, regional economics, international trade, administrative cost,
and enforceability, will need to be refined or developed during the
course of the Committee's work.
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The Committee recognizes that the state of the art of assessing the
economic value of environmental and conservation benefits is not
well developed. As a result, certain benefits of conservation may
have to be stated in physical rather than economic or market-value
terms.
4.	Emphasize Gradual Transition and Implementation Features. To
mitigate the limitations and uncertainties noted above, the design
of a policy should provide for adequate monitoring, feedback, and
subsequent corrective adjustments. Where dislocations are a
problem, policies should also be designed to be phased in over time
so that changes will occur less abruptly, allowing affected groups
better opportunity for adjustment.
5.	Encourage Public Participation and Review. Participation and
debate by public and private interest groups will be provided for
and encouraged throughout the study period. Reactions,
comments, and suggestions will be used to revise the policies and
will be reported along with the Committee's findings, conclusions,
and recommendations.
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I\#
1 W HID
THE
SUP
1
PLAN
(nil tn*638B	WWl
This section describes the overall scope of the study effort and
the plans for conducting the activities of the Committee.
RANGE OF POLICIES TO BE REVIEWED
The Act specifies that the Committee should consider a broad
range of conservation policies including: (1) new incentives or
disincentives, (2) modifying or eliminating the effects of existing fiscal
and regulatory policies, and (3) possible regulations restricting the
manufacture or use of products. A more detailed listing follows:
1.	Incentives and Disincentives for Recycling and Conservation.
A.	Charges—particularly the proposal to place solid waste
management charges on consumer products.
B.	Subsidies—investment subsidies, operating subsidies.
C.	Deposits and bounty mechanisms.
2.	Effects of Modifying Existing Public Policies.
A.	Percentage depletion allowances for minerals.
B.	Capital gains treatment of timber.
C.	Severance taxes.
D.	Freight rates and regulations.
E.	Government-supported research and development.
F.	Pollution control regulatory programs.
G.	Federal tax treatment of pollution control investments
(e.g., pollution control revenue bonds).
18

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3. Product Regulations as a Conservation Tool.
A.	Recycled material content specifications.
B.	Product durability standards.
C.	Bans on use of hazardous materials.
D.	Product design requirements.
E.	Material rationing schemes.
These represent the specific policy issues noted in Section 8002(j),
paragraphs (1)(A) through (1)(D) of the law; paragraph (1)(E)
specifies that the Committee shall also report on the need for further
research, development, and demonstration in the area of resource
conservation. This present report does not provide a separate study
plan; this will be considered as an inherent aspect of the work
throughout, and will be reported on in the interim and final reports.
COMMITTEE WORK PLAN
The activities of the Committee Staff are organized into four
distinct but interrelated areas: Policy Development and Coordination;
Support Studies; Public Participation; and Administration. The
responsibilities associated with each activity and the respective
implementation plans are described below.
Policy Development and Coordination Plan
Policy Development and Coordination includes: identifying specific
policy areas for review, developing a range of detailed proposals for
each general policy area, and interacting with the Support Studies and
Public Participation groups to ensure that each proposal is adequately
assessed and reviewed (Figure 1). At each iteration, the results of this
process would be reviewed by staff representatives of all participating
agencies. The findings of this process for each policy area will be
synthesized in a final policy guidance report.
Considerable effort is required to translate a general policy into a
practical design proposal. Yet this detailing is essential so that the
proposal can be quantitatively evaluated and receive meaningful public
review. For example, EPA spent almost one year in translating the
principle that "the costs of solid waste management should be
internalized in the prices of products" into the specific policy design
reported upon in its Fourth Report to Congress. Such design questions
as how high the charge should be, where the charge should be
19

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collected, which product categories should be included and excluded—
all needed to be "fleshed-out" before any meaningful analysis or public
review could begin.
SUPPORT STUDIES
POLICY DEVELOPMENT AND COORDINATION
Review design,
revise if necessary
Develop specific
impact questions
Broad
Policies
Review design,
revise if necessary
Develop eAjcational
and review material
Reactions
Presentations
PUBLIC PARTICIPATION
Figure 1. The Resource Conservation Committee will develop specific proposals
through the interaction of three functions: (1) policy design, (2) support studies to
evaluate impacts, and (3) public participation.
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There are many possible proposals in each policy area. For
example, several subsidy and charge proposals have been suggested to
increase recycling. Similarly there are a large number of possible
product regulations that might conserve resources. The Committee's
overall plan is to consider each of the policy areas sequentially, develop
a series of detailed proposals representing the range of possible
options, and then subject these specified options to analysis and public
review. Based on the results and interactions among agency
representatives, the initial proposals may be revised several times to
improve their individual design features. The interagency and public
review processes will provide some guarantee that no important concept
is neglected and that each initiative is fully specified and evaluated.
The Policy Coordination staff will request assessments--e.g., what
is the administrative cost or impact on materials use and other cost and
benefit measures--of the various proposals from the Support Studies
program and re-evaluate each proposal based on the reported results.
Similarly, the Policy Coordination staff will request that the Public
Participation group inform the relevant interest groups of each option,
determine their views on the current design, and revise the proposal
based on this information.
This development work will be iterative, involving as it does
repeated revision of each proposal. This work will involve the difficult
process of concurrently considering efficiency and equity objectives,
effectiveness, design principles, political feasibility, and practicality.
This process of translating a concept into a viable proposal is a very
difficult area. The Committee intends to accomplish this task by con-
ducting interviews, attending workshops, evaluating reports, modeling
impacts and supervising and reviewing contract studies and public
reviews, as needed. Results will be published for critical review and
comment.
In principle, this activity could converge toward a proposal
reflecting a consensus of the Committee. The plan is to approximate
this goal within the mandated reporting schedule. The resulting
alternatives and the extent of agreement will be summarized in periodic
reports to Congress. These reports will summarize not only all the
relevant results of the Support Studies function, but also the
expressions of opinion from all review groups. If subsequent criticisms
emerge, then additional work on that policy area may be necessary.
Support Studies Plan
The Support Studies activity, involving both contract and grant
studies as well as staff analyses, will identify, develop, and carry out
numerous technical studies. The work falls under the three broad cate-
gories of background surveys, policy impact analysis, and quantitative
methods development.
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Background Surveys. These consist of a series of studies
designed to provide background information or state-of-the-art reviews
for a number of specified policy and problem areas. The reviews will
aid in defining the longer term study needs of the Committee and will
serve as briefing documents for interagency staff representatives.
They involve preparation of annotated bibliographies, synthesis of data
and conclusions, and recommendations on the value and scope of further
work in the respective fields.
Many of these studies are now under way, utilizing previously
committed Fiscal Year 1977 funds of the Environmental Protection
Agency, and some will have been completed by the time this first report
is submitted. Thus far, such studies have been planned in the
following areas:
State of the art in modelling industry response to incentive
policies.
A review and evaluation of existing user-charge approaches
for solid waste management and other public services.
Problems and policies relating to littering.
The potential value of extending the deposit or refund
concept beyond the beverage container application.
State-of-the-art modelling for evaluation of impacts on
industrial employment.
Survey of income distribution impacts of environmental and
conservation policies.
Others will be initiated as the needs of the Committee dictate. The
background studies will require a small but essential part of the total
contract budget for the Committee.
Policy Impact Analyses. This second major area of Support
Studies comprises a series of economic, environmental, and resource
impact assessments of specific policy design options.
The purpose is to serve the needs of the Policy Development group
for quantitative assessments, estimates, or projections relating to such
areas as:
Basic industry and market responses to alternative incentive
policies, including changes in output, recycling, raw material
use, market prices, industry sales and investment.
22

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Broader regional, national, and international economic
impacts, such as (but not limited to) shifts in income
distribution, effects on consumers, and international trade
implications.
Regional and national employment impacts, such as as shifts
in total jobs, skill mix, or job locations.
Comparative environmental effects, including total system
changes in effluent and emission levels as well as post-
consumer solid waste.
Expected changes in virgin raw material and energy
requirements.
These analyses must utilize whatever estimating techniques and
data are available now or that can be acquired in the very near future.
Existing data and procedures in many of these fields are quite primitive
compared to the desired outputs from this effort. Nevertheless,
techniques are available and will be applied with understanding of their
limitations.
The impact studies will be closely integrated with the Policy
Development work. The sequence of policy areas to be evaluated will
thus parallel that of the policy design and reporting schedule.
Most of these analyses will be specified in detail by this summer as
the actual policy design work progresses. Policy impact work will
accelerate throughout the summer, depending on the availability of staff
and funding. The work will be performed partly by Support Studies
staff and partly under level-of-effort contracts. By reprogramming
Fiscal Year 1977 funds, it was possible to write a limited amount of this
type of work into existing EPA contracts. Considerable additional work
will be required, since this activity will be of highest priority.
Improving Quantitative Assessment Methods. This area involves
the adaptation, improvement or development of analytical tools and
techniques for performing quantitative impact estimates and analyses of
policy options. Such tools and associated data requirements are
available at various levels of depth, sophistication, and relevance for
most of the estimating needs presently foreseen. These needs include
estimates of the industrial or market responses to alternative policies
and, given these, estimates of the economic, conservation, and
environmental effects of the industrial changes.
This is a very complicated set of analytical requirements in an area
of admittedly imperfect tools and data. EPA has been working in this
area for some time and fully appreciates the difficulties involved in any
23

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attempt to enhance the state of the art. Essentially the dilemma may be
stated as follows. On the one hand, it is necessary to provide specific
quantitative estimates early in the course of the study, despite the fact
that with current procedures they must be imperfect. On the other
hand, the Committee shares the opinion expressed by the National
Commission on Supplies and Shortages that the ability to predict the
response of the market to governmental policies should be improved. In
the longer run, improved models are essential for making better
quantitative estimates and projections. However, such a development
effort is a highly speculative endeavor, requiring substantial
professional resources, and may not yield substantive payoff within the
time period of the Committee's mandate.
Faced with this problem, the Committee1s "tool-development plan"
has both a short-term and a long-term component.
The short-term component, with portions scheduled for completion
within the next 4 to 8 months, includes extensions and improvements on
recent EPA and other agency contract and in-house work. This
includes developing response models of the basic material industries--
paper, steel, glass, aluminum, and plastics. Other industries may also
be included as the work progresses, including basic raw-material
sectors and final-product industries. These models will provide
estimates of industry changes in inputs (secondary vs. virgin
material), product outputs, and prices in response to various disposal
charge and recycling subsidy measures. Another series of models or
methods will be used for estimating the impacts of industry changes on
such areas as environmental emissions and energy use, the income
distribution impacts of price changes, the inflationary impact of various
policies, the employment impact, and certain other inter-industry or
macro-economic repercussions.
During this short-term phase of tool-development, the work will
focus on completing existing projects, assuring that the different
estimating procedures are consistent with one another, and adapting
other existing analytic methods to the range of conservation proposals
being considered.
Longer term programs involve synthesizing the available work for
all major industries and major policy impacts and designing new
procedures to extend the state of the art in this field beyond present
levels. Though this work is somewhat speculative in terms of providing
major advances in capabilities that will match the time requirements of
this Act, the Committee recommends that it be initiated. The Committee
recognizes the long-term importance of improved modelling capabilities
for future environmental and conservation policy analysis. The Support
Studies plan therefore includes a work scope and a budget for this
activity.
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Public Participation Plan
Public participation in the Committee's activities will involve two
activities: public education and public review. Public education
programs will alert the public to the importance and role of resource
conservation, and inform them of the activities of the Resource
Conservation Committee.
The public review activity is intended to encourage members of the
public to participate in the policy development and implementation
activities of the Committee. This public involvement will ensure that
the Committee remains aware of the many diverse viewpoints on
conservation policy questions throughout its work.
The public participation plan calls for these objectives to be
achieved through various activities including public discussions and
meetings, grants for public education programs to public interest
groups, and seminars and presentations to private interest groups.
Public Meetings will be coordinated with preparation of the Com-
mittee reports to Congress so that public comments and reactions can be
incorporated into the reports. A meeting on the general subject of
resource conservation was held March 7, 1977. A second meeting,
focusing specifically on the Committee's Implementation Plan, was held
April 6. Transcripts of these meetings are available. Other public
meetings are tentatively scheduled for August 1977, February 1978} and
August 1978.
These meetings will serve the dual purpose of keeping the public
informed of the progress and plans of the Committee and of gaining
insight into the reactions of the public to the plans and activities of the
Committee. Meetings will be formally transcribed and may also be
recorded on audio or video tape.
Grants will be considered for public interest groups, where need
is evident or where grants offer a cost-effective way of ensuring public
education and review. The grant process will allow representatives
from each interest group to become familiar with the issues and policies
being developed by the Committee, to communicate this information to
their respective constituencies, and to report the reactions of their
constituencies back to the Committee.
These grants will generally be relatively small, but should provide
adequate funding for staff, printing and mailing expenses. The
grantees will be required to assign specific staff to work with the
Resource Conservation Committee. Each grantee will:
(1) Review all background information and become familiar with
the activities and issues being considered.
25

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(2)	Communicate this information to the members of their
respective constituencies through such means as newsletters,
pamphlets and meetings.
(3)	Solicit and synthesize the reactions, comments, and sug-
gestions of their constituencies.
(4)	Compile and report this information to the Committee.
The grantees could include groups representing environmental,
consumer, State and local governments, labor and industry. The list
may include such organizations as the International City Management
Association, League of Women Voters, American Public Works Associa-
tion, Environmental Action Foundation, National Wildlife Federation,
National Association of Counties, National Governor's Conference, the
AFL-CIO, and the Chamber of Commerce.
Other unscheduled but anticipated public participation activities
will be expected of the Committee staff. The staff will prepare and
present information on the work of the Committee through papers,
articles, and by participating in meetings and conferences.
In addition to the above activities, the Committee staff will be
available for informal periodic consultation to ensure substantive
participation by those groups and individuals interested in the
Committee's activities.
Administrative Activities
A significant portion of Committee staff time will be devoted to
administrative functions such as scheduling Committee meetings, compil-
ing the minutes of these meetings, procuring and managing grants and
contracts, and hiring and coordinating staff.
REPORTS AND SCHEDULE
The Act requires that this Study Design be submitted to Congress
by April 1977, and that three subsequent reports follow at 6-month
intervals, i.e., October 1977, April 1978, and October 1978, This plan
calls for all staffing and contracting activities to be completed by this
summer, and for the reassignment of staff to begin by August 1978.
Since the findings of the Committee are potentially very important,
the opportunity for wide public discussion of the various conservation
policies should be provided as soon as possible during the two-year
study period. To ensure this, the October 1977 and April 1978 reports
are designed to provide substantive data and any conclusions reached
26

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by the Committee on the major conservation policy areas. These
substantive reports will serve to focus discussion and stimulate broad
intensive review. The final report in October 1978 will review these
criticisms, revise the previous reports as necessary, and provide final
Committee recommendations.
Since recycling incentive policies have been extensively reviewed
by EPA over the last several years and inasmuch as a forthcoming
report by Treasury will review this same topic, it would be practical
and timely to summarize this work in the October 1977 report. Thus,
this first report will include recycling incentives and a comparison of
waste disposal charges and subsidies. The April 1978 report would
consider other conservation policies.
Data and computations from the Support Studies on the recycling
incentives topic will be submitted to the Committee staff by July 31,
1977. The first draft of the Recycling Incentives Report will be
distributed by the Resource Conservation Committee staff to agency
staffs by August 20, 1977, for their review and comments. A public
review meeting will be scheduled at this same time. These reports will
be reviewed concurrently by all Committee members. This is necessary
given the severe time constraints faced by the Committee. The final
staff report incorporating review comments will be submitted for
concurrence or exception by the Committee by September 20, 1977.
The April 1978 report will cover the remaining policy areas
(existing public policies, product regulations, deposits and bounties),
laying out the issues and policy instruments to ensure full discussion
and debate by all parties. Data and computations from support studies
pertinent to these policy topics should be completed by December 10,
1977.	A first draft of the report will be distributed to EPA and the
other agency staffs by January 15, 1978, with a public review meeting in
early February. The final staff report, incorporating review comments,
will be submitted for Committee concurrence or exception by March 1,
1978.
The final committee report, due in October 1978, will review the
previous reports and address any new policies or subjects raised during
the review period. Any final quantitative studies and comments from
interested parties will be included, but the focus will be on final
recommended alternatives to Congress. The closing date for comments
on the previously distributed (draft final) reports (October 1977 and
April 1978) will be June 20, 1978; and final quantitative studies and
comments will also be due by this date. A draft of the final report
should be completed for distribution by July 31, 1978. The public
review meeting will be held in August 1978. The final report
incorporating review comments will be submitted for Committee member
concurrence or exception by September 20, 1978.
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Formal meetings of the Resource Conservation Committee will be
coordinated with this schedule. At minimum, three meetings are
scheduled during the review process for the remaining three reports to
Congress, with approximate dates during August 1977, February 1978,
and August 1978.
A time-line display of this reporting schedule follows:
FIGURE 2
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28

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BUDGET
AND
STAFFING
This plan describes a proposed level of effort that will require approximately
$2 million and a staff of 25 over the 2-year study period. This is consistent with
Congress1 authorized limit of $2 million for this section of the Act. However, the
actual funding level is uncertain at this writing. The current resource commitment
of the Environmental Protection Agency is far below this level, and commitments
from other Committee members have not yet been decided. As soon as the actual
funding and staff level are determined, the Committee will decide how these are to
be allocated among the various policy areas, support studies, and public partici-
pation programs discussed in the report. These decisions will be reported to the
President and Congress at that time.
29

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REFERENCES
President's Materials Policy Commission. Resources for
Freedom; a report to the President. Washington,
U.S. Government Printing Office, June 1952. v. 1
National Commission on Materials Policy. Material
Needs and the Environment; Today and Tommorrow.
Final Report. Washington, U.S. Government
Printing Office, June 1973.
U.S. Senate Committee on Public Works. Solid Waste
Utilization Act of 1976. Report No. 94-988.
Report of the Committee together with individual
views to accompany S. 3622. Washington, U.S.
Government Printing Office. 1976.
U.S. Environmental Protection Agency, Office of Solid
Waste. Fourth Report to Congress; Resource
Recovery and Waste Reduction. Environmental
Protection SW-600. Washington, U.S. Government
Printing Office, 1977.
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APPENDIX
PUBLIC COMMENTS ON THE DRAFT IMPLEMENTATION PLAN
FOR THE RESOURCE CONSERVATION COMMITTEE
As the initial element of the Committee staff's plan to
involve the general public in the work of the Committee,
copies of an earlier draft of this report were distributed
to over 300 individuals and organizations known to have a
professional, occupational, business, or public interest
responsibility in the Committee's workscope. The cover
letter gave notice of a public meeting to be held for
purposes of discussing the implementation plan and also
invited written comments to be submitted for the public
record and publication as part of this first report.
The public meeting was held at EPA Headquarters in
Washington, D.C. on Wednesday, April 6, 1977. Forty-one
persons attended, representing thirty-eight organizations
covering a broad spectrum of industrial, governmental, and
conservationist interests. The meeting was structured both
for the Committee staff to answer questions and clarify
positions expressed in the Draft Report and to receive
public comments, which will be transcribed for the public
record. This record, together with written comments will be
used to guide the Committee in carrying out its study programs.
Written statements by the Committee through April 15
are included in this Appendix, in alphabetical order, as
follows:
Organization
American Can Company — P.R. Payne	33
American Iron and Steel Institute — S.G. Fletcher	36
American Paper Institute — Richard J. Wiechmann	38
Can Manufacturers Institute — John M. Dunn	40
Dawson, Riddell, Taylor, Davis & Holroyd —	42
James W. Riddell
Ducks Unlimited, Inc. — Dale E. Whitesell	45
Energy Research and Development Administration —	47
W.H. Pennington
Environmental Action Foundation — Marchant Wentworth 48
Glass Packaging Institute — William W. Sadd	59
Grossman, Robert E.	67
Institute of Scrap Iron and Steel, Inc. —
Herschel Cutler
31

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(continued)	Page
Knox, Ellen	69
League of Women Voters of Arkansas — Lois Imhoff	70
National Association of Recycling Industries, Inc.	— 73
M.J. Mighdoll
National Association of Recycling Industries, Inc.	— 74
Edward L. Murry
National Commission on Supplies and Shortages —	77
George C. Eads
National Solid Waste Management Association —	79
Michael F. Hill
National Wildlife Federation — Thomas L. Kimball	81
PAK-CENT — Frank M. McManus	83
Sierra Club-Angeles Chapter — Fredrika E. Bernstein	86
32

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Peter R. Payne
Director, Legislative Affairs
Corporate Public Affairs
American Can Company
American Lane
Greenwich, Connecticut 06830
April 11, 1977
Dr. Sheldon Meyers
Deputy Assistant Administrator for Solid Waste
U. S. Environmental Protection Agency
Washington, D. C.	20460
Dear Dr. Meyers:
Thank you for your March 22, 1977 letter to me so-
liciting American Can Company's comments on the March 24,
1977 draft implementation plan for the Resource
Conservation Committee. I am taking the liberty of
copying other departments who have representation on this
Committee so that they may share directly in our comments
and suggestions. We feel our comments below are objective
and constructive and sincerely hope that you will examine
them in that climate.
The overall issue of materials planning, resource
conservation, internalization of costs (call it what you
want) will have far-reaching effects on national economic
policy planning and our very way of life. The issue is
immense. All parties involved in this study must recognize
the responsibility with which they have been charged, and
the absolute necessity of policy recommendation only after;
1.	A complete data base has been established;
and
2.	A full exploration of alternatives has been
completed.
To accept anything less than this objective would not
be in the national interest.
33

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Page Two
It is important to repeat here that Section 8002 (j)
(1) of the RCRA charges that Committee to "conduct a full
and complete investigation and study of all aspects of the
economics, social and environmental consequences of resource
conservation with respect to 	Section 8002 (j)
(3) includes timetables for the study design and completion
of the study which study "shall include at least two alter-
natives to the proposed recommendation."
The March 24 Draft Implementation appears to concentrate
too much on specific policy recommendations by the EPA and
too little on social and economic values, which should be
the major contribution of other agencies. We must strive for
the ideal balance of all values.
Congress has mandated a study design by April 21, 1977.
They did not request a broad based policy recommendation
such as the March 22 draft — especially one that has not
yet been impacted by the other agencies or the private
sector.
In the short time before April 21, we respectfully
request that the full Committee revise the March 22 draft so
it will truly be a study design and not a policy proposal
which was completed before commencement of quantitative
analysis. The first Section of the Plan (pp 4-12) sets the
principles and guidelines under which the Committee will
function; the next Section then effectively discards the
principles by recommending five operating techniques for the
staff.
The draft concentrates on a narrow range of resources
and their uses and does not appear ready to consider scarcity
or social value.
Scarcity of a material can be directly related to an
economic, social, and environmental value that goes beyond
an arbitrary product change. This type of thinking must go
into the study preparation before narrow-based regulation is
artificially inserted into our free market. As a manufacturer
of packaging good, utilizing a wide-range of raw material
sources, we are concerned that our industry is signaled out
as a special target group encouraged in no small measure by
many already existing or soon to be released EPA- studies.
One important ingredient of this study should be its impar-
tiality and its ability to identify where material conservation
is needed and feasible.
The draft does not provide enough mechanisms for
private sector participation in the study design. Public
meetings satisfy the demand of the law but not the intent of
the law. Industry, key public interest groups, and others
cannot be effective participants if limited to input only at
public hearings.
34

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Page Three
When you spoke before the NAM Environmental Quality
Meeting last month, you solicited cooperation from industry.
We have many specific suggestions and talents that will
insure a broad and reasonable amount of participation in
the studies. We stand ready to volunteer those ideas and
services.
Throughout the Draft Implementation study we perceive
the recognized necessity for new and comprehensive data.
To rely heavily on the scope and conclusions of previous
reports or studies would not be in the national interest.
Two years with progress reports, as indicated, is an
appropriate length of time for a subject of this importance.
We urge you to steadfastly resist pressure from CEQ and
perhaps other groups to telescope the study completion date
to six (6) months. This effort appears to us as an ill-
conceived tactic to adopt into national policy previous
conclusions or policies that cannot be widely supported
on their merits. We urge you to continue to adhere to
and accept the time frame intended by Congress.
In conclusion -
The intent of Congress under 8002 (j) is clear - to
inform itself on the social, economic, and environmental
consequences of resource conservation through the medium
of a two-year interagency study which is to address five
issues and make recommendations on alternative policies.
The implication is that Congress wants the benefit of a
comprehensive study before further consideration of product
restriction legislation.
Because of the potential consequences, or benefits,
of such legislation on all of us. American Can Company
stands ready to assist the appointed Resource Conservation
Committee in any way that seems most appropriate.
Thank you for your consideration.
Sincerely yours
PRP:jer
cc: (Please see distribution
list)
NOTE: List is not included
35

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*3%>ee/,
» C/ f 6 .
STEWART G. FLETCHER
SENIOR VICE PRESIDENT
-April 11 , 1977
Mr. Sheldon Meyers
Deputy Assistant Administrator
for Solid Waste
U.S. Environmental Protection Agency
Washington, D. C.	20460
Dear Mr. Meyers:
The American Iron and Steel Institute has carefully reviewed
the draft implementation plan for the Resource Conservation Committee
and was represented at the April 6, 1977, public meeting at which this
plan was discussed.
In the opinion of AISI, the draft plan represents an excellent
and proper approach to the task set out for this Committee by the Resource
Conservation and Recovery Act. The principles proposed as guidelines,
with their emphasis on equity, economic efficiency and administrative
feasibility, should result in policies avoiding the pitfalls which have made
some current programs onerous to industry. The approach to policy
developments stressing consensus, quantitative analysis, and full partici-
pation by all interested parties, should result in balanced effective pro-
grams. Particularly encouraging to us is the position of the staff that
wants and needs inputs from industry.
The iron and steel industry is vitally interested in conservation,
recovery, and recycling of resources. Recycled scrap is a vital raw
material to us and plays a major role in the economics of the industry.
We have, therefore, carried out and are now making many studies perti-
nent to several aspects of the policies to be reviewed as listed in the
Study Plan. We will be happy to submit this material to the Committee
for its use in policy analysis.
We are submitting to the Committee herewith the following
documents which we believe contain information pertinent to this study:
36

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Mr. Sheldon Meyers
April 11 , 1977
Page Two
1)	Steel Industry Economics and Federal Income Tax Policy;
2)	Statement of Edgar B. Speer, Chairman, U.S. Steel, before
the Senate Finance Committee, March 10, 1977;
3)	Summary Report of Solid Waste Processing Facilities, AISI
Committee of Tin Mill Products Producers;
4)	Progress Report on Recycling, AISI Committee of Tin Mill
In addition, the Institute has in preparation a detailed report on
the factors involved in recovery, utilization, and economics of ferrous
scrap. This report by Father William T. Hogan of Fordham University,
is expected to be complete in about one month. We will, as soon as it is
available, send a copy to the Committee for its use.
We hope that the Committee will call on us for additional infor-
mation as its study progresses.
Products Producers.
Very truly yours,
SGF/sd
Ends.
NOTE: Enclosures are not included,
37

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I6it) Massachusetts Avenue. N w . Washington, D O. 2
-------
Mr. Sheldon Meyers, (AW-462)
April 11, 1977
Page 2
As was discussed at the April 6th public meeting, there are
pressures to speed up the section of the study dealing with waste
disposal taxes and submit legislative recommendations to the President
and the Congress in six months rather than two years. We would
strongly oppose this "hurry up" approach. This is a most complex
issue and the various impacts and implications should have thorough
study — as the Congress required — of all economic, social and
environmental consequences.
For example, little thought seems to have been given as yet as
to how to dispose of the funds collected by a waste disposal tax, in
such a way as truly to encourage resource recovery. There are many
other problems related to the proposed broad-based product tax —
these deserve full and careful study, not a six-month superficial
justification.
In closing, we feel that the study mandated by Section 8002(j) of
PL 94-580 can ultimately prove to be the single most important element
of this act. We strongly urge that it be given the necessary in-depth
and detailed investigation that the Congress required.
Richard J. Wiechmann
Directpr
Environmental Affairs
RJW/vcl
39
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Can
Manufacturers
Institute
1625 Massachusetts Avenue, N.W. Telephone
Washington. D C. 20036	202 232-4<
202 232-4677
April 8, 1977
Mr. Sheldon Meyers
Deputy Assistant Administrator
for Solid Waste
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Meyers:
The Can Manufacturers Institute, whose members represent almost
ninety percent of total U.S. metal can production, very much
appreciates the opportunity to comment upon the "Revised Draft
Implementation Plan for the Resource Conservation Committee,"
dated March 27, 1977.
The Institute supports the purpose and intent of Section 8002 (j)
of the Resource Conservation and Recovery Act and commends EPA*s
initial work with the interagency committee responsible for the
completion of a full and complete investigation and study of all
aspects of the economic, social, and environmental consequences of
resource conservation. Participation by both public and private
interest groups clearly is highly desirable. The posited goal of
"balance" is most important, and we are pleased to note the re-
quirement for at least two alternatives in support of recommenda-
tions for achievement of an optimal resource conservation program.
The need for time phasing in order to be certain of a well defined
study program is obvious. Such a plan is critical to the attain-
ment of a well conceived and executed solution to the complex
problem of solid waste management. In short, the scope and sched-
ule of a comprehensive, deliberate study of resource conservation
reflects the justified concern of the Congress and the magnitude
of the achievement expected of the Act and the Resource Conserva-
tion Committee.
Some questions arise concerning the "Implementation Plan" itself.
For example: it appears to focus almost solely on the packaging
industry and the data base, therefore, is unnecessarily limited?
the complexity and interrelationships of various alternatives, such
as recycling incentive policies, may prove unmanageable in a six
40
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Mr. Sheldon Meyers
April 8, 1977
Page Two
month analysis; and there is no clear mechanism to insure balance
in weighing commercial and socio-economic impacts relative to
environmental consequences. The single unresolved question most
important to our members is whether the Committee will establish
a formal mechanism to assure continued, frank communication be-
tween us for the duration of the study program.
Please be certain of our strong support and our desire to work
closely with the Committee.
Every good wish,
John M. Dunn
President
JMD:mj
41
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Donald S. Dawson
Jambs W. Riddbix
Hobaht Tat lob, Jk.
John Davis
L.J. Holbotd
M. JoSBFH STOTJTKNBUBOH
William Lisccm Bohden
Job E. Moodt
OF COVHSBL
Dawson, Riddell, Taylor, Davis & Holhoyd
Attorneys at Law
Washington Building
Washington, D. C. 20005
Tblbphohb
Ahba Code eoe
390-6900
Cjublk Addbbss
Dakts
Tilzx No. 440909
April 13, 1977
Mr. Sheldon Meyers
Deputy Assistant Administrator for
Solid Waste
Environmental Protection Agency
Waterside Mall
401 M Street, S.W.
Washington, D.C. 20024
Dear Mr. Meyers:
Enclosed are comments prepared by Mr. R. S. Weinberg
for the United States Brewers Association concerning EPA's
Draft Implementation Plan for the Resource Conservation
Committee.
While the comments do not attempt to reflect an in
depth analysis of the Draft Plan, I believe that they are
as comprehensive as are possible due to the rather sweeping
generalizations contained in the document. However, we
understand and sympathize with the fact that these studies
are indeed in the planning stage, and we intend to accept
the invitation contained in the Draft to present our views
at each step of the development of the models, objectives
and criteria which will be employed in these studies as
they relate to our industry. Not only will these forth-
coming comments be in comprehensive detail, we are hopeful
that they will provide meaningful technical assistance
to the Task Force in addition to those sources of such
assistance which EPA consistently utilizes.
With kindest regards, I am
Sincerely yours,
JWRxamv
Enclosure

James W. Riddell
Special Counsel to U.S.B.A.
42
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RS.WEINBERG AND ASSOCIATES
PIERRE LACLEDE CENTER • 7733 FORSYTH BOULEVARD
ST. LOUIS, MISSOURI 63105 • (314) 862-8480
April 7, 1977
Mr. Henry B. King
President
United States Brewers Association
1750 K Street N.W.
Washington, D.C. 20006
Dear Henry:
In response to your request, we have reviewed the recently released
Draft Implementation Plan for the Resource Conservation Committee in which this
Committee proposes to spend two million dollars in studying consequences of
resource conservation. This proposal contains mostly suggestions and intentions
too broadly and vaguely stated to allow for the possibility of having opinions
about them at all.
There 1s, however, one Interesting allusion of potentially great in-
terest to the brewing industry. This occurs on page 19 of the draft, where the
authors Indicate an area of study as the "nature and potential for deposit-refund
systems 1n non-beverage-conta1ner applications." This pointed exclusion of bev-
erage containers raises a serious question: Are we to infer that this committee
regards the desirability of a deposit-refund system for beverage containers a
foregone conclusion? And if so, on what evidence 1s this conclusion reached?
Studies commissioned by EPA and others on the subject of restrictive packaging
legislation have characteristically been naive and hypothetical, reaching their
conclusions only after lengthy but nevertheless superficial analyses. It 1s of
considerable concern to the brewing Industry If this committee plans to recommend
extension of this dubious system on the basis of hypothesized "benefits" 1n the
malt beverage production/distribution system.
This first concern leads to a second: This draft suggests commissioning
several more studies as part of three remaining reports to Congress. Given the
quality of studies performed on the question of restrictive packaging legislation,
we doubt that the taxpayer will receive his money's worth from these studies. To
spend two years and two million dollars to produce another group of studies with
limited scope and sweeping assumptions seems questionable at best.
There 1s yet another concern: This committee 1s presented as representa-
tive of the Departments of Commerce, Labor, Treasury, and Interior, the Council on
Environmental Quality, and the Office of Management and Budget as well as of the
Environmental Protection Agency. However, resource conservation has traditionally
been associated with EPA, and they have commissioned several studies of the topic
already. The Commerce Department conducted a study of restrictive packaging legis-
lation 1n-house, and the Federal Energy Administration contracted one study on the
topic. Otherwise, as far as we know, EPA has dominated the topic. We fear that
EPA would dominate the letting of these proposed new studies, and, 1n view of the
poor quality of past EPA-contracted studies, we think the cooperating department*
would be shortchanged for their participation and commitment-of time and money.
43
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Mr. Henry B. King
-2-
April 7, 1977
This is especially deplorable because Commerce's in-house study was far more
objectively conducted than any of EPA's contracted studies.
The quality of this Commerce study derives from the quality of the people
employed by the Commerce Department. Groups of skilled professionals who now com-
pose the Bureau of Economic Analysis or the Bureau of the Census have been assembled
over decades and have had the benefit of years of rigorous research on such matters.
Similar groups exist within the Department of Labor, Interior, and other departments
participating in this Committee. These seasoned professionals tend to be more
objective and more skilled than almost any private research firm in areas that have
fallen under their purview.
Outside consultants, on the other hand, are characteristically assigned
limited amounts of time and money to conduct studies on subjects whose fine points
may prove impenetrable to generalists given only limited time and money. Research
must fit into these time and money constraints (especially those of the Committee,
which are mandated by Congress) and abridgements of research are made up for by
assumptions. Given the nature of government contracting, the .assumptions are often
slanted towards the predilections of the sponsoring agency, so that the results
reflect at least partially what the sponsor wants to hear. What emerges from this
inexperience and these limitations are hypothetical and biased studies. They never
are able to say what will happen with any probability, but instead are reduced to
saying what could happen under a specific set of given assumptions which often are
of questionable realism. The conclusions of contracted studies are typically so
hedged by assumptions and subjunctive moods that they are meaningless.
Our recommendation for the studies Congress has directed the Committee to
perform 1s that they be performed by an interdepartmental task force created for
this purpose. We believe the most able and experienced people in the field should
conduct these studies; we also believe these people are to be found in Washington
working for the various participating departments. These career professionals,
whose ability and experience in economic questions is unchallenged, would produce
the best studies.
If crowded schedules or other considerations "render formation of this
interagency task force infeaslble, then our second-choice recommendation would be to
form an interagency coordinating board to let the contracts and to ensure that the
outside consultants cover all the major Issues raised by the subject to be studied.
This Interagency board should serve to vitiate the biases of any one agency and
referee the assumptions and methods of the consultants. With close supervision by
professionals trained to analyze the fine points of economic Issues, there is at
least some hope for unbiased, reasonable, comprehensive studies to emerge from the
Committee for Congress. The consultants' reports should not be released to Congress
or the public until they have gone through a formal refereelng process and the key
professionals 1n each agency certify the validity of the assumptions, data, and
methodology used 1n supporting the reports' conclusions. Too much is at stake to
accept anything but the most objective and professionally sound studies as a basis
for policy actions 1n this vital area.
Sincerely,
Vr-
R. S. Weinberg
Copy to Mr. James VI. Riddel!
RSW/dk	44
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Ducks
Unlimited, Inc.
1937-1977—Four decades of conservation pioneering
National Headquarters • P.O. Box 66300 • Chicago, Illinois 60666
April 12, 1977
Mr. Sheldon Meyers
Deputy Assistant Administrator
for Solid Waste
United States Environmental Protection Agency
Washington, DC 20460
Dear Mr. Meyers:
Reference is made to your letter under date of March 24, 1977 to the
recipients of the Draft, Revised March 24, 1977... "Implementation
Plan for the Resource Conservation Committee".
I noticed under the section "Principles and Guidelines", five basic
principles that appear to be all inclusive of most of the problems to be
encountered. However, one area that applies to wildlife specifically is
mitigating losses or the application, etc. While wildlife can never be
truly mitigated for, it is better than nothing.
An interesting aspect to mitigating loss that has not been involved with
our thinking or, at least, our actions of the past where the environment
has been modified where wildlife is concerned, is the mitigating loss as
the result of agriculture.
We consider mitigating loss for the Corp of Engineers where dams and
stream modification are involved. We think of mitigating loss when an
industry or governmental entity is involved with correction or change of
the environment, but we have not applied it to agriculture, and agriculture
is the greatest debilitator of wildlife today, and has been for the better part
of this century.
I realize that to take on the sacred cow would be almost heresy. However,
I would further like to point put that in our water quality programs little
continued
45
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Mr. Sheldon Meyers
-2-
April 12, 1977
has been accomplished as to the affects of siltation and, again, very
little in the way of mitigating loss has ever been discussed with the
agricultural element.
These are several considerations that must be considered in every habitat
modification event involving wildlife. Whether or not we do anything about
it does not negate its importance.
awr
cc: Mr. Robert L. Herbst
Mr. Lynn A. Greenwalt
Mr. John Gottschalk
Mr. Gaylord Donnelley
Mr. Lee C. Howley
Mr. Herman Taylor, Jr.
Dale E. White sell
Executive Vice President
46
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UNITED STATES
ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION
WASHINGTON. D.C. 20545
APR 1 2 1977
Mr. Sheldon Meyers
Deputy Assistant Administrator
for Solid Waste
U.S. Environmental Protection Agency
f "
The Implementation Plan for the Resource Conservation Committee
transmitted by you on March 24 has been reviewed as requested, and
the following suggestions are offered.
The term "society's resources" might be defined relative to public or
private ownership or control over the use of resources. General
acceptance of a concept should be based on uniform understanding.
Environmental considerations are sufficiently pervasive that the need
for environmental assessments of the various proposals from the support
studies program might be stated.
A major area for investigation not identified is that of process
material substitution so that upon completion of the useful life of
an end product, it could be economically reclaimed 1n an environ-
mentally acceptable manner. An Immediate example would be the
substitution of a benign organic for sulphur 1n vulcanization,
thereby making the large quantities of scrap rubber tires available
as an energy source 1f they could not otherwise be recycled. The
draft should be expanded to address approaches to creating a needed
change 1n the psychological and social Impediments to public
acceptance of recycling materials.
I hope that these comments are helpful to you.
Sincerely
W. H. Pennington, Director
Office of NEPA Coordination
47
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COMMENTS ON THE DRAFT IMPLEMENTATION PLAN
FOR THE
RESOURCE CONSERVATION COMMITTEE
TO THE
OFFICE OF SOLID WASTE
U.S. ENVIRONMENTAL PROTECTION AGENCY
APRIL 6, 1977
Marchant Wentnorth
Research Director
Solid Waste Project
Environmental Action Foundation
Dupont Circle Bldg., Suite 724
Washington, D.C. 20036
202-659-9682
48
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Good afternoon, My name is Marchant Wentworth,
Research Director of Environmental Action Foundation's
Solid Waste Project.
I would like to thank the Office of Solid Waste
for the opportunity to comment on the draft implementation
plan for the Resource Conservation Committee.
To save time, I will briefly summarize my remarks
concerning this draft plan and submit a more detailed
comment for the record.
It is ironic that in spite of the title of the
new solid waste legislation, there is little direct
reference to resource conservation in the new Act. This
Resource Conservation Committe represents one of the
few direct specific actions outlined in the Act that is
directly concerned with the subject of resource conservation.
Therefore,the importance of this Cabinet-level committee,
both as a policy and a planning tool, can not be over-
emphasized.
It is vitial that this committee have the full
support of the Office of Solid Waste and have ample funding
if it is to operate effectively. Clearly more research
is needed in the field of resource conservation. Concrete
programs based on these findings must be implemented. We have
just begun to start to answer some of our questions concerning
49
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this basic solid waste issure. This committee is an
important Beginning of that process.
Turning to a few specifics of the implementation
plan, we feel that, overall, this draft plan can provide
a realistic framework for working on the issues of
resource conservation. We are particularly glad to see
the emphasis on using specific ^ssues as a tool to define
the overall policy. This approach can be an effective
way to generate needed information on specific issues
and further define policy.
We are aids encouraged to note the role of public
participation in the workings of the committee. While
this role must be firmly defined in order to be meaningful,
this participation process can help to insure that the
committee receives a full range of opinion.
We feel that the "polluter pays" principle outlined
in the draft is a good one. It is important to note
however that indirect as well as direct costs should be
included.
We have also identified other barriers to resource
conservation that should be studied in addition to those
mentioned in the draft. Fpr example, freight regulations
that act as a disincentive to resource conservation should
be throughly investigated by this committee. While the
50
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subject of freight rates has been researched, preliminary
investigations reveal that restrictive ICC regulations mayr
in some circumstances, prohibit the use of certain trucks
and carriers from transporting recycled materials. Often,
this may create an excessive economic burden on the
recycler and act as a disincentive to conserve resources.
We ask that the committee reveiw these regulations and report
their recommendations to the Congress and the Interstate
Commerce Commission.
In another area, we think that the effects of advertising
on waste generation should be investigated by the committee.
Too little is known concerning the motives of the consuming
public and how advertising affects those motives. More
research is needed.
To conclude, we would like to urge the Office of
Solid Waste to actively press for full funding for this
important committee. Only in this way can the mandate
of the Resource Conservation and Recovery Act be adequately
furfilled.
Thank you.
(Text of additional xemarks will be forthcoming under
separate cover.)
51
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environmental
action
foundation
724 Dupont Circle Building
Washington, D.C. 20036
Telephone (202) 659-9682
Advisoiy Board
April 11, 1977
Robert Rienow, chairperson
Walter Boardman
Harry Caudill
Herman Daly
Michael Frame
John Gofman
La Donna Harris
Denis Hayes
Hazel Henderson
Sam Love
Margaret Mead
Victor Reuther
Alvin Toffler
Projects
Elecric Utilities
Solid Waste &
Materials Conservation
Transportation
Nuclear Power
B-l Bomber
Hr. Frank. A. Smith
Resource Recovery Division (AW-463)
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Smith,
Enclosed pftease find a copy of our additional conu#ents
on the draft implementation plain for the Resource
Conservation Committee.
If you have any questions or comments feel free
to contact me.
Marchant Wentworth
Solid Waste Project
52
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ADDITIONAL COMMENTS
ON THE
DRAFT IMPLEMENTATION PLAN
FOR THE
RESOURCE CONSERVATION COMMITEE
TO THE
OFFICE OF SOLID WASTE
U.S. ENVIRONMENTAL PROTECTION AGENCY
BY
Marchant Wentworth
Research Director
Solid Waste Project
Environmental Action Foundation
Dupont Circle Bldg., Suite 724
Washington, D.C. 20036
202-659-9682
S3
-------
In spite of the importance of resource conservation
in overall solid waste management planning and implement-
ation, resource conservation is rarely directly mentioned
in the Resource Conservation and Recovery Act of 1976.
The Resource Conservation Committee provided for under
this Act becomes the main resource conservation provision
in this new legislation. For this reason, it very important
that this Committee be fully supported and funded by the
Office of Solid Waste. Adequate funding for this Committee
will pay dividends to other areas of investigation and
implementation. Of course the potential economic and
energy savings to the entire society would be enormous.
The importance of materials conservation and proper
funding for this Committee can not be over-emphasized.
To arrive at some conclusions on what direction we feel
the Committee should take to achieve a comphrensive policy
on materials conservation policy, we have analysed the draft
implementation plan and offered our comments on how the
draft maight be inqproved or changed. Page and paragraph
numbers refer to the draft circulated by Sheldon Meyers dated
March 24, 1977.
Turning to the specifics of this draft plan, we find
that, overall, the draft does break valuable new ground in
confronting some of the administrative and bureaucratic
problems that have traditionally surrounded the area of
54
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resource conservation. We certainly support the objectives
of the Committe and encourage it to develope strong policies
and objectives that are specific as possible. Accordingly,
we wonder if the section on page 5 concerning the free-market
principle is helpful or even accurate. While we could all
tk««rically agree that conservation policies should not
interfere with the free choice of producers and consumers to
make their selection in a decentralized fashion, we see
numerous instances where these two principles have conflicted
and, in fact, constitute the reason for the existance of the
Committee. Of course we recognize the importance of the
free market system but we doubt whether the consumer is
offered a clear freedom of choice. Too often we have ex-
perienced this failure in the free market system when we
have been forced to pick between the best of two evils.
And too often we suspect that what we want is- dictated not by
needs or social benefits but rather by a complicated system
that equates social status with material goods. While it
is not realistic to expect that we will change basic human
needs, it is clear that because ;nany of the costs of the
free-market system remain to be internalized in the economic
system, regulations or restrictions may well be necessary
to minimize environmental degradation and economic dislocations.
55
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We approve of the "polluter-pays principle" outlined
in the draft plan. It is important to include all thedirect
and indirect costs in this principle. We recognize that
many of these indirect costs are enormous. Nonetheless,
we feel that the polluters, not the consumers/ should bear the
burden of these social and economic costs.
We applaud the concept of social and economic equity
as outlined in paragraph 3 on page 6 of the draft. Again,
we would urge that all direct and indirect costs be considered
in this equation. We would favor compensating the affected
parties rather than taxing windfall profits.
On page 9, the concept of building on consensus is
laudable and we hope it works. In case it doesn't, we
would want to see dissenting opinions presented in the
report.
On page 11, paragraph two, re recognize the diffi-
culties involved with assessing .the economic value of the
primary benefits but feel strongly that these benefits
must be quanitified rather than just stated in physical
terms as stated in the paragraph. Unless benefits are
quantified, concrete comparisons are difficult.
We are in complete agreement with the features
that allow transition and implementation so as to mitigate
the limitations and uncertainties of new policies. It
may be impossible to anticipate all the impacts of a part-
icular policy. Step-wise implementation may help avoid
many pitfalls.
fifi
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In part of three of the draft plan - the study
plan - we feel that among the incentives and isincentives
to be considered, freight regulations (not including
freight rates), should also be investigated. For example,
preliminary investigations, reveal that restrictive ICC
regulations may, in some circumstances, restrict the use
of certain trucks and transporters for the hauling of
recycled materials. These regulations, in effect, create
an extra expense for the recycler that must pay for the
unnecessary expense of additional trucks. This penalty
is often an economic barrier to recycling, especially
in rural and semi-rural areas that lack local markets.
On page 21, we are shocked to find that only a
very limited amount of money is presently written into
existing EPA contracts using FY 77 funds. It is vitial
that EPA reprogram its funds to insure full funding and
support for the Resource Conservation Committee.
We feel that the Committee's approach to the problem
of "tool development" using both the short and long-term
programs is an effective one. However, the specifics of the
long-term program are not clear. We find that industry
modelling, while useful to some extent, are continually
open to question concerning data base, applicability, etc.
They should not be relied upon. A comphrensive materials
conservation policy would be much more useful and could be
utilized by a variety of sectors for guidance.
57
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We are very enthusiastic about the public participation
section of the implementation plan but recommend that
specific procedures be outlined by the Committee. We
think that the provisions for public meetings are a good
one and believe that they are an effective vehicle for
receiving imput. More work remains to be done however.
More publicity must be provided, more lead time given if
public participation is to be a reality. Specific questions
may be more useful then broad policy questions. Public
interest groups are more adept at replying to specific
cases than general cases.
This concludes our comments on the Resource Coservation
Committee draft plan.
Thank you
58
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Glass
Packaging
Institute
1800 K Street NW, Washington, D.C. 20006
(202) 872-1280
TWX: 7108229337 GLASS WSH
March 22, 1977
Mr. Sheldon Meyers
Deputy Assistant Administrator
Office of Solid Waste
U.S. Environmental Protection Agency
401 M Street, S. W.
Washington, D. C. 20460
Dear Mr. Meyers:
We have had only a few days thus far to review
your March 15, 1977 "Draft Implementation Plan for the
Resource Conservation Committee: First Report to the
Congress." However, we want to provide you and the oth-
er Agencies on the Committee with our preliminary reac-
tions in advance of the Committee's initial meeting,
which I understand has not yet been held* We are also
cognizant of the time pressures that the Committee faces
in view of the April 21, 1977 date by which your first
interim report to the President and the Congress is due.
We have a number of significant concerns about
EPA1s apparent concept of the resource conservation
study, the basic criteria and assumptions that EPA pro-
poses for the Committee to employ, and the procedures
proposed for carrying out the study and reports. A
brief summary of our concerns is provided as an attach-
ment to this letter. We raise these issues in a con-
structive spirit, looking forward to the opportunity to
discuss them with the Committee and to assist you on a
continuing basis to meet the demanding analytical and
reporting requirements of section 8002(j) of P.L. 94-580.
59
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Mr. Sheldon Meyers
March 22, 1977
Page Two
If you have any questions concerning our comments,
please contact me or Mr. Pat Corcoran, Vice President of
the Glass Packaging Institute, at 872-1280.
Enclosure
cc: Dr. Sidney Galler
U.S. Department of Commerce
Dr. Lawerence Woodworth
U.S. Department of the Treasury
Ms. Nina Cornell
Council of Economic Advisors
Mr. Bruce Blanchard
U.S. Department of Interior
Mr. Steven Jellinek
Council on Environmental Quality
Mr. Jim J. Tozzi
Office of Management and Budget
Mr. Edward F. Tuerk
U.S. Environmental Protection Agency
Sincerely

William W. Sadd
President and General
Manager
60
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March 22, 1977
PRELIMINARY COMMENTS OF THE GLASS PACKAGING INSTITUTE
ON THE
MARCH L5, 1977 E.P.A. DRAFT IMPLEMENTATION PLAN
FOR THE
RESOURCE CONSERVATION COMMITTEE, FIRST REPORT
UNDER
SECTION 8002(j) OF P.L. 94-580
I. Concept of the Study and Report
A.	Taken as a whole, the EPA draft seems to empha-
size unduly the selection and proposal of policies as op-
posed to the rigorous and thorough analysis of a full range
of policy options. The law does call for recommendations
from the Committee but only after, and on the basis of, the
sort of analysis just described. Even at this point, how-
ever, the Congressional desire for a display of options is
evidenced in the explicit requirement that any recommenda-
tion be accompanied by at least two alternatives.^!/ The
draft's list of policy options to be reviewed—?./ reflects
the relatively restricted range that evidently would be
considered under the EPA draft. For example, this list ap-
pears to include few if any options for incentives/disincen-
tives or regulations at the consumer level as opposed to the
industrial production level. Similarly, the draft's pro-
posal for work on industry-specific response models (23),
as part of an attempt to improve available analytical tools,
appears to single out an extremely narrow range of indus-
tries, basically the container and packaging industries.
The very limited list creates at least the inference that
these industries may be singled out for particular atten-
tion. If this is true, some rationale is needed. If this
is not true, clarification should be provided. Comments
I.B. and I.e., which follow, are closely related.
B.	The draft does not appear to recognize that the
national interest in conservation varies considerably among
the many different resources and among their various uses.
Rather, it seems to treat "resource conservation"' as a single,
undifferentiated subject. Some resources are relatively
plentiful domestically, while others are in short supply
domestically and are available overseas only from unrelia-
ble sources of supply. Similarly, the present extent of
resource waste, and the related extent of opportunities for
JJ P.L. 94-580, S8002 {j) (3) .
2/
—' EPA Draft, p. 12. Hereinafter, relevant pages
of the EPA Draft are referenced in the text in parentheses.
SI
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increased conservation, vary widely among resources and
among categories of uses of particular resources. Thus,
it would seem that one important function of the compre-
hensive study should be to identify where conservation
is most needed and feasible. Priorities should be es-
tablished.
C. Once priority areas of concern have been iden-
tified, Congressional intent requires a thorough analysis
of a full range of options for achieving conservation
goals. The study of particular alternatives should be
comprehensive, taking into account interrelationships
among products, industries, etc. Except insofar as the
priorities discussed in I.B. above dictate, neither the
overall study nor the basic options considered should be
limited to particular industries, products, or resources.
II. Basic Criteria and Assumptions
A.	Although the draft expresses a laudable commit-
ment to minimizing interference with free market choices
insofar as possible (5), this objective would more appro-
priately be stated in an affirmative fashion, i.e., by a
positive commitment to relying upon the free market inso-
far as possible to solve problems that are identified.
Thus, particular priority should be given to first elimina-
ting any distortions or artificial constraints (e.g., cer-
tain tax policies), in the marketplace today that tend to
stifle conservation or promote waste. The addition of
new regulations or charges, further modifying free market
incentives, should be considered only secondarily, where
it appears that removal of present market impediments will
not adequately meet conservation needs.
B.	The draft assumes without question that the
"polluter pays" principle must and should apply without
exception (6). In a study intended to explore a full
range of alternatives, such a blanket preconception is
analytically unjustified. Moreover, the statement of the
principle which was accepted by the U.S. and other O.E.C.D.
nations is not as .unqualified as the discussion in the
draft suggests.—-' Obviously, in some cases application
of the principle can be quite regressive in its economic
3/ see Council on Environmental Quality, Third An-
nual Report, pp. 80-81, 102-104 [particularly a.(a)5] (1972).
62
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impact on different income groups.—^ Consideration of
less regressive alternatives should not be excluded. In-
sofar as the "polluter pays" principle is to be followed,
however, it should be made clear to the public and the
Congress that this in effect means the polluter's custo-
mers pay. There should be no misapprehension that pollu-
tion control costs borne by the private sector, without
governmental redistribution of impact, will stop at the
polluter's level. Under most market conditions, such
costs will (and should, according to most economists) be
passed along to consumers to a substantial extent (limited
principally by the existence of competition from signifi-
cantly less-polluting industries).
C.	EPA's expressed concern for "social and econ-
omic equity" (6, 7) should include a recognition that in
some cases the magnitude or severity of the impact of a
conservation measure on one particular competitive sector
may be a valid reason to reject a particular alternative
altogether in favor of a less disruptive one, even if the
benefits to be achieved by the alternative are somewhat
less. The document seems to imply at several points (7,
11) that the solution for a conservation proposal which
may have significant adverse economic impacts is simply
to phase it in in some way so as to minimize the impacts
in the early years. If a proposal is fundamentally un-
sound on economic grounds, a phase-in may simply mask
this fact and is not a proper solution.
D.	It would seem desirable for the Committee to
commit itself to shifting debates insofar as possible away
from the areas of methodology and validity of data and in-
to the legitimate area of value judgments. Too often in
the past, studies of this nature have generated consider-
able debate and controversy among the Agency and affected
interest groups on methodological rahter than substantive
issues.
III. Procedures
A. The draft's discussion of "economic efficiency"
(7, 8) alludes to cost-benefit analysis. Since the study
is to cover ''all aspects of the economic, social, and-§n-
vironmental consequences of resource conservation," —
See Council on Environmental Quality, Fourth An
nual Report, p. 107 (1973).
P.L. 94-580, S8002(j)(l).
63
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a commitment to providing such analyses in the report, in-
sofar as feasible, seems appropriate.
B.	The concern for economic efficiency should ex-
plicitly include analysis of employment impacts, both as
to quantitative measures of the number of people employed
and disposable income and as to qualitative measures of
the nature and value to society of the types of jobs
created or destroyed by a particular proposal.
C.	The reference to seeking consensus is ambiguous.
(9) If it means that the interagency committee will ob-
viously seek to achieve a consensus in the course of its
activities (see p. 16, last paragraph), this is logical
and to a large degree desirable. But, if the reference
suggests that the study should start out with a predis-
position to certain ideas that are deemed to be "popular"
on the basis of past studies, opinion polls, etc., then
this should be rejected. The study should certainly at-
tempt to lay out all feasible alternatives in an objec-
tive way and leave it to the President and the Congress
to evaluate the popularity and thus political feasibil-
ity of particular alternatives.
D.	The commitment to use the best quantitative
estimates that are possible for benefits (10) is laudable,
but there should also be such a commitment to do quantita-
tive estimates of economic impacts and other side effects
(e.g., potential effects on competition). Moreover, it
should be recognized in both of these areas that the inher-
ent imprecision of most estimates calls for a display of a
range of possible impacts with an explanation of the assump-
tions used to derive both the high and low estimates with-
in the range. Where reliable data are not available, the
study should avoid presenting only one assumed scenario
and instead display a range of assumptions.
E.	We are seriously concerned about the proposed
public participation "plan" (24-26). There is absolutely
no mechanism suggested for permitting, much less solicit-
ing, input and reactions from industry, public interest
organizations, or other interested groups on a meaningful,
continuing basis. Such intimate involvement of interest-
ed parties outside the government will be essential if the
study is to provide the President and the Congress with
supporting documentation as to which there is a reasonable
64
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consensus. (See comment II. D., supra.) Of course, there
will be various views on particular alternatives and recom-
mendations, but involvement of interested parties, many of
whom have essential information and expertise to contribute,
can minimize controversy over data and methodologies.
The four proposed public meetings are totally in-
adequate, in our judgment, to permit meaningful private
sector participation. Much more continuous involvement is
necessary if private organizations are to do anything more
than listen to a few "presentations" by the government (25)
concerning work already done and conclusions already reached,
at stages when comments would be too late.
As an alternative the Committee should consider open-
ing all of its formal and working sessions, and those of sub-
committees and staff groups, to attendance from the private
sector. Reasonable limits could be placed on the raising
of questions and suggestions at those meetings themselves,
but this process would allow the government participants to
question those who may have essential information. Also,
the private sector participants could raise timely sugges-
tions and questions throughout the study period outside of
the actual meetings to the extent appropriate. A variation
on this approach might be the establishment of a private
sector advisory group to give additional structure to the
sort of realistic, continuous participation suggested.
If afforded the type of realistic opportunity to par-
ticipate just described, the Glass Packaging Institute is
prepared to make available to the Committee on a continuing
basis qualified people with essential technical and/or econ-
omic expertise. We assume that a number of other organiza-
tions would respond similarly.
F. Given the scope of the study that the Congress
has demanded, we have a major concern that the proposed
funding levels are grossly inadequate (32-36). In some
areas, sophisticated analytical techniques must be developed
or perfected. In a number of areas, data bases must be es-
tablished. Otherwise, the "study" will be a misleading,
superficial one that is built largely upon assumptions and
hypothoses rather than the best data and analytical tech-
niques available within reason.
65
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Will qualified contractors, presumably afforded the
opportunity to bid competitively, be able to offer their
services within the severe funding limits placed on some
very demanding tasks? Do the proposed grants to public
interest organizations make sense on a priority basis
when considered in light of the substantial shortage of
funds for essential analytical work?
If there is no realistic prospect for a significant
increase in funding, the Agency should consider the alter-
native of substantially reorienting it as a more "macro-
economic" analysis of resource conservation issues. A
study with the level of detail that is proposed, if severly
underfunded, could create more confusion than enlighten-
ment.
G. We have a number of questions about the pro-
posed schedule and sequence of reports (27-31). In parti-
cular, we question the appropriateness of using the October
1977 interim report as a sort of partial final report,
limited to recycling incentives. The Congress appears to
want a comprehensive report that compares a wide variety
of options. It is willing to wait until October, 1978
to have this complete report. That objective would not
seem to be well-served by an interim report that effec-
tively draws some "final" conclusions as to one category
of options, such as recycling incentives, in isolation
from other categories of options. Any similar effort to
prepare an early "final" report on a particular option or
category of options would also seem to run contrary to
Congressional intent.
66
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%25 Emory Grove Road
Gaithersburg, Kd, 20760
April 10, 1977
Mr. Sheldon Meyers
Deputy Assistant Administrator for Solid Waste
EPA
A W ^62
ifOl M st. SW
Washington D.C. 20460
Dear Mr. Meyers 1
The Implementation Plan For The Resource Conservation Committee transmitted
by you on March 2k for public review might be improved by certain expansions.
The term "society's resources ¦ should be defined relative to public or private
ownership or control over the use of the resources. Uniform understanding must
precede general acceptance of a concept.
Environmental considerations are, or should be, so important that the need for
environmental assessments of the various proposals expected from the support
studies program should be made explicit,
A major area for investigation not identified is that of process material
substitution so thit upon completion of the useful life of an end product, it
could be economically reclaimed in an environmentally acceptable manner* An
immediate example would be the substitution of a benign organic for the sulphur
used in rubber vulcanization. Eliminating the sulphur would make the scrap tire
mountains available as an energy source ff the materials could not otherwise
be recycled.
The draft should be expanded to address approaches to creating a needed ohange
to the psycological and social impediments to public acceptance of material
recycle.
Tours truly

Robert E. Grossman
67
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lstltute of Scrap Iron
and Steel, Inc.
established 1928 Joseph S Schapjro, President
1729 H street n w Noah LiH, First Vice President
Washington, D. C 20006 Morton B Plant, Second Vice President
202 ¦ 298-7660 loUiS p Hehman, Treasurer
Emanuel Crystal, Secretary
Herschel Cutler, Executive Director
April 12, 1977
To: Resource Conservation Committee
.ve Director
From:
Thank you for the opportunity to review the Committee's draft implementation
plan. It is certainly a comprehensive undertaking which we hope will result
in a thorough investigation and analysis of resource conservation that will
lead to appropriate and aggressive Congressional action where needed.
To that end, the Institute looks forward to cooperating with the Committee
and its staff to the fullest.
Our one major comment on the draft plan deals with the section on Principles
and Guidelines (p. 5), 1. Free-market principles.
It states that "... conservation policies should not interfere with the
free choice of producers and consumers to make their selections in a decentralized
fashion. ..." The tone of this first principle implies that while other
policies could or might interfere with the private market system, conservation
policies should not. But it is obvious that other policies now in effect do
interfere with the private market system. The Institute has continually
spoken out on the issue that the private market system is being influenced
by artificial factors, e.g. freight rates and tax policies, which discriminate
against recyclable iron and steel scrap to the advantage of its virgin counterpart
iron ore.	*
Certainly, removal of artificial factors such as these would provide a much
clearer indication as to effectiveness of the private market system as an
allocator of society's resources.
At the present time, under these conditions, the private market system is not
able to most efficiently perform that function.
The Institute would suggest that the word "conservation" be deleted to indicate
that no policies should be allowed to interfere with free choice.
68
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March 31, 1977
Sheldon Meyers
Solid Waste Division
EPA
Washington, D. C. 20460
Dear Mr. .Meyers,
Your office has kindly sent me a copy of the draft implementation plan
for the Resource Conservation Coomlttee, and my general comments are simply
gratification that you have managed to organize your approaches so efficiently.
My specific responses were stimulated by a number of items. On page 2,
in the quotation from the ACT, I felt that 1 wanted to raise questions about
these "charges", although I guess that I am totally in favor of having this
topic throughly aired. I enclose a copy of the letter that I have sent to
President Carter in regards to his suggested tax to control beverage containers,
which makes my point about the wide variation in "disposal routes" chosen
which, to my mind, make t&is approach not wholly satisfactory.
On page 5 I bristled somewhat at this lip service to "free-market
principles", objecting more to the flag waving tone than to the sober
underlying concept that these mechan£tos, when they are allowed to operate
without hidden constraints, such as subsidies, or long term contracts,
do indeed have some utility.
*
Since I am not foliar with the recent documents you cite, on page 9,
I can only assume that these /lineal descendants of the Materials studies
of 1973 and 1974, such as those from the National Academy of Sciences.
I am pleased to see that you plan to continue to work with the League of
Women Voters and with the Environmental Action Foundation. I am a member of the
steering committee for the National Coalition of Solid Waste Management, which
as you knfw Is supported through EAF's Solid Waste Project. I am also, as a
member of the Sierra Club, in touch with their committees on Energy Conservation.
As an early disciple of Br^ce Hannon, I incline to try to apply energy criteria
In parallel with dollar costs in the development of environmental policy.
I would be most appreciative if you could keep me supplied with the reports
from this new committee. 1 am very much involved in the development of the
public lnformatlonQrograms, in Ohio and the Midwest, that contribute to the
"environmentalists1 positions", and the more Information I have, the better.
Sincerely yours,
(these are my personal comments
not to be confused with formal
Sierra Club positions.)
69
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THE LEAGUE OF WOMEN VOTERS OF ARKANSAS
April 6, 1977
Mr. Sheldon Meyers
Deputy Assistant Administrator
for Solid Waste
United States Environmental Protection Agency
Washington, D.C* 20460
Dear Mr. Meyers:
As a recipient of the draft implementation plan for the
Resource Conservation Committee 1 am pleased to make reply
comments on behalf of the LWV of Arkansas. Since ours is a
rural state our statements will in some respects be taking a
different emphasis from Leagues in more heavily populated
regions. However, our comments are predicated upon U.S.-LWV
policy. Since the LWV natimal position is amply understood
by EPA, I shall not restate it. Our action does "support
policies to reduce the nonessential part of the waste stream,
recover the nonreducible portion, and then ensure the safe
disposal of the rest".
My first comments would relate to the "Policy Background
and Principles, Reasons for Federal Involvement". Here League
would like to see a clear statement that a primary goal of
national resource conservation should be to forestall depletion
of nonrenewable resources and especially those resources with
unique properties for which we have no foreseeable substitute.
This should include analyzing the energy consumed as material
is discarded in a higher state of entropy than its original
form--especially for the supply of low entropy materials as
any consumption of such a limited material is a real cost.
"Principles and Guidelines" are listed to be used in
assessing and recommending resource conservation and recovery
policies. We strongly support your "the polluter-pays"
principle and feel that to the fullest extent possible
external costs must be fully internalized. It should also
be recognized that both consumption of resources and pollution
of the environment contribute to the GNP and a study should
be made of the economic impact of "optimal growth rates" for
the consumption of materials and energy when these are
reduced to the lowest level so goods are long lasting, and
depletion and pollution are minimal.
70
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Mr. Sheldon Meyers
April 6, 1977
Page 2
Finally, under the study plan we in the LWV would like
to see included a specific analysis to develop a solid waste
management plan for (1) towns under 60,000 and (2) rural
regions to establish guidelines to be included in state
plans that would give direction in resource conservation.
This would address collection of the materials separated
at the source and incentives for the maximum marketing
feasibility of the recovered materials. Specific problems
should be addressed such as: automobile tires, batteries,
beverage containers, news print, marketable end products
from small industries, public policy incentives for use of
natural fertilizers such as poultry processing wastes,
manures and sewage sludge by offering subsidies for the use
of compost and sewage sludge as opposed to the current sub'
sidles for the use of inorganic.; fertilizers.
Also to be addressed would be a determination of
adequate level of Federal funding necessary to assure state
and local government programs to implement resource conser-
vation and recovery to the fullest extent possible. This
level of funding should then be recommended by this study.
Citizens who are concerned, as League members are,
about unnecessary depletion of resources and the resulting
environmental insult to the land, air and waters of our
nation look to this study as a unique opportunity for a
really quality analysis of the problem. The public is highly
concerned--especially in areas such as Arkansas where soil
structures are often unsuitable for sanitary land fills.
These areas, many rural, need assistance in planning local
and/or regional resource recovery with combined low and
high technology. The operation of these facilities must
be fully demonstrated as the local governments do not have
the resources to construct and operate energy and capital
intensive facilities. The technical assistance and guidance
of Federal studies is necessary.
We are pleased your study includes policies for promoting
governmental procurement of secondary materials at the state
and federal levels. Only by requiring increased use of the
secondary materials will we reduce our total consumption of
virgin resources. Finally, we would urge that you also
include a study of the impact of the media on the consuming
habits of our nation.
71
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Mr. Sheldon Meyers
April 6, 1977
Page 3
This study provides a most unique opportunity to identify
means to promote a culture identified as a "conserving society"
instead of our current "consuming society". The public input
to your plans is strong and we hope that the final report will
establish a time frame to assure the concerned public that we
will move into implementation of resource conservation as
smoothly and quickly as the policy allows.
Thank you for this opportunity to make comments into the
record.
Sincerely
Loxs lmnoxx
Vice President
72
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NATIONAL. ASSOCIATION OF RECYCLING INDUSTRIES, INC.
330 MADISON AVENUE I NEW YORK, N.Y. 10017 / iahea code sib> 067-7330
April 5, 1977
To: Jacob Levin
Commerce Department
From: M. J. Mighdoll
This is in response to the opportunity you provided us to review the
EPA Implementation Plan for the Resource Conservation Committee.
Having received this material only a few days ago — and attempting to
meet your April 6 deadline for comments — we have haul only an oppor-
tunity to quickly review the draft.
Perhaps my initial reaction is that it is most unfortunate that this
entire effort was not undertaken several years ago. However, speaking
more constructively, my hope is that the Committee could consider operat-
ing on an expedited schedule so as to provide the results of its policy
area analyses to the Congress during the current year. Since many of
the policy issues with which the Committee's work will be concerned are
currently before the Congress, it is indeed unfortunate that the Com-
mittee's final report is not scheduled until late 1978.
It would appear that the substantive policy areas to be analyzed by the
Committee do include most of the principal issues which NARI considers
essential topics.
I hope that we will have an opportunity to provide input to the Committee
as the policy areas are discussed in view of our primary involvement and
concern with recycling potentials.
Best regards.
MJM:dc
73
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NATIONAL ASSOCIATION OF RECYCLING INDUSTRIES, IIMC.
330 MADISON AVENUE I NEW YORK. N.Y. 10D17 / caaba code aiai BS7-7330
April 11, 1977
Honorable Nicholas Humber
Director, Resource Recovery Division
Environmental Protection Agency
Room 2107
Waterside Mall
401 M Street, S.W.
Washington, D. C. 20460
Re: Resource Conservation Committee - First
Report To Congress Under Resource Con-
servation And Recovery Act Of 1976
(Public Law 94-580)	
Dear Mr. Humber:
As our representative stated during the public meeting
the Resource Conservation Committee held on April 6 with reference
to its Draft Implementation Plan under the Resource Conservation
and Recovery Act of 1976, the National Association of Recycling
Industries, Inc. (NARI) and its more than 800 member companies
in the aluminum, copper, lead, zinc, wastepaper, textile and
rubber recycling industries stand ready to assist and cooperate
with the Committee in every possible manner as it endeavors to
comply with the Congressional mandate contained in the 1976
legislation.
It is unfortunate, of course, that a coordinated federal
effort of this nature was not undertaken several years ago. But
now that the task has been assigned to the Committee, we believe
the energy, resource recovery, and solid waste disposal problems
confronting the United States are too crucial and too urgent to
permit workable solutions to be postponed for another two years —
i.e. until the Committee renders its final report in October,
1978. Consequently, from the very outset NARI urges the
Committee to establish an expedited schedule that will enable
the Committee fully to respond to the Congressional mandate at
a much earlier date.
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Honorable Nicholas Humber
April 11, 1977
Page two
In this regard, we note the Committee does intend to
deal with "Recycling Incentives" on a priority basis, and that
your report in this area will be sent to Congress in October,
1977 or sooner. This is very logical and exceedingly desirable
because, as you know, recycling incentives have literally been
"studied to death" by one federal agency after another, and while
all concur that incentives are vitally necessary, there has been
no reasonable consensus, with the result Congress has repeatedly
failed to enact any of the various proposals.
Here therefore is an area where the Committee can exercise
real dynamic leadership from the very beginning of its work. The
necessary facts are readily available to the Committee and as
stated above, almost everyone agrees that maximum recycling will
never be realized unless and until the Federal Government supports
the very significant efforts already being made by the private
sector with (1) a workable tax incentive, (2) reasonable trans-
portation rates, and (3) a strong, affirmative federal procurement
program.
NARI believes most sincerely that a reasonable, workable
recycling tax incentive can and certainly should be enacted this
year — as part of the federal energy conservation program — if
the Committee will take a completely new, fresh, open-minded look
at the problem. In the past two years, both the House Ways and
Means and Senate Finance Committees favorably reported different
versions of a recycling tax credit, and there is every indication
both committees intend to try to resolve the issues involved when
they consider the President's energy tax proposals this year.
NARI also believes the transportation rate issue is now
ripe for Congressional solution. Pursuant to Section 204 of the
Railroad Revitalization and Regulatory Reform Act of 1976, the
railroads themselves were compelled to produce evidence last
year regarding rates charged throughout the United States for
the transporation of recyclable materials. That evidence demon-
strates beyond a shadow of a doubt that the prevailing rate
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Honorable Nicholas Humber
April 11, 1977
Page three
structure governing the movement of recyclables is exceedingly
discriminatory and unreasonable. Certainly, the Committee should
carefully consider all of the testimony and evidence produced
before the Interstate Commerce Commission in that proceeding,
and devise legislative proposals Congress can readily enact later
this year to resolve this problem which has existed for decades.
Again, NARI believes Congress is ready to act if the Committee
will offer a workable solution. During the past four years,
Congress has passed two separate Acts directing that all un-
reasonable, discriminatory rates governing the transportation
of recyclable materials be rectified.
Finally, Congress has already directed the Federal Govern-
ment to adopt new, workable procurement programs which mandate
maximum utilization of recyclable materials. NARI believes the
time has plainly arrived for the committee to enforce that mandate
as fully and as promptly as it possibly can.
In conclusion, therefore, NARI submits the Resource Con-
servation Committee has one of the most vitally important Con-
gressional mandates to fulfill in the history of our nation,
flhe Committee simply cannot afford to fail, and realizing this,
the national recycling industry is waiting anxiously to help you
in your work in every possible respect.
Looking forward to your advice as to how we may best
cooperate in this effort, we are
Sincerely,
NATIONAL ASSOCIATION OF RECYCLING
INDUSTRIES, INC.
Counsel
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NATIONAL COMMISSION ON SUPPLIES AND SHORTAGES
1750 K STREET, N.W., SUITE 800
WASHINGTON, D.C. 20006
March 17, 1977

Mr. Sheldon Meyers
Deputy Assistant Administrator
for Solid Waste
United States Environmental
Protection Agency
Washington, D.C. 20460
Dear Mr. Meyers:
Please excuse the delay in responding to your letter of March 4. We
are winding up the Commission's affairs preparatory to going out of
business at the end of the month, and there are more things involved
in this than I would have thought possible.
In a real sense, what your Committee proposes to do is a direct follow-
on to our Commission's work. We found that "a number of Government
practices effectively (if inadvertently) discourage recycling" being
"deviations from the principle that the rate of recycling should
reflect Informed decisions made on the basis of the cost of materials."
The legislation setting your Committee up requires you to take a
closer look at several of the issues we discussed including percentage
depletion for minerals, capital gains treatment for standing timber,
and product disposal charges.
As you know 1f you have seen our report, the Commission was unable to
find any convincing evidence that the depletion allowance either
reduced our import dependence or Increased total mineral supply. At
our public hearing, Commissloners repeatedly asked supporters of
percentage depletion whether they were aware of any such evidence, and
the reply was always in the negative. For example, 1n an exchange of
letters that took place as a result of our public hearing, Dr. William L.
Fisher, Assistant Secretary of the Interior for Energy and Minerals,
stated that the available data were Insufficient to permit quantitative
justification of the percentage depletion allowance for minerals (though,
of course, he supported its continuation even 1n the absence of such
information). He indicated that he was directing Dr. Hermann Enzer,
Director of the Office of Mineral Policy Research and Analysis, to
initiate analytical work on the subject. (This letter 1s reproduced
on page 96 of the enclosed volume.) Perhaps your Committee might try
to see that this commitment 1s followed up on. We certainly don't want
to end a tax subsidy that serves a useful public purpose, but paying
approximately $1 billion per year (and creating a modest disincentive
to recycling) as we do now based only on faith 1s ridiculous.
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With regard to capital gains treatment on standing timber, the
Commission felt that not enough was known about its effects to permit
us to reach a judgment on its retention. Here is another area where
work initiated by your Committee could prove most useful.
I am particularly gratified to see both a reference to product disposal
charges and, more specifically, to the importance of initiating a pilot
project on the topic. What is needed in this area at this time is not
more study, but hard experimental evidence. I think the wording of
the legislation setting up your Committee reflects that feeling, too.
Last summer a draft chapter of an EPA report titled "An Evaluation of
Product Charges as a National Solid Waste Management Tool" was circu-
lated to us. This chapter contains an extremely interesting and
apparently well-thought-out proposal for an experiment with a 1.3 cent
per pound charge on all paper an
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A
(^m>

cAfationaC 2o6d QAyast62LAAanag6mentu^2Sociation
1120 CONNECTICUT AVENUE, N.W • SUITE 930 • WASHINGTON. D C. 20036
TELEPHONE (202) 659-4613
EUGENE J. WINGERTER
EXECUTIVE DIRECTOR
April 11, 1977
Mr. Frank A. Smith
Resource Recovery Division
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460
Dear Mr. Smith:
On behalf of the National Solid Wastes Management Association, I would like
to express the Association's appreciation to you and your colleagues for the
opportunity to comment on the March 24, 1977 Draft of the "Implementation
Plan for the Resource Conservation Committee", relating to Section 8002(j)
of the "Resource Conservation and Recovery Act of 1976" [P.L. 94-580].
We recognize that the Resource Conservation Committee is developing strategies
for public participation in order to Incorporate the fullest possible range
of views 1n implementing the required studies and reports on materials con-
servation. We are encouraged by the attempts to include the Ideas of
Interested parties.
We are concerned, however, that one particular aspect of the public participation
strategy may not result in an adequate reflection of the views of all groups.
Specifically, we refer, on page 25, to the provision of grants to "several
public Interest groups to develop and disseminate information to their con-
stituencies and provide responses to the committee." Several of the groups
named represent governmental interests, such as the International City Managers
Association, American Public Works Association, National Association of Counties
and the National Governors' Conference. We feel that In order for a full range
of views to be represented, such private industry groups as NSWMA, Institute
of Scrap Iron and Steel, and the National Association of Recycling Industries
should be eligible to participate on an equal basis with their government-interest
counterparts.
We do not believe that the awarding of grants 1s an equitable or appropriate
policy for the Resource Conservation Committee to follow. Because there are
many Interests Involved besides those 1n government, preferential consideration
of governmental Interests through the grant mechanism would appear to bias the
viewpoints presented to the committee.
Many private Industry groups are directly affected by the wide range of Issues
related to materials conservation. To limit their participation 1n the Resource
Conservation Committee program 1s not 1n the best Interests of the conmlttee
NSWMA recomnends, therefore, that the RCC adopt a two-t1ered public participation
79
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Mr. Frank A. Smith
April 11, 1977
Page 2
strategy. On one level, an advisory group, made up of both government and
private industry interests, would communicate regularly with the RCC staff.
This advisory group would Include the organizations mentioned before, such as
NSWMA, ISIS, NARI, NACO, ICMA, APWA and N6C. On a second level of public
participation would be the previously-scheduled open meetings and review and
comment procedures which would allow all other interested particles to participate
in the work of the RCC.
Once again, on behalf of NSWMA, I appreciate the opportunity to comment on the
draft "Implementation Plan". We look forward to making a contribution to this
effort.
Sincerely
Michael F. H111
Director of Governmental Affairs
MFH/vr
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National Wildlife Federation
1412 16TH ST., N.W., WASHINGTON, D C. 20036	Phone: 202-797-6800
April 11, 1977
Sheldon Meyers
Deputy Assistant Administrator
for Solid Waste
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Meyers:
We appreciate the invitation to coaant upon the draft "Impl«mentation
Plan for the Resource Conservation Committee." We feel that, in general,
this plan does meet the requirements for this committee as mandated by
Congress under the Resource Conservation and Recovery Act of 1976.
Recognising the time constraints under which you are operating and the
desirable Intent to have the interagency committee function on a
consensus basis, your draft vas remarkably successful la covering the
broad scope of interest under this section of the Act. We note with
special interest the statement of Intent that this be "the first Cabinet-
level committee to address national materials policy Issues." We find
this to be in keeping with the National Wildlife Federation's objective
of the establishment of a comprehensive national materials policy.
(See attached Resolution #10.)
We do have some comments on this draft, both general and specific, which
we feel should be considered for incorporation In the final plan.
On page 4, "Policy Background and Principlest Reasons for Federal
Involvement," while we feel that the role of Interstate commerce is
implied, it should be explicitly stated as a major reason for federal
involvement in this arena. We would also change the phrasing of the
statement, "Past public policy distortions" to "Direct and indirect
effects of public policy either through intent or distortion." He feel
that a broad range of existing public policies most be examined, and
their effects evaluated.
On page 5, under "Free-market principles," we agree with the Intent to
preserve the free market system. However, we feel that the committee
must pTawing the extent to which the free market system has been
circumvented to cause interference "with the free choice of producers
and consumers to make their selections in a decentralized fashion."
On page 6, we applaud the enunciation of the "polluter-pays" principle.
We feel that this principle must apply to the complete consumption cycle
from production through disposal.
-------
National Wildlife Federation
Sheldon Meyers
-2-
April 11, 1977
On pages 9-11, under "Approach to Policy Development and Evaluation,"
performing the quantitative evaluations of various policy alternatives
as set down is essential. While it is delineated that these vill be
examined in relation to various effects upon "material recycling, waste
quantities generated and disposed of, on material and energy conservation,
and on environmental impacts," we feel that the effects of various policy
alternatives upon each other is essential. Many possible policy alterna-
tives may overlap in their effects. Few will be mutually exclusive.
Since we recognize that eventually there will be a combination of policy
alternatives required, we feel that some evaluation of the effects of
a variety of combinations is highly desirable.
Under Section III, the "Study Flan," we suggest that some additional
elements should be included. Under 2, "Effects of Existing Public
Policies," we feel that transportation policies other than freight rates
also have significant effects which should be evaluated. Under 3, "Product
Regulations as a Conservation Tool," in keeping with the free market
concept, effects of marketing and advertising practices should be
evaluated.
Comments on pages 13-17 concerning "Committee Work Plans" are difficult
without more specific data on the availability of funds and staff to
assist the committee. We feel that this is a quintessential consideration
in evaluating the potential for this entire study plan. We wholeheartedly
support the suggested procedure for public participation and congratulate
the Agency on its continued recognition of the Importance of public involves
If we can supply you with additional information or details on our contents,
please contact us. We look forward to assisting the Agency in providing
public participation in the development of this plan.
Sincerely,
Executive Vice President
Enclosure
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PAK-CENT
Packaging Consultants
G313 38 Street, N.W.
Washington, D. C. 20015
FRANK M. McMANUS	(202) 363-6034
April 6, 1977
Mt. Sheldon Meyers
Deputy Assistant Administrator for Solid Waste
U. S. Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Meyers:
This is in response to your request for comments on the
draft implementation plan for the Resource Conservation Committee.
In general, the plan seems to be a comprehensive one and one con-
sistent with the Congressional mandate.
I am concerned, however, that insufficient time is avail-
able for broad dissemination of the plan and comment thereon. As you
know, many membership organizations do not have the capability to
respond when less than a month is allowed. More importantly, the
Federal agencies may not have had adequate time to assess the plan
since the first formal meeting was on March 24 in the face of a report
due Congress on April 21. I would assume that the Committee had
made some changes in the draft implementation plan.
The principles set forth to guide the development of public
policy for resource conservation seem reasonable. With respect.to
the packaging industry, however, it has seemed to aany that EPA staff
have not recognized the complexity, variability, and dynamism of the
American distribution system. Some seem to feel that packaging per se
is an evil or an environmental insult.
We understand that EPA is preparing to recommend that
Congress adopt a system of taxes or charges on packaging which would
attempt to internalize the costs of disposal. In principle, this seems
deceptively reasonable. Other analysts may, however, differ as to
where, if at all, in the production, fabrication, and multiple uses
of packaging any pollution tax should be levied.
With respect to specific policies, all too often the
packaging industry has been cited as the principal contributor to
the solid waste stream. Well over one thousand bills have been intro-
duced in every State of the Union and in countless cities, towns, and
counties bearing on restricting one or more types of packaging.
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The packaging industry accepts a reasonable responsibility
for its share but too often feels that it has been unfairly singled
out. It would be self-defeating if the Committee proposed a course
of action that unreasonably singled out packaging for a unique type
of regulation.
With respect to use of Quantitative Analysis, once again
there exists a case in point that causes anxiety in the packaging
industry. Several agencies of the Federal Government — EPA, Federal
Energy Agency, and the Department of Commerce — have analyzed data
concerning the retumable-nonreturnable beverage container. We under-
stand that there are no fundamental differences on the data as to
the impacts of national deposit legislation, but there are profound
differences on the assessment of those data. Even now the General
Accounting Office is concluding a study of all the studies while at
least one other agency, the Office of Technology Assessment, has
finished its analysis of this issue. This one matter is so complex,
so dynamic, yet so persistently promoted that soae segments of the
packaging industry are justifiably skeptical of any study of this issue.
We encourage the broadest possible public participation
and review. However, we would urge that the Chaaber of Commerce, National
Association of Manufacturers, and perhaps professional societies whose
membership embrace a wide spectrum of producers and consumers as well
as academic members, receive as much consideration as environmental
and governmental organizations.
Incentives and Disincentives in the Study Plan could include
the impact of Federal purchasing policies since the Office of Federal
Procurement Policy has already stated that Federal agencies must review
their purchasing specifications to increase the use of recyclables.
The assessment of Deposits and Bounty Mechanisms should be deleted
because the principal threat would be to a narrow segment of the waste
stream, beverage containers, which have been studied ad nauseam. The
Federal Government might analyze its participation in the mandatory
and voluntary standajrds-making process of the dozens of organizations
which develop such standards.
I note with great interest that EPA spent almost a year to
convert the principle that "the costs of solid waste management should
be internalized in the prices of products." In order to assess and
comment properly, affected industry groups should have these materials
as soon as possible. It is not necessary to flesh out specifics before
"public review could begin."
Congress gave the Committee a mandate to "conduct a full
and complete investigation and study of all aspects of the economic,
social and environmental consequences of resource conservation
The detailed listing on page 12 does not reflect that Congressional
concern adequately.
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It is not clear to me where the Committee has a responsi-
bility for assessing the "political feasibility" of any Federal
proposal (see page 16). I suggest such assessment be deleted.
The Background surveys again reflect a continuing distortion
of EPA staff effort vis-Ji-vis the packaging industry. Five of the
six cited studies embrace broad conceptual issues in contradistinction
to another study on packaging.
We note with great interest that EPA will develop industry
models for various segments of the packaging industry. We urge that
EPA meet with representatives of key associations and corporations,
both large and small, to assure that the models properly reflect the
industries and/or segments of the industry. Models by necessity aggre-
gate data of large and small firms, new and mature firms, by providing
a model which may be inaccurate for a substantial segment of an industry
or labor force. Care must be taken to assure that these models include
an appropriate level of detail for analysts to weigh varying options.
Thank you for the opportunity to respond. I only regret
that we had insufficient time to make a comprehensive assessment of
the Resource Conservation Committee plan.
Sincerely yours*
Frank M. McManus
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SIERRA CLUB-ANGELES CHAPTER
2410 WEST BEVERLY BLVD., LOS ANGELES, CALIFORNIA 90057
Phone (213) 387-6482
April 8, 1977
Sheldon Meyers
Deputy Assistant Administrator for Solid Vaste
United States Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Jfyers:
Thank you on behalf of the Southern CHLifornia Regional Con-
servation Committee of the Sierra Club for the opportunity to
comment on the draft implementation plan of the Resource Conser-
vation Committee. In general I shall follow the format of the
Plan and comment by page number and heading.
Page
5 Ours is a mixed economy, but free market principles merit
special defense in the ease of small entrepreneurs. I refer
here not to the individual consumer whose "freedom of choice"
has so often been invoked on behalf of the non-returnable beverage
container, but to local producers of labor intensive products
often of natural materials whose use and disposal impacts the
environment minimally. Their products can be at a disadvan-
tage relative to mass produced and promoted b£ environmen-
tally less desirable plastic products and containers.
7 Market conditions, availability of labor and materials and
many other factors have always operated to keep jobs,pro-
ducts and profits in a state of flux. As policies change,
industry will seek to maximize profits under a new set of
86
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Sierra Club - 2
circumstances. Labor retraining or transfer aid should be
available through government-supported programs to workers
displaced for any reason.
An environmental consideration in transitions should be to
minimize waste. For example, when retooling for production
of a resource saving container, not only should the amount
and type of material in the product be considered, but the ma-
terials required for the new machinery, the transportation
(crates, box cars, rails, etc.), and the recyclability or
disposal of old and new production systems.
8 (line 3) Social benefits and costs are the final line to the
above judgments. "The benefits of the policy1' must be judged
not only by standard economic criteria but in long-terra so-
cial values which certainly include environmental benefits
such as the preservation of open space, adequate air and
water standards and even in the long run a balanced ecosystem.
10	(2.) Ve concur that policy should be set expeditiously so
that specific proposals can be considered, such as a survey
of conspicuous wastes. Examples: unsolicited throwaway mail
consuming hundreds of tons of paper daily, tossed away un-
opened for burial in an overflowing landfill; novelty items
of negligible social value which clutter public places, etc.
Ve must set goals for air, bnd and water quality and assume
responsibility for the stewardship of resources for the pub-
lic good, now and in the future. An awareness of these con-
cepts of public good must be widely disseminated and discussed.
11	"...the benefits of conservation"—to continue—need to be
expressed in terms of the quality of life, of natural habi-
87
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tat, and even of asthetics.
(4.) Phase-in time is sometimes extended unnecessarily to
maximize profits. The beverage container industry, for ex-
ample, had in many cases prepared for the elimination of flip-
top can openings well in advance of the date prescribed by
certain state laws and could easily have spared the public
undue hazard.
Policies
1.)	Fiscal procedures tend to be arbitrary and complex to
administer. Subsidies have favored large corporations. The
paperwork alone discourages small companies from applying.
In the energy field, individual contractors have profitably
entered the residential solar heating field without subsidies.
Similarly the secondary materials industry has operated pro-
fitably for years. The used materials market would be helped
most by requiring the specification of more recycled materials
in contracts, as under (3.), product regulations.
Internalized charges for product disposal must be admini-
stered so that those charges are specifically allocated to the
intended use. Deposits, on the other hand, are self-operating
and accomplish their purposes automatically.
2.)	All these listed public policies cry out for change. Many
perpetuate extremely resource-wasteful practices. The Sierra
Club requests the opportunity to provide input at the appro-
priate time. One comment (E.)—government R&D should not focus
solely on high technology systems. Another category (G.?):
public and workplace safety and material use (OSHA).
3.)	Product durability: probably most vital for major appli-
ances. Current studies show that style changes, favti.ly mobi-
lity, difficulty of repaS^f and many other faoti|0rs affect length
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Sierra Club - 4
of product usage, aside from durability. Social factors must be
considered along with standardization of pnoduct parts, ease of
repair and design for recyclability.
27 Please alLow adequate time to prepare comments on draft reports.
Some final considerations:
The economic and employment consequences of resource depletion
without controls or government involvement must be borne in mind,
particularly when potential piitical repercussions operate to inhi-
bit regulation.
Modifications in life style and an increase in government con-
cern are unavoidable as population increases enforce the need to
live within limits of available resources. It would be unrealistic
to minimize such changes which, if approached constructively, might
even enhance the quality of life. Good policy'planning can help
overcome the stereotyped view that material consumption signifies
progress. Resource conservation is well served by the encouragement
of appropriate technology at the individual and community level.
Grassroots public input and effective public relations should help.
Respectfully submitted

Fredrika E. Bernstein, Solid Waste chair,
Southern California Regional Conservation
Comnittee, Sierra Club
copy to Paul Swatek
Reply to 14710 Sutton Street
Sherman Oaks, CA 91403
W01527
SW-618
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