The Honorable Jennings Randolph
August 8, 1974
Page 2

provide the Administrator with the benefit of expert technological advice by authorizing the formation of an advisory committee made up of experts from Federal and state governments, the academic community and industry. In dealing with non-hazardous waste, the states should be directed to institute waste management planning and control programs under general guidelines prepared by the Environmental Protection Agency.

The thrust of this legislation in both instances should be to place, to the greatest extent feasible, administrative authority in the hands of local/regional entities.

2. Any legislation should take into account the over-lapping of statutory and agency responsibilities and regulatory activities. For example, OSHA currently has jurisdiction over the safe handling of 'potentially hazardous materials within a manufacturing or processing facility. The Department of Transportation has jurisdiction over the proper transporting of waste materials and tire performance standards. The latter regulations could be in conflict with proposed Environmental Protection Agency disposal requirements.

3.

4.

We support the concept of a permit system but as the disposal
of solid wastes presents peculiar problems, we feel that such
requirements and considerations should be designated by
specifically tailored legislation and regulations separate
from the permit provisions of the Federal Water Pollution
Control Act of 1972. In addition, we feel that permits
should only be required of the disposal site operator.
Such a permit would automatically dictate what materials may
be disposed of at the site.

We support the concept of resource recovery, especially with
the timely implications it has for energy conservation.
However, we are deeply concerned with the concept of defin-
ing acceptable products, containers, and packaging based
upon wastes produced in their manufacture, or upon their
potential for resource recovery. The promulgation of such
regulations as proposed in Sections 111 and 112 of S.3549
in terms of their complexity, effect upon supply and demand,
and ultimately the functioning of our entire economic struc-
ture are adverse to the public interest. We strongly urge
the committee to carefully review and evaluate such far-
reaching considerations as to their practicability and
impact upon the economic system.

The Honorable Jennings Randolph
August 8, 1974

Page 3

5.

The value of demonstration projects in terms of pioneering new concepts and techniques and expanding existing technology and management practices needed for improved waste control cannot be underestimated. It is important to accompany such plans and innovations with a careful economic analysis of their effect upon the whole system. We would hope the committee would take the above into consideration.

6. In the case of the Federal Water Pollution Control Act of 1972, problems arose in implementation due to unrealistic deadlines. It is hoped the committee will take into account the problems created when unrealistic deadlines are thrust upon an administrative agency. The promulgation of regulations without the proper technological back-up are not to the best interest of the public and do not lead to effective solutions.

We would be happy to meet with you or your staff to discuss techniques and problems associated with solid waste disposal as relates to rubber and chemical products.

Sincerely,

Jobert D. Buchber

RD B: go

On May 31, 1974 you introduced Senate Bill 3560, the Solid Waste Utilization
Act of 1974. On July 9th, 10th and 11th, the Special Panel on Materials
Policy held public hearings on this bill. I shall greatly appreciate it if
you will send me four (4) copies of Senate Bill 3560 hearings.

Enclosed you will find a research report (original and copies) prepared
by me entitled "Towards a National Materials Policy". I shall sincerely
appreciate it if you could arrange to have my research report inserted in-
to the printed record of the hearings on Senate Bill 3560. Please acknow
ledge, by writing, your reception of my research report and that it will
so be published.

I am a planning aide with the Camden County Planning Department and also
serve as librarian and editor of its quarterly newsletter "Kaleidoscope".
A copy of it is being forwarded to you under separate cover together with
a Camden County map and a copy of our County Directory, all for your files.
Also under separate cover, I am submitting a copy of the Camden County
Comprehensive Plan adopted by the nine (9) member Camden County Planning
Board on January 24, 1974. Two reports, "Land Use Plan with maps" and
"Solid Waste 1970" which are components of the plan are being sent you.

Camden County's Board of Chosen Freeholders, the seven (7) member governing
body, established a Solid Waste Liaison and Information Committee. A com-
plimentary copy of their "Information Kit" is also being forwarded to you.
A principal staff member of the Camden County Planning Department acts as
secretary to this committee.

A RESEARCH REPORT PREPARED FOR THE UNITED STATES SENATE COMMITTEE ON PUBLIC WORKS

SPECIAL PANEL ON MATERIALS POLICY

JULY 9, 10, 11, 1974 HEARINGS ON SENATE BILL 3560

"THE SOLID WASTE UTILIZATION ACT OF MAY 31, 1974"

BY FRANK RODIO, JR., PLANNING AI DE

CAMDEN COUNTY, NEW JERSEY DEPARTMENT OF PLANNING

AND

L. LEON WUETHRICH, SECRETARY

CAMDEN COUNTY, NEW JERSEY SOLID WASTE LIAISON AND INFORMATION COMMITTEE