to be a proper function of the Federal Government to provide large loan-guarantee underwriting bulwarked by the creation of artificial markets which will require Federal subsidy for the indefinite future. There are private re-cycling plants operating successfully, right now in various parts of the country. Perhaps their activities could be strengthened through more appropriate Federal action such as tax incentives and/or accelerated depreciation. In essence, we support a policy whose primary objective should be a reduction in the amount of waste generated. We recognize that this is not a simple problem and that it does require continuing research for its solution. But, we would encourage the Committee to search for a means of establishing financial disincentives to the production of Solid Waste as a fundamental goal while, at the same time, continuing research and development programs and aid to the States and Communities to assist them in the establishment of resource recovery systems. With respect to the possibility of the Federal Government assisting in some way in providing Federal markets for recycled products, we agree that it might be appropriate to do so, as a matter of public policy, but that this should be done only within specific limitations, such as are identified in Section 110 (2)(b) of S. 3549. It appears that this also might be an opportunity to furnish incentives to those industries which produce no extraneous solid waste by equating their products with the Federal procurement opportunities envisioned for recycled goods. In summary, we recommend the deletion of Sections 216 and 217 from S. 3560; the revision of Section 216 to eliminate loan guarantees to private borrowers; and the substitution for Section 217, of Section 110 of S. 3549, with an additional proviso that the Federal procurement policies to be applied to recycled products shall apply in like manner to equivalent products whose manufacturing process contributes no extraneous solid waste matter. ***** ENVIRONMENTAL HEALTH AROUND THE WORLD 1600 PENNSYLVANIA DENVER, COLORADO 80203 PHONE (303) 222-4456 OR 222-5118 NATIONAL ENVIRONMENTAL HEALTH ASSOCIATION NICHOLAS POHLIT, MPH PS EXECUTIVE DIRECTOR July 26, 1974 Senator Jennings Randolph, Chairman Panel on Materials Policy C/o Senate Committee on Public Works Room 4204 Dirksen Senate Office Building Dear Senator Randolph: This is in reference to your letter dated July 3, at which time you invited the National Environmental Health Association to submit a statement for the record on the following bills and related legislation: S. 3560, Solid Waste Utilization Act of 1974; S. 3549, Energy Recovery and Resource Conservation Act of 1973; S. 3277, Energy and Resource Recovery Act of 1974; and Ten copies of our statement, "COMMENTS ON SENATE BILLS 3560, 3549, 3277 and 1086 by the NATIONAL ENVIRONMENTAL HEALTH ASSOCIATION," are being sent to the Senate Committee on Public Works. We certainly appreciate your kindness in allowing us to give the Senate Committee of Public Works our views, which we feel will be an asset to this nation. COMMENTS ON SENATE BILLS 3560, 3549, 3277 and 1086 by the NATIONAL ENVIRONMENTAL HEALTH ASSOCIATION In recent years it has become quite clear that one of the major costs of urban growth has been the accumulation and concentration of increasingly intractable wastes. The problems are most apparent in their symptoms: dirty air, defouled and contaminated rivers, and the lack of safe, adequate disposal sites for solid wastes. There has apparently been little understanding or recognition of the interrelationship of these problems, for the solution of air pollution problems may create water pollution and solid waste problems. The same is generally true for solutions of water pollution or solid waste problems. In other words, the waste may be changed from a liquid to a solid or gaseous nature depending on whether it is burned, buried, dewatered or impounded and leached into our ground and surface waters. Until recently Congress and the Executive branches of government have recognized the national significance of the Federal role in air and water pollution control and has supported these programs with planning and construction grants, technical assistance to State and local governments, research and special studies and program grants to States to implement their Statewide plans. However, comparable support to solve the solid waste problems have not been forthcoming. In 1965, Congress passed the Solid Waste Disposal Act (PL 89-272); and it stated that the major reasons for the passage of this Act was the recognition that air and water pollution resulted from improper solid waste disposal, the continually increasing volumes of discarded materials and the waste of natural resources as a result of the failure to reuse these resources. The Act also recognizes that the problems emanating from solid waste disposal are national in scope and necessitate Federal action through financial and technical assistance and leadership in the development, demonstration and application of new and improved methods and processes to reduce the amount of waste and unsalvageable 40-687 74 pt. 3 57 materials and to provide for proper and economical solid waste disposal practices. This Act and its amendment, the Resource Recovery Act of 1970 (PL 91-512) initiated a national program to plan for local and Statewide solid waste management systems to protect the environment throughout the Nation. This initiative must not be lost. Solid waste programs are being developed by many local, regional and state governments; and it is of utmost importance that the technical capability available in the Office of Solid Waste Management which took over eight years to develop not be lost at this crucial time while Congress is deliberating on the merits of Senate Bills 3560, 3277, 1086 and 3549 and the House of Representatives on H.R. 12567. It is therefore essential that the current legislation be extended with appropriate funding until Congress has time to develop adequate legislation to cope with the national problems of solid waste management. In reviewing Senate Bills 3560, 3549, 3277 and 1086, it is apparent that the intention of Senate Bills 3560 and 3549 is the broadening of the scope of the Solid Waste Disposal Act as amended by the Resource Recovery Act of 1970 so that current solid waste management problems existing throughout the nation may be adequately met. This is clearly stated in the "Declaration of Policy" in S. 3560, the "Findings and Purposes" in S. 3549 and in S. 3277. Senate Bill 1086, however, would limit the national effort in solid waste management to hazardous wastes only. While this is a significant phase of the problem, it would be inadequate to meet the critical national needs of the overall solid waste management dilemma. To deal with the problems of collection, transportation, processing, energy and resource recovery as well as final disposal of all forms of solid waste materials, the National Environmental Health Association recommends the following to be included in legislation: 1. Congress and the Executive Branch of the Federal Government provide the necessary incentives for increasing the recovery of energy and materials from solid wastes and take positive action to broaden the markets for products manufactured from recovered materials. 2. Authorization and appropriations for adequate State solid waste management program grants for State programs which provide for development of area-wide systems, encouragement of improved industrial programs, stimulation of markets for secondardy materials and environmental surveillance and enforcement. 3. Authorization for the Federal government to establish operational standards for the management of hazardous wastes and minimum performance standards for the processing and disposal of all other types of solid waste. These standards to be enforced through Federally-assisted State solid waste management programs. Authorization for Federally-assisted training and educational programs for State and local officials. It is essential that the Federal Government strengthen its technical programs involving all aspects of solid waste management, including energy and resource recovery and disseminating this information to State and local 4. governments. 5. Provide for adequate funding for Federally-supported research, development and demonstration projects at a level necessary to develop and furnish the expanding technology required to deal more effectively with the increasing volume and complexity of solid waste. |