Page A10 The Virginian-Pilot Wednesday, February 14, 1973 To Encourage Recycling President Nixon is convinced-if his words are to be taken at face value that "We can no longer afford the indiscriminate waste of our natural resources; neither should we accept as inevitable the mounting costs of waste removal. We must move increasingly toward closed systems that recycle what are now considered wastes back into useful and productive purposes." And William D. Ruckelshaus, administrator of the Environmental Protection Agency, asserts: "The principal obstacles to resource recovery are economic and institutional, not technological. We are going to have to stop subsidizing virgin (new) materials' use and take steps to assure that secondary materials can compete on an equal footing." Well, Mr. Ruckelshaus's agency recommended such steps last August-in a report to Congress that the Office of Management and Budget has not yet released. The study's authors recommend (1) an end to freight-rate disparities that discriminate in favor of raw materials and against scrap, (2) granting subsidy payments of tax incentives to promote the re-use of municipal and industrial solid waste, and (3) removal of the Federal requirement that buyers attention be called to any "waste" material in products. Steel, oil, glass, aluminum, brewing and soft-drink, timber, and container industries object to the proposals to limit packaging, ban nonreturnable containers, and modify the liberal mineral-depletion allowances that encourage mining and drilling for oil. It is unlikely that depletion allowances will be reduced sharply or that returnable containers will become mandatory. We are facing an era of heavy dependency upon Middle Eastern oil and domestic drillers are demanding incentives for exploration. Shoppers regard throwaway containers as convenient. Still, it ought to be possible to reduce the handicap junk travels under. It costs 21⁄2 times as much to ship a ton of steel or iron scrap by rail than it does to ship a ton of iron ore. It takes four tons of bauxite ore to make a ton of aluminum, so three tons of waste must be disposed of at the mill. By contrast, a ton of aluminum cans can be re processed with only 300 kilowatt hours of electricity, but it takes 16.000 kilowatt hours to make a ton of new aluminum. Energy savings on a smaller scale, but considerable nonetheless, are possible in using recycled steel. And some 14 million more gallons of water are needed to make a thousand tons of new paper than to make a thousand tons of recycled paper. The water comes out polluted in each instance-but more polluted when paper is being made from virgin timber. What the nation would have by recycling is not peanuts. The Office of Management and Budget should hasten its review of the Environmental Protection Agency report and forward it to Capitol Hill. States find problems in developing highway environmental action plans Some states could have all federal-aid highway funds cut off later this year unless they move ahead quickly in developing planning processes that assure adequate considerations for economic, social and environmental effects of highways, The state action plans, which are in response to the 1970 federal highway act, are due at the Federal Highway Administration (FWHA) for review by July 1 and must get federal approval before November 1. But at this stage a number of states say they are unsure just what FHWA wants The highway administration issued guidelines to the states last June outlining four basic criteria each state must meet in its action plans: a kit of tools such as hearings, meetings and advisory groups to use at various stages of the planning process. Leading the way. To help the states develop their programs, FHWA assisted with pilot plans in Pennsylvania, Florida and Nebraska. "Pennsylvania's action plan is really an expansion of our present activities, not a new set of procedures," says Louis E. Keefer, the state transportation de partment director of the bureau of advanced planning. "We are calling on an enlarged citizen participation program beginning at the system planning stage." Now citizen participation is mostly at the project state. In the public meetings, citizens will be asked to comment on community • Actively seek involvement of the goals and objectives to help determine community at all stages. • Identify social, economic and envi ronmental impacts and assure there will be capability to study them. Take an interdisciplinary ap proach. • Offer alternatives, including public transit and building nothing. Each state must develop its own action plan. This is in lieu of the federal government handing down specific guidelines. land use patterns on which the transportation plan will be based. Lash says that about half of the states are expected to have problems building up a staff to carry out the guidelines requirements because many are going through austerity programs. Pennsylvania's action plan estimates that about 40 new positions in the state Michael Lash Get public in early transportation department would have to be created. Texas, on the other hand, sees no need to reorganize or add personnel. However Mare Yancey, state highway engineer for administration, says "I see problems ahead, and I think they will come in what the federal requirements will be for citizen participation." FHWA faces another potential prob lem: Filing an environmental impact statement on the action plans. The question is "under review," according to Lash. If it does become a requirement, "We would do them ourselves," he says. FHWA hopes that the action plans will decrease court challenges to proj ects, since they will emerge from an approved process developed with early public participation and hearings. At least 10 states "look to be in Nixon puts solid waste grants in the garbage trouble," says Michael Lash, FHWA director of environmental policy, but he refuses to identify them. "They waited so long and put so few dollars into it," he says. According to Marvin Manheim of Massachusetts Institute of Technology's Urban Systems Laboratory, which helped develop the FIWA guidelines. "I don't think highway people really understand the depth of change required to meet the FHWA guidelines." One of the toughest problems is how to involve the public realistically in the decision-making process early enough in the process. "It's not easy to pull a guy out of his living room at an early stage of development in a highway plan." Lash savs. "It will not be enough for a state plan to merely say officials will select an appropriate level of public involvement, depending on the particular project." says Lash. Instead he wants the action plans to spell out just how the public will be brought into each proj. ect. Manheim cautions states not to get hung up on techniques, but to develop The Environmental Protection Agency (EPA) is fighting a losing battle with the Nixon administration budget cutters over a $15-million program of financing solid waste demonstration projects. As a result, the Administration will propose legislation that will have no moncy for demonstration grants, even though such a grant program was in a draft bill developed by EPA last year. The EPA proposal, to replace the Resource Recovery Act of 1970 which expires in June, would have authorized EPA to make grants to states for demonstrating resource recovery systems and for building improved solid waste disposal plants. The new Administration proposal, marked "administrative confidential," was changed early this year. An internal EPA memorandum dated Jan. 9, 1973, says the draft bill has been changed to cut out funds for continuing EPA's planning and demonstration grant programs. Instead, the Administration wants to reorient the whole solid waste program towards finding ways to control toxic wastes. That, too, is a change in Administration thinking. Just last year, the White House was pushing for underground disposal of toxic wastes. Meanwhile, the Senate public works pollution subcommittee is planning solid waste hearings in April A subcommittee spokesman Siss there will first be an extensive look at how the solid waste program is operating. Then the committee will move into legislative proposals for a new law. Besides the expected Administration bill, there will be one from Sen Edmund S Miskie (D-Me.) that calls for spending húndreds of millions of dollars for a variety of efforts, including extensive grant programs for state and local planning, construction of demonstration projects, and construction of improved disposal facilities (ENR 1/25 p. 27). Sure to be discussed at the hearings is an EPA report that favors reeveling wastes EPA, in the report, says that recovery of material from wastes is "conceptually the best alternative to dis posal February 15, 1973 ENR 13 Thank you for the opportunity to comment on your proposed legislation which would amend the Resource Recovery Act of 1970. In general I agree that the long range approach to the solid waste problem must be one of reduced packaging and recovery of resources. Thus your bill is a welcome step forward in that regard. However, certain aspects may have implications for Maine that would reduce their value, and we would ask your serious consideration of these matters. First, may I make the philosophical note that another categorical grant program carries with it a certain level of suspicion. Such a grant program's success will depend in large measure on the type of administration and funding it receives over the years, an aspect that is often subject to numerous shortcomings. However, solid waste is a much more serious problem than most people are willing to admit, and your approach has the merit of calling attention and directing resources to its solution. To get more specific on the bill itself: Section 102 (a) (1) - I would question the use of the words progress and improvement in reference to packaging technology. What we really have had are changes in technology and marketing systems which have led to a proliferation of packaging. Reducing the amount of packaging should not necessarily imply a degradation in quality. (a) (3) By implication the wording of this paragraph immediately places the emphasis of the bill on urban areas, an emphasis which continues throughout. Not only would this be harmful to Maine, but it ignores the very real costs of solid waste management that accompany low volume, high mileage rural areas all over the nation where per capita and per ton management costs may well exceed those of urban areas and where the economics of resource recovery are much less favorable. Section 103 (For whatever it is worth, the numbering system in this section is not consistent with the others.) The definitions included are appropriate, but the phrase "solid waste management"is used a number of times without definition, possibly leading to some confusion. Section 104 No comment. Section 105 It seems likely that the December 31, 1973 deadline imposed on E.P.A. for reporting to Congress in this area is unrealistic, especially if, as seems probable, the bill would not receive approval before late summer. Section 106 (b) As written this paragraph allows several undesirable things to occur. 1. It gives a financial bonus to states which, for whatever reason, are ready to go quickly. This will probably mean states with resources to have been working on the problem already, or it will mean hastily planned programs. 2. It assumes that a statewide program is most suitable, and provides an incentive. In states like Maine it is quite possible that such an approach would be both politically and economically unwise. 3. With limited grant funds available many of the states most in need of assistance are likely to be shorted "at the trough". (c) (2) See comment #2 above. It certainly applies here. (d) (1) The purpose here is not entirely clear but at some point in the bill a provision should be made to require state approval on all grant applications from non-state agencies. Failure to do that will result in overlapping applications and a loss of state ability to encourage the best combinations of municipalities, short of legislative power to mandate. Section 107 Again the emphasis in this section is on resource recovery or at least on the improvement of technology (107) (c) (1) (B). It is probable that significant efforts in resource recovery or significant technological improvements would not occur in rural areas of states like Maine. The volume is too low to support such advances, land is usually available, and the travel distances required to centralize are often uneconomical. So, while some improvements might be made, we will usually be faced with sanitary landfill and relatively small regions or single town operations. But even this, properly done, would be a big step forward for a state like Maine, and an expensive one that deserves support. Such an approach should, in our estimation, encourage resource recovery and technology, where practical, but permit the Administrator to make grants where volume and markets considerations make it impractical. Thus a state like Maine would be assisted in its goal of reducing the public health and environmental degradation that results from mismanaged solid waste. Section 108 Once again this section probably leaves Maine out due to the emphasis on resource recovery. 40-687 O 74 pt. 3 68 The remainder of the bill applies to areas outside of our jurisdiction and experience. The sections on packaging and major items (111 & 112) really get to the heart of the matter and are sorely needed. Again, I appreciate the opportunity to comment on what is basically good legislation. I do hope, however, that you will consider these comments in relation to the law's effect on Maine and other state's in similar circumstances. If we can be of further help, let me know. Sincerely, Hallam Adam William R. Adams WRA: HEW:1dp |