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July 17, 1974

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Wherever and whenever these programs of municipal

recycling and resource recovery come under discussion

of materials and/or energy tant person to be involved.

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the scrap processor is an impor

As an expert in recycling metal

lic solid waste, he knows the problems and possibilities better than anyone else. His advice is invaluable to municipalities exploring the possibilities in this new era of recycling and reclamation.

During 1973, the scrap industry processed and shipped record tonnages of scrap iron. The industry has always contended that obsolete scrap will move to processors for recycling when the economics become attractive, when the price paid to the processor is high enough to permit payment of higher prices to collectors. This happened during 1973 and is continuing in 1974. One obvious result is the near disappearance of the ubiquitous abandoned auto that often disfigures the countryside and produces headaches for municipal officials. The hulks disappear because the markets are

there

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it is economically advantageous for them to be brought to processor's plants for preparation into a raw material to be recycled by steel mills and foundries.

7.

Legislative Proposals Under Consideration by
the Public Works Committee

As the preceding discussion indicates, a number of

viable domestic industries have developed to collect and

process significant quantities of various discarded materials

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so that these materials do not enter the solid waste stream and, thus, do not require disposal at governmental expense. On the other hand, a clearly recognized governmental function traditionally has been the collection and disposal of garbage (solid waste) which is not drawn back into the industrial process by private sources.

The reduced availability of land and the increased need for domestically generated energy have created demands for new waste treatment and disposal centers which can reduce substantially the amount of waste requiring disposal and possibly can generate significant energy from solid wast Such disposal systems also raise the possibility of recovering quantities of recyclable commodities from solid waste as a by-product of the disposal system.

The Institute has reviewed the various proposals pending before the Public Works Committee with the functions of private industry on one hand and the function of governmentally administered or supported waste management and disposal centers in mind. In reviewing these legislative proposals, the Institute has focused on the broad implications of Federal support for waste management and disposal centers, rather than on the specific provisions of any bill. In summary, all bills are designed to provide assistance in the development of new waste disposal systems at the local level. Such support may be needed for research and development of the processes which can be utilized in these systems and

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for demonstration projects which test the commercial feasibility of various processes. */ Care must be used, however,

to assure that Federal funds are not used as a device for hindering or eliminating private industry from fulfilling its function of removing valuable recyclable materials before they enter the solid waste disposal stream. In authorizing EPA to promulgate solid waste disposal standards, the Public Works Committee should clarify whether these standards are to be applicable to all solid was e sources, to hazardous waste, or only to waste treatment and disposal centers.

8.

Research and Development and Demonstration
Projects

Because of the need to reduce the volume going to landfills and because the possibility of energy recovery from solid waste has become generally apparent only recently, the requisite technology might not now exist to permit an adequate evaluation of the economic feasibility or desirability of solid waste systems which recover solid waste or energy as

by-products.**/ Federal support for research and develop

ment and demonstration projects to test various processes clearly is warranted where the project is novel and not merely another application of existing technology since such novel ग

Much of the authority for such assistance already exists under the Solid Waste Disposal Act of 1969.

The technology generally under discussion is not new or unusual and, thus, does not need significant development or testing. Funds clearly should be available, however, for research into new methods of recovery.

40-687 - 74 pt. 33

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projects will provide a much clearer understanding of the costs and benefits of various forms of solid waste management. This research also should include an examination of the available and new markets for the by-product recovered from these waste disposal systems so that this material does not become merely a substitute for recyclable materials already being sold.

9.

Inter-Relationships Between Private Industry

and Solid Waste Treatment and Disposal Functions

In evaluating the form and scope of Federal assistance for solid waste treatment and disposal centers, it is important to re-emphasize that the purpose of these centers is to perform a legitimate public health function environmentally sound waste disposal. To the extent that energy

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or materials can be recovered and marketed for less than the cost of disposal of these materials, the costs of the waste management system naturally are reduced. If the public disposal system seeks to go beyond this by-product marketing, however, to siphon-off material traditionally acquired by the recycling industries, the disposal system is impinging on the legitimate role of private enterprise. In the long run, such competition will result in the destruction of a segment of industry unable to compete with the subsidized waste disposal system. Federal legislation previously has recognized that public funds, either in the form of a loan or grant, should not be utilized to foster competition with

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private industry unless the public policy favoring such competition is overwhelming and then such competition should be

limited to the extent necessary to meet this policy.*/

In accord with this general policy objective, any legislation adopted by the Public Works Committee should provide that no solid waste treatment and disposal center receiving direct or indirect Federal assistance under the Act may seek to acquire for processing materials not collected in the normal garbage and waste collection process for the area served by that center. Such a provision would prevent

the disposal center from diverting material which normally would flow to private industry.

A second requirement which Congress should insist upon in any demonstration project or other treatment facility seeking to recover resources, where the project is sponsored by the Federal grant or loan program, is that the appropriate Federal and local agencies be required to make a thorough review of the economic impact of the proposed project, similar to the environmental impact statement required under the National Environmental Policy Act [42 U.S.C. §4332(2)(C)], in which such matters as the availability of new markets for the by-products of the project and the effect of the marketing of these by-products on existing industries are considered prior to the commitment of Federal funds.

Sce, for example, 3(c) of the Urban Mass Transportation Act.

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