False Economy: The Folly of Demand-Side Recycling

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This article is reprinted from ENVIRONMENT, Volume 36 Number 1, January/February 1994. False Economy: The Folly of DemandmSide Recycling By Christopher Boemer and Kenneth Chilton 1319 Eighteenth Street, 'HELDREF PUBLICATION

Transcript of False Economy: The Folly of Demand-Side Recycling

This article is reprinted from ENVIRONMENT, Volume 36 Number 1, January/February 1994.

False Economy: The Folly of DemandmSide Recycling

By Christopher Boemer and Kenneth Chilton

1319 Eighteenth Street, 'HELDREF PUBLICATION

cn

m

The Folly of Demand-Side Recycling

D uring a recent meeting with the Conference of Mayors and the National Association of Counties,

the chairman of the Senate Environment and Public Works Committee, Senator Max Baucus (D-Mont.), detailed his strategy for tackling the U.S. “garbage crisis” and ensuring markets for recycled materials: “If recycling is going to sur- vive and even prosper, we will need to do more-much more. The cornerstone of my strategy rests on the principle that I call ‘manufacturers’ responsibility for the life-cycle of a product.’ . . . Anyone who sells a product should also be re- sponsible for the product when it be- comes waste.”’ At the core of Baucus’s message to the mayors and county offi- cials is an awareness of the financial bur- den that recycling programs are placing on local governments. Increasingly, city officials are finding themselves in the precarious position of either discontinu- ing these enormously popular programs or discovering new sources of revenue to pay for them. As a senior environmental advisor to the Conference of Mayors framed the issue, “Recycling is a good thing, but it costs money. Money that could go for schools is being absorbed by increasing disposal costs. We are moving into the second phase of recycling, which is deciding who pays.”2

Baucus’s “responsible entity’’ ap- proach to recycling is one way to shift the financial burden of these curbside pro-

grams off local governments and square- ly onto the private sector. By legislating that industry take greater responsibility for its product and packaging waste, en- vironmentalists hope to stimulate the de- mand for recyclables and relieve munici- palities of the tons of collected but un- processed materials presently crowding storage facilities in many parts of the United States. As the debate over these “demand-side” programs widens and in- tensifies, policymakers and voters must

CHRISTOPHER BOERNER is the Jeanne and Ar thu r Ansehl Fellow at t h e Center for the Study of American Business a t Washington University in St. Louis, Missouri. KENNETH CHILTON is the deputy director of the center,

BY Christopher Boerner and Kenneth Chilton

Volume 36 Number 1 ENVIM

cities have been forced either to store the materials or to curtail the number of items collected. A number of cities, such as Seattle, have even reported oc- casions when source-separated mate- rials were actually sent to dumps or in- cinerators rather than recycled.’

As a result of this oversupply, scrap values for recyclables have fallen dra- matically over the past five years. Ac- cording to a study conducted by WMX Technologies, Inc., the world’s largest hauler and recycler of solid waste, the average price paid for recycled mate- rials has plummeted from $97 per ton in 1988 to $44 per ton in 1992 (see Fig- ure 1 on page 9). The same study puts the total cost of collecting and recy- cling materials at around $175 per ton, which suggests that, even when a buyer for recycled materials can be found, the price paid covers barely one-quarter of the collection and sorting costs.6

According to Bill Brown, director of environmental affairs at WMX Tech- nologies, “We lose money on recycling. It costs $150 to $200 a ton to collect from the curbside and sort household refuse. We might make $40 a ton from selling waste materials, and we might avoid $30 a ton of landfill charges. But [the] bottom line is that it’s not profit- able.’”

With more and more communities subsidizing these costly curbside pro- grams, elected officials are desperately trying to find some way to ease their al- ready strained local budgets. Forcing industry to take responsibility for prod- uct and packaging waste has been en- thusiastically embraced as a convenient way to pass along recycling expenses. The program that has seemingly be- come the paradigm for this “respon- sible entity” approach is Germany’s “green dot” law.

Germany’s Green Dot Program

Adopted in 1991, Germany’s “Ordi- nance on the Avoidance of Packaging Waste” requires manufacturers and distributors to take full responsibility for their packaging. Businesses through- out the distribution chain must collect, process, and recycle any packaging or

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containers sold with their product. The ordinance specifies interim recycling rates for 1993 and higher rates by July 1995 for seven different categories of packaging materials. By 1 July 1995, 80 percent of the specified packaging materials must be collected, and be- tween 80 and 90 percent of these items must be shipped on to recycling facilities (see Table 1 on page 10).

In an effort to cope with the enor- mous practical problems associated with meeting these requirements, ap- proximately 600 manufacturers and distributors have developed an inde- pendent system to manage packaging waste, the Dudes System Deutschland (DSD). This nonprofit company col- lects, sorts, and arranges for reproc- essing the packaging discards of mem- ber firms. Each type of packaging used is assigned a fee, based on its weight and material content, which must be paid by the participating com- pany. The revenue from these fees is used to cover the system’s operating costs. Only those items displaying the green dot that signifies that the pack-

age maker is a member of the program are eligible to be collected and proc- essed by DSD.’

Although the Ordinance on the Avoidance of Packaging Waste did not take effect until January 1993, DSD has been operating since 1991. Already, several problems with green dot have become evident. The primary difficulty is that the system is terribly expensive, partly because the organi- zational structure and operations of DSD do not control collection costs. DSD expects to collect and process 5.6 million tons of material in 1994 at an estimated cost of $2.6 billion, or 4.16 billion deutsche marks. The company’s cost of $460 per ton to collect and proc- ess packaging discards is roughly twice the cost of collecting and disposing of other German household waste. Har- vey Alter, manager of the Resources Policy Department at the U.S. Cham- ber of Commerce, conservatively esti- mates that the cost of the German pro- gram, prorated to the U.S. population, would increase U.S. municipal solid waste management costs by $4 billion a

FIGURE 1. Supply-side effects of U.S. curbside collection programs.

1988 1989 1990 1991 1992

YEAR

SOURCE: Waste Management of North America, Inc., “Recycling in the ‘90s: A Shared Responsibili- ty,” (Oak Brook, Ill.: Waste Management of North America, Inc., 1992).

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year.9 Moreover, DSD’s costs are based tion’s plastic recycling capacity by on the comparatively modest 1994 recy- 115,000 tons.” Much of this excess cling requirements. But the recycling was dumped on the world market,

A common rate for plastic packaging, for instance, straining the waste management pro- k

demand-side approach is the enactment of ‘ ‘ recycled content” mandates, or laws specifying what percentages of recycled materials must be used in manufacturing certain products.

jumps from 9 percent in 1994 to 64 per- cent by July 1995. Clearly, DSD’s costs will explode with the implementation of the 1995 quotas.

For a system that, prior to June 1993, was close to $300 million in the red, the burden of higher costs may be overwhelming. Indeed, the angst created in Germany over DSD’s financial woes has led many business and consumer groups to request that the collection of plastics be scaled back and that waste- to-energy incineration be permitted when recycling proves too expensive.

A second and perhaps the most damaging criticism of DSD is that it fails to address the true economics of recycling by attempting to recycle all packaging, regardless of costs and quality considerations. Even if the in- Duts of recovered materials are sup-

grams of neighboring countries even countries as far away as

and the

Pacific rim. In fact, the overwhelming glut of col-

lected but unrecycled material crowd- ing storage facilities led the German government in June 1993 to reorganize DSD and delegate responsibility for recycling plastics to a separate com- pany, DEKUR Kunstoff Recycling GmbH. Additionally, Germany’s min- ister for the environment, Klaus Top- fer, suggested that, in the short term, it may be necessary to incinerate or land- fill those plastics that cannot be han- dled using the country’s existing recy- cling infrastructure. Until the issues of cost and capacity are addressed, how- ever, the financial problems of the green dot program will likely continue.

plied to reprocessors for “free,” the remanufacturing costs may exceed the

u.s. State and Federal Initiatives

market price of competing virgin ma- terials. The fact that the volume of collected material in Germany has far exceeded the country’s reprocessing capacity reflects this marketplace real- ity. Last year, for instance, the Ger- man government expected that DSD would collect 100,000 of the 928,000 tons of plastic packaging consumed within its borders. Instead, 360,000 tons were collected, exceeding the na-

Although U.S. officials have yet to propose legislation as comprehensive as the German ordinance, the popu- larity of the “responsible entity” ap- proach to managing solid waste is very apparent in the rash of demand-side proposals that have been considered or enacted at both the state and national levels. Among the states, the demand- side programs that have been debated vary. In several instances, legislators

TABLE 1 GERMAN COLLECTINGy SORTING, AND RECYCLING REQUIREMENTS FOR PACKAGING

Collection quotas Sorting quotas Effective recycling Type of (percent) (percent) rates (percent) materials Jan. 1993 July 1995 Jan. 1993 July 1995 Jan. 1993 July 1995

Glass 60 80 70 90 42 72 Steel 40 80 65 90 26 72 A I u m i n u m 30 80 60 90 18 72 Card 30 60 80 90 18 72 Paper 30 80 60 90 18 72 Plastic 30 80 30 80 9 64 Composite

material 20 80 30 80 6 64

SOURCE: M. Raymond, Verpack VO: Germany’s Tough Recycling Mandate-A Warning to the Packaging bY~r!d &%!es! Ches!er, Pa.: Packaging Strategies, Inc., 1991).

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have simply banned materials that could not easily be reused or recycled, in effect forcing manufacturers to util- ize recycled or recyclable packaging materials. Maine, for example, pro- hibited the sale of products in packag- ing deemed to be unrecyclable. Aseptic containers, particularly juice boxes and milk cartons, were effectively banned because of the difficulty of recycling these multimaterial packages. Several other states, including Nebraska, New Jersey, Iowa, and Maryland, have or are considering product bans of their own.”

A more common demand-side ap- proach is the enactment of “recycled content’’ mandates, or laws specifying what percentages of recycled materi- als must be used in manufacturing cer- tain products. As of January 1993, 24 states, which together consume more than 60 percent of the newsprint in the United States, had minimum-content requirements for newspaper. Idaho and Virginia require that recycled materials be used in road construction projects. Five other states-California, Connect- icut, Maryland, Oregon, and Wiscon- sin-have content laws covering such items as telephone directories and glass (see Table 2 on page 12).12

Other, broader measures have been introduced in several states but not en- acted. Massachusetts’s Question 3, which was rejected by voters in 1992, and a resolution presently being de- bated in the New York legislature are notable examples. Both proposals man- date waste reduction and recycling goals that manufacturers must achieve by choosing among a “menu” of meth- ods, including reducing the quantity of packaging created, making packag- ing reusable, or utilizing a minimum amount of post-consumer material. 1Slassichusetts’s pi-opod, for exampie, would have required that packaging contain at least 50 percent recycled ma- terial by 2002. The New York measure, proposed by Assemblyman Richard Brodsky and Senator Nick Spano, goes one step further, mandating that all packaging sold in the state after 1996 be reusable, recyclable, or recycled. This legislation would place severe limita-

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tions on how manufacturers can design packaging. To manufacturers relying on modem packaging materials to pro- vide safe and wholesome consumer products, this menu of packaging re- strictions is not palatable.

At the federal level, the primary push for demand-side mandates has centered on Congress’s reauthorization of the Resource Conservation and Recovery Act (RCRA). Although other issues have preempted consideration of RCRA during the 103d Congress, bills were introduced in both the Senate and the House of the 102d Congress in 1992 (S. 976 and H.R. 3865) that would have established a “comprehensive national municipal solid waste poli~y.’”~ The comerstone of this policy, as outlined in S. 976, was a series of ambitious, though largely arbitrary, recycling goals for materials entering the waste stream-25 percent of all municipal soiid waste to be recycied by i995 and 50 percent by 2000. To achieve these goals, packaging users would have been required to reduce the amount of pack- aging consumed, reuse the package a specified number of times, or attain re- cycled-content goals. Among the con- tent requirements specified in the Sen- ate proposal were a @percent recovery rate for all paper products by 1995,

which would rise to 50 percent by 2000, and a recycled-content rate of 25 per- cent by 1995 and 50 percent by 2000 for rigid plastic containers.

By establishing such stringent man- dates, the RCRA reauthorization bills would have, in effect, forced manu- facturers to take greater responsibility for the waste they produced. The hope among some legislators was that, as re- cycled-content and reuse requirements increased the demand for recyclables, the value of these materials would in- crease. Only by artificially elevating scrap values, RCRA proponents ar- gued, could recycling be made profit- able and sustainable.

Such reasoning is fallacious in a number of important respects. First Although local -

conditions and higher than average tipping fees may alter these figures somewhat, state averages suggest that the compliance cost of content legislation is significantly higher than total disposal costs.

and foremost, it fails to consider that complying with RCRA's demand-side

instance, analyzed the previously men- tioned New York recycling proposal and found that the total compliance costs for firms doing business in New York would be nearly $1.3 billion an- nually. Simply to meet the documenta- tion requirements of this bill, manu- facturers in the state would be re- quired to spend between $600 million and $1 billion a year.I4 In Massachu- setts, a similar study of the defeated Question 3 found that the total cost of compliance would be approximately $500 million ann~al1y.l~

By examining landfill tipping fees in the Northeast, it is possible to learn how present disposal costs (Le., the cost of not enacting content legislation) relate to the compliance costs cited above. As expected, average landfill tipping fees vary significantly in differ- _. ~

proposals would involve enormous ent regions of the country; Massachu- costs to achieve few environmental setts charges approximately $55 for a benefits. A study conducted by Clay- ton of municipal solid waste and New ton Environmental Consultants, for York charges $63 per ton.I6 Given that

TABLE 2 STATE MINIMUM-CONTENT LAWS

State Material Recycled-content requirement

California Newsprint 50 percent by 2000 Glass containers Plastic bags

65 percent by 2005 10 percent for 1 .O mm bags by

1993 30 percent for 0.75 mm bags by

1995 25 percent post-consumer material

or 25 percent recycling rate or reusable/refillable 5 times or reduced 10 percent in content bv 1995

Plastic containers

Illinois Newsprint 23 Dercent bv 1993 Maryland Newsprint 40 percent by 1998

40 percent by 2000 Telephone directories hAL..--,,A lVllJD"",, Ne;*sfprint -- 5n pprcgn! by 2000 North Carolina Newsprint 40 percent by 1997

Texas NewsDrint 30 oercent bv 2000 3 -

Wisconsin Newsprint 45 percent by 2001 10 percent by 1995 Plastic containers

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Massachusetts sent 4.8 million tons of municipal solid waste to landfills in 1992, the disposal cost, based on the average tipping fee, was approximately $264 million. That is almost $236 mil- lion less than the estimated cost of complying with content legislation in that state. In New York, the adminis- trative costs of content legislation would exceed total estimated tipping fees by close to $200 million.I7 Al- though local conditions and higher than average tipping fees may alter these figures somewhat, state averages suggest that the compliance cost of con- tent legislation is significantly higher than total disposal costs. Lower tipping fees in other regions of the country would magnify these differences. There- fore, it is difficult to imagine demand- side legislation leading to significant cost savings over present disposal practices.

To understand better how the aver- age consumer is affected by content legislation, consider that, to comply with these proposals, manufacturers would have to alter dramatically how they produce and package their goods. Economic impact studies suggest that the increased costs to businesses of these changes could be quite signifi- cant. Because of recyclability and cost concerns, a margarine producer, for example, would likely switch from soft plastic tubs to aluminum containers. The incremental packaging cost for such a producer would increase by 25 to 50 percent." This extra cost would most certainly be passed on to consum- ers in the form of higher prices. One re- cent study found that the costs of com- plying with Massachusetts's Question 3 initiative could have cost that state's consumers as much as $200 per house- hold annually. l9

In addition to the immense cost of proposed RCR-4 chariges, such de- mand-side measures place a strangle- hold on packaging innovations. Forc- ing manufacturers to meet stringent recycling, reuse, or content require- ments necessitates that companies be more concerned with recyclability than with other packaging characteristics, such as weight, strength, and flexibil- ity. In many cases, manufacturers

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Shredded tires are mixed with coal and burned to provide the Argonne National Laboratory near Chicago.

would be forced to switch from multi- material packages, which are difficult to recycle, to homogeneous, single-lay- ered packaging. Multimaterial pack- ages, however, provide a number of corimercid and environmenrai benefits.

Tom Rattray, associate director of corporate packaging development at the Proctor & Gamble Company, for example, offers evidence of the con- sumer values and reductions in waste disposal provided by the development of the coffee brick pack-a packaging option that might ultimately have been disallowed under RCRA reauthoriza-

energy

E INVIR lONM

melted. rolled into sheets, and sold to can makers within 90 days.

Difficulty in

tion proposals. The brick pack, made of aluminum foil and plastic laminate, not only ensures product protection and freshness but also yields an 85-per- cent reduction by weight in packaging material per pound of coffee com- pared to the conventional can. If a consumer purchases 65 pounds of cof- fee in 13-ounce steel cans-assuming a 30-percent recycling rate for the can -14 pounds of steel will go to the landfill compared to only 3 pounds of brick-pack material. To achieve the same low weight of packaging material sent for disposal, people would have to recycle 85 percent of their coffee cans.”

The development of the Srick pack is precisely the sort of innovation that is discouraged under demand-side pro- posals. In attempting to expand the use of post-consumer materials, con- tent and reuse requirements codify in- to law how certain manufacturers must use recyclables. As a result, in- dustry has little incentive to develop more innovative and efficient uses for these recycled materials. As Reason Foundation’s Lynn Scarlett explains, “[Although] mandating use of recy- cled content by select manufacturers will boost their use of such materials, . . . [it] may actually deter entrepre- neurs outside the mandated end uses _̂_... frnm exploring ways of using these materials in other products such as

animal bedding, glassphalt [and] insu- lation. ”2‘

In many circumstances, simply re- covering the energy from packaging in a waste-to-energy incineration facility may be more economically efficient than recycling. Mandated content re- quirements, however, prevent these and other options from being consid- ered by manufacturers or local solid waste officials.

A final objection to the logic under- lying U.S. demand-side proposals is that they fail to address the fundamen- tal problems of the recycling industry: material flow and quality uncertainty. A report issued by the Recycling Advi- sory Council and the Chicago Board of Trade concluded:

Collection, processing and end-use of sec- ondary materials are all activities encoun- tering substantial barriers to growth. These barriers are due, in part, to: market uncer- tainties, regarding the adequacy and relia- bility of supply, . . . the consistency with which suppliers can meet consumers’ qual- ity requirements and the price that such materials bring. 22

Policymakers intent on improving the demand for recycled materials should focus their efforts on helping buyers and suppliers remove these barriers to long-term contracts. One effort to do just that is the Chicago Board of Trade’s plan to establish an electronic trading system for a number of post- consumer materials, including plastic, glass, and aluminum. This marketing infrastructure will encourage the es- tablishment of uniform quality stan- dards and specifications, will improve the lines of communications between buyers and suppliers, and, if allowed to develop into a futures-trading sys- tem, might help to stabilize the price of post-consumer materials. Such de- veiopments wiii be far more effective at stimulating demand for recycled materials than will arbitrary content mandates.

The False Premise of Demand-Side Proposals

Whether one is speaking of state product bans, the proposed RCRA re-

JanuarylFebruary 1994

cycled-content requirements, or Ger- many’s green dot program, all de- mand-side measures share the same fallacious premise that recycling is the only environmentally conscious way for the country to save scarce re- sources and avoid being buried in its own trash. The problem with this sim- plistic line of thinking is that it is based on many common misconceptions about the need to recycle.

The first of these misconceptions is that the United States is running out of safe and secure places for landfills. This notion is simply unsupported. A survey of half of the state of New York, for example, identified 200 square miles of acceptable sites for fu- ture landfills-enough to meet the state’s needs for more than 180 years, even if no recycling or incineration were to take place. Difficulty in siting landfills has less to do with a lack of geologically safe locations than with local opposition. Some of this public opposition is now being defused by of- fering “host fees” or other compensa- tion to the residents whose property values are diminished by locating a landfill or waste-to-energy plant in their neighborhood.

Part of the public’s resistance to the building of landfills and incinerators

stems from a second misconception, that these facilities pose significant health risks to the surrounding com- munities. Increasingly stringent con- struction and post-closure monitoring requirements, however, are reducing the already infinitesimal health risks associated with landfills. EPA esti- mates a risk of less than one cancer in- cidence in 13 years as a result of all currently operating landfills in the United States. The agency goes on to point out that modern waste-to-energy plants pose a cancer threat of less than one in a million. To put this in per- spective, Bruce Ames, a professor of biochemistry at the University of Cali- fornia at Berkeley, estimated that this health risk is equivalent to the chance of getting cancer from drinking one can of beer every eight years.*’

Perhaps the most pervasive misun- derstanding among the public is that recycling is an environmentally benign process that in all cases saves resources. Recycling, however, is a manufacturing process like any other: Raw materials must be collected, prepared for proc- essing, and manufactured into market- able goods. Although the process of re- cycling conserves some resources, it consumes others. Energy, water, and, often, chemical resources are alI inputs

The stipp!)J of used pkstics fsr cut;*?eighs the demsnd. Eere, p!m!ic csn:ainers are collected in a bin at a county recycling center in Eugene, Oregon.

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in the recycling process. Inevitably, this manufacturing process results in some waste. Deinking the used paper fibers from newsprint, for example, creates a chemical sludge that must be treated.

Policymakers should attempt to choose the waste management method that, on balance, is most cost-effective and efficient. To be sure, one must also consider the environmental im- pact of municipal solid waste manage- ment alternatives. Prices cannot be re- lied upon if one form of solid waste management creates environmental ‘ ‘externalities’ ’-environmental costs not reflected in the management meth- od’s costs. Ubiquitous federal, state, and local environmental laws and regu- lations, however, directly and indirectly affect the costs of landfills, incinera- tors, and even recycling. As a result, it seems that many, if not most, of these environmental “externalities” are in- ternalized, thus allowing decisionmak- ing to be based primarily on economic comparisons.

In the end, the Achilles heel of de- mand-side programs, whether German or American, is that they ignore one fundamental economic truth: Markets -even those for recycled products- work best when relatively free of gov- ernment intervention. Society can de- rive many benefits from recycling, but only when it is pursued in an econom- ically efficient manner. To determine whether recycling a particular material is a net gain or net loss to society, there is no better measure than the market prices for those resources. If environ- mental “externalities” are largely inter- nalized and if government intervention in the marketplace is kept to a mini- mum, resources will be allocated to their most valuable use as a result of the prices placed on them by the “invisible hand” of the marketplace.

The economic costs of demand-side recycling are being learned the hard way in Germany. Before politicians in the United States make a similar mis- take, they would be wise to consider a market-based alternative. Local gov- ernments should take a hard-nosed ap-

(continued on page 32)

ENVIRONMENT 15

proach to recyc!ing hy continuiflg tc!

collect those materials whose market value plus the costs of forgone dis- posal outweigh the extra costs of col- lection and sorting and by abandoning other, uneconomical curbside pro- grams. Local officials should not look to the state or federal governments to “fix” the demand side of recycling in order to bail out programs that are wasting taxpayers’ money. Shifting

ference of Mayors and the National Association of Counties, Washington, D.C., I April 1993. 2. J . Holusha, “Who Foots the Bill for Recycling?” New York Times, 25 April 1993, 3-5. 3. Nichols-Dezenhall Communications Management Group, Garbage, Trash, Refuse, Waste, Dkcards, Rub- bish & Junk: The Book 2 (Washington, D.C.: Nichols- Dezenhall Communications Management Group, 1992), 9; and K . Chilton and J. Lis, Recycling for Recycling’s Sake (St. Louis, Mo.: Washington University, Center for the Study of American Business, 1992). 3. 4. F. E. Allen, “As Recycling Surges, Markets for Materials Are Slow to Develop,” Wall Street Journal, 17 January 1992, Al ; The National Solid Wastes Man- agement Association, personal communication with the authors, 28 June 1993. 5. See S. Pattison, “Consumer Alert: Recycling Costs,” Consumers’ Research, September 1993, 36. 6. Waste Management of North America, Inc., “Re- cycling in the ’90s: A Shared Responsibility” (Oak Brook, Il l . : Waste Management of North America, Inc., 1992), 4. 7 . B. Brown, “The Money in Muck,” A Survey of Waste and the Environment, special section of Econo- mist, 29 May 1993. 8. A recent Canadian proposal draws on many of the same concepts embodied in the German system. Most notably, Canada’s National Packaging Protocol (NAPP) calls on industry to establish an organization (similar to DSD) to collect, sort, and process recycla- bles. Although presumably voluntary, NAPP would establish a commitment on the part of producers and users t3 reduce the amount of packaging discards sent through the waste stream. 9. Harvey Alter, Resources Policy Department, US. Chamber of Commerce, personal communication with the authors, 6 July 1993. IO. Recycling Times, “Germany’s Green Dot Pro- gram Rebuked,” 15 June 1993, 16. 1 1 . Recycled Paper News, “Maine Debates Lifting State Ban on Aseptic Packaging,” July/August 1993, 4. 12. C. Miller, “Recycling,” Waste Age, March 1993, 30, 32. 13. H.R. 3865, 102d Cong., 2d sess., 58. 14. Clayton Environmental Consultants, Economic Analysis of Proposed Packaging Legislation in New York: The Environmentally Sound Packaging Act, pre- pared for the American Plastics Council (Lexington, Mass.: Clayton Environmental Consultants, May 1993), 111-1. 15. Clayton Environmental Consultants, Economic Impacts of Question 3: The Massachusetts Packaging Initiative, prepared for Responsible Waste Management and Jobs Committee (Lexington, Mass.: Clayton Envi- ronmental Consultants, September 1992), IV-I. 16. Allen Blakey, Director of Public Affairs, National Solid Wastes Management Association, personal com- munication with the authors, 18 October 1993. Tipping fee averages are based on private landfa charges. Unlike many municipal facilities’ charges, private landfd fees usually reflect the full cost of the services they provide. 17. The amounts of waste generated in New York and Massachusetts were provided by Blakey, note 16 above. 18. Clayton Environmental Consultants, note 14 above: page 111-7. 19. L. Scarlett, Mandates or Incentives?: Comparing Packaging Regulations with User Fees for Trash Collec- tion (Boston, Mass.: Pioneer Institute, October 1992). 10. 20. Chilton and Lis, note 3 above, page 12. 21. Scarlett, note 19 above, page 6. 22. Chicago Board of Trade report of 7 April 1993, as quoted in W . B. Crawford, Jr., “CBOT Eyes Market for Recyclables,” Chicago Tribune, I O June 1993, Busi- ness Section, 1. 23. A. Logomasini, How to Manage America’s Trash: Privuie Soiuiioris io a Public Fr-ohki>i ( W ~ ~ h i i i g t ~ ~ ~ D.C.: Citizens for the Environment, 1991). 7.

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