Integrated waste management: An elusive goal

The Resource Conservation and Recovery Act of 1976 contributes to public understanding of two fundamental facts that were implied by earlier legislation, but it goes only part way toward the essential next step of requiring an integrated approach to the management of residuals (the wastes and other leftovers from the production process).

First, the law emphasizes that residuals will always be with us—that the terms "consumer good" and "consumption" do not imply disappearance of materials through use. It is misleading to say that after a good no longer provides the desired service or utility or satisfaction it is "thrown away." There is no "away"; mass does not disappear—the same quantity of material which originally went into the product is still in existence and must be disposed of. The passage of the 1976 act and previous solid wastes legislation of 1965 and 1970 recognize that our capacity to "throw away" is temporary and limited. Nearly fifty major metropolitan areas have projected an end of their landfill capacity within ten years.

Second, the 1976 act echoes the economic definition of a residual. It recognizes that there are millions of tons of materials which could be recovered physically, but are not recovered because the costs of recovery are greater than the value of the recovered materials—given present markets. These materials are deposited in landfills each year. Therefore, whether a material is reused or is a residual depends on time, the costs of utilization, and the relative prices of alternative raw materials.

Progress in 1976. The act marks an advance over earlier congressional thinking in two respects. It makes explicit the direct relationships among the three environmental media—water, air, and land. It points out that "as a result of the Clean Air Act, the Water Pollution Control Act and other federal and state laws respecting public health and the environment, greater amounts of solid waste (in the form of sludge and other pollution treatment residues) have been created. Similarly, inadequate and environmentally unsound practices for the disposal or use of solid waste have created greater amounts of air and water pollution and other problems for the environment and for health." The implications of this passage are clear. They point to the need for an integrated management approach covering all forms of residuals, material and energy, and all environmental media.

The act also makes explicit for the first time that once a residual is produced, additional material and energy are required either to utilize the residual in another production process or to modify its form to reduce the environmental impacts of disposing of it. Reduction in residuals generation (termed "resource conservation" in the act) is not only desirable but necessary. The act defines resource conservation as: "reduction of the amounts of solid wastes that are generated, reduction of overall resource consumption, and utilization of recovered resources." Reducing solid residuals generation by altering production processes, product output specifications, and the like, can have significant positive effects on energy use and on generation of gaseous and liquid residuals, and thus on managing air and water quality.

Although it seems to be simply good sense to encourage resource recovery and the reduction of residuals generation simultaneously, it is important to indicate that the two are not necessarily completely compatible over time. Recovery systems are capital intensive, and operating costs are high, even for small plants. For these systems to operate economically, a waste stream of guaranteed quantity and composition is required. Future reductions in residuals generation are likely to reduce the total quantity of materials and change the types of materials in the waste stream. Hence they may make recovery systems using presently known technologies uneconomic. This is not to say that recovery and conservation are incompatible, but only that an integrated program encompassing resource conservation (including energy), resource recovery, and residuals management is what is needed. Resource recovery systems themselves generate residuals, as do other production and use processes. The actions outlined in the act for the EPA administrator appear to be heavily biased in favor of resource recovery at the expense of resource conservation.

The unfinished task. The Resource Conservation and Recovery Act typifies the piecemeal approach taken by the Congress in environmental legislation, such as: the National Environmental Policy Act of 1969, amended 1975; the Clean Air Act Amendments of 1970; the Federal Water Pollution Control Act Amendments (FWPAA) of 1972; the Noise Control Act of 1972; the Federal Environmental Pesticide Control Act of 1972; and the Coastal Zone Management Act of 1972. The approach has been to pass separate legislation to address each area of concern, and as new problems are identified (toxic substances, for example), to pass new and separate legislation. Most of the legislative acts have required that residuals management plans be prepared for the problems addressed by the legislation. For example, Section 208 on areawide waste treatment plans and Section 303 on river basin water quality management plans are mandated by the water pollution control act, and state implementation plans and air quality maintenance plans are mandated by the Clean Air Act Amendments. In addition, it is also important to note that other legislation not commonly considered "environmental legislation" requires planning related to residuals management. Examples are the transportation plans required by the Urban Mass Transportation Act; the natural resource conservation plans required by the much-amended Bankhead-Jones Farm Tenant Act; and land use planning required by the Housing Act of 1954, amended by the Housing and Community Development Act of 1975.

All of these planning activities have typically (1) concentrated on a single environmental medium and ignored the intermedia effects; (2) involved only a small range of physical methods for improving ambient environmental quality; (3) involved only a small range of implementation incentives to induce residuals dischargers to change their behaviors; and (4) concentrated on physical methods and ignored the critical elements of legislation, implementation, monitoring, and enforcement.

To many observers, including some at RFF, it has been clear for some time than an integrated approach to residuals management is needed—one that explicitly considers in one management framework all residuals, environmental media, and interactions between and among both residuals and environmental media. None of the existing legislation, including the 1976 act, explicitly requires such an approach. It should be noted, however, that although not indicated in the legislation, the guidelines promulgated by the Environmental Protection Agency for planning under Section 208 indicate that the impacts of the plans on air and land quality should be evaluated. Consequently, planning agencies are to some extent required to produce a partially integrated residuals management plan. The degree to which these plans will incorporate consideration of solid and gaseous residuals and land and atmospheric environments is not known and is likely to vary greatly from plan to plan. Beyond that, there is no evidence yet to suggest that congressional initiatives for mandating integrated residuals management planning efforts will be forthcoming.