Re: Draft EPA letter -additions
Fri, 22 Jan 1999 16:19:47 -0500

Here are elaborations of the two points I would like to see in the letter to
--Bill Sheehan

1. Add to end of first paragraph:

We applaud EPA for setting a national goal, but we urge EPA to set a
waste reduction rather than recycling goal, and we urge EPA to set a far
more ambitious goal. Specifically, we believe that 50% reduction of waste
by the year 2000 is attainable, followed by 100% reduction (zero waste) by

Add where appropriate:

We request that EPA change the focus to waste reduction rather than
recycling because reduction of wasting in landfills and incinerators is the
appropriate goal from an environmental and economic perspective.

Measuring recycling is far more difficult than measuring reduction in
wasting (waste going to landfills and incinerators). But more importantly,
reputed increases in the national recycling rate in the past decade have
had only a minor impact on wasting, according to data published by both
EPA and BioCycle magazine. We are wasting (burning and burying)
almost as much per capita as we were ten years ago. This trend is not
sustainable, and focusing only on recycling rates obscures this fact.

Establishing and achieving waste reduction rates and goals, on the other
hand, requires increased waste prevention, reuse and composting, as well
as traditional recycling.

2. Add somewhere else:

We request that EPA work to revise Subtitle D of the Resource
Conservation and Recovery Act (RCRA) to require landfills that will
protect groundwater for as long as wastes remain a threat.

Subtitle D regulations require a landfill design that attempts to isolate
wastes using plastic sheeting and compacted soil/clay liners to keep
wastes dry and contain any leachate within the landfill. Keeping garbage
dry will require maintenance and periodic replacement of the cap in
perpetuity, not just for the arbitrary 30-year period set by federal law.

Today's landfilling regulations transfer the economic public health and
environmental burdens associated with groundwater pollution to future
generations. They also postpone pressure on society to develop viable
long-term discard management alternatives.

RCRA needs to be updated to develop landfills that will protect
groundwater for the long term. Landfilling is the cheapest option for
managing our discarded resources only if the costs of perpetual
maintenance and the associated groundwater contamination are ignored.
Requiring the full costs to be paid by those who generate garbage will aid
the evenmntual elimination of landfills (and incinerators), which must be
our national goal.