[GRRN] Fwd: The True Cost of Landfilling

From: Bill Sheehan (bill_sheehan@mindspring.com)
Date: Thu Jul 20 2000 - 15:00:33 EDT

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    -----Original Message-----
    From: RecycleWorlds <anderson@msn.fullfeed.com>
    To: jtrnet@valley.rtpnc.epa.gov
    Date: Thursday, July 20, 2000 8:56 AM
    Subject: Re: JTRNET digest 638

    Mike McGonagle writes in regard to the running
    controversy over the proposed study design by three EPA
    economists to determine the true cost of landfilling.

    "Unfortunately, the uncertainty surrounding such
    damages makes it extremely difficult to estimate these
    external costs. In fact, it is these uncertainties that
    probably lead to less than optimal host community fees in
    some cases. Arguably though, some of these costs are
    captured through the potential liability for future costs
    associated with such damages and by RCRA regulations
    requiring landfill operators to set aside funds for post
    closure maintenance. I'm not trying to argue that these
    mechanisms sufficiently account for such costs; previous
    discussions on this list regarding RCRA point out some
    significant flaws. However, I would suggest that there is a
    significant portion of these costs accounted for by our
    current policies and system of legal recourse.

    The National Recycling Coalition Policy Workgroup
    which I chair has been studying this issue extensively
    over the past year. It has been our conclusion, based in
    significant part upon the statements by EPA's own
    technical experts during the development of 40 CFR 258
    (the Subtitle D MSW landfill regulations) -- before the
    final political compromises in the ultimate rules where
    overlaid over that technical evaluation -- that the only
    thing which the liner and cap barriers, leachate and gas
    removal and monitoring systems accomplish (if done
    properly) is delay the onset of environmental impacts for
    some period of time after closure hopefully after the
    financial assurance instruments no longer are required to
    be maintained. But that length of time is a small fraction
    of the time the waste load remains a threat to the
    environment. Effectively our policy of SHORT TERM
    isolation we have moved out in time enormous
    environmental impacts from our kids and left them for
    our grandkids. It may very well be among the worst
    possible solutions by acting to deliberately isolate waste
    during the time the load is being monitored and
    supervised and pushed most of the decomposition and
    leachate/gas generation activity out to a time when there
    is not likely to be anyone responsible to care for the
    attendant problems. Don't misunderstand us though. We
    are not intending to be critical of EPA. At the time, they
    moved the ball very far from where it had been before
    when the country was dotted by unengineered dumps and
    open burning. It's just that now that we've had 10 years
    to reexamine how well we've done, it's time to move to
    the next stage. Hopefully, that can be done without
    political compromises that the agency had to make in
    1991 that undermine necessary environmental protection.

    That is to say, if one does not discount impacts on future
    generations as irrelevant to us today, it is not the case that
    the RCRA rules account for "a significant portion of
    these costs". They account for very few of them.

    Resolving this fatal flaw ought not be all that
    complicated. What needs to be done is not an endless
    series of regression modeling preceded by much
    econometric teeth gnashing. We need to proceed post
    haste to figure out what brand new environmental
    strategy ought to be used for our waste stream. The
    answer seems to lead to some program that would bar
    land disposal of organic material that is the source of the
    leachate and gas generation.

    >From there the question will probably divide between
    some form of waste-style pretreatment of the discarded
    MSW stream (whether in site or above ground) or
    separation and composting. That is where we think the
    debate should focus.

    Some of our statements to EPA in this regard are posted
    on our web page www.nrc-recycle.org.

        Peter [Anderson]

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