-----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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