etters Abatemen tax credits
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.96 Environmental Science & Technology
DEARSIR: I woulc like to comment on the Editorial in the January 1969 issue, which urges the establishment of tax credits or similar incentives for pollution control for industry. Alth'ough we can all agree, I think, with the stated goal-sharing the costs of pollution controls equitably-I cannot immediately agree that your recommended tax credits are the best way to reach that goal. We all agree that pollution abatement will usually increase costs of production. The question is how to most equitably spread the burden of this added expense. Under a system of tax incentives, the costs are spread to all of the taxpayers. including those who do not use the particular product. You necessarily complicate the general tax structure, but, more importantly, you force some kind of bureaucratic determination of what portion of the manufacturing process constitutes the pollution control, since this portion will be subject to faster depreciation. Inequities can arise here. between different companies in the saine industry. and between different industries. It will require a n increase in bureaucracy to insure similar procedures, and it may discourage industry from devising processes which do not produce pollution in the first place. Further. it would require government inspectors to examine the industrial process in detail to determine which portion may be allocated to pollution control, and industry has a notorious dislike for having its proprietary processes examined by outsiders. The other alternative is to consider the increased costs caused by pollution control as an increase in the costs of an essential raw material, i.e.. water, and let it become part of the cost of doing business, just like increased costs of other raw materials and of labor. The eventual price will then be determined by the forces of competition in the free market place. One might well debate which of the two approaches is to be preferred. We have precedents for both in our system of taxing. For example, gasoline taxes which are applied to highway projects are paid only by people who drive
cars. O n the other hand, public works projects which are judged to contribute to the “common good” are paid out of general tax funds. A particularly interesting situation exists in the power industry, where cooling facilities add to the cost of electricity but rates are controlled by public utilities commissions. Max N. Edwards Assistant Secretary U S . Department of the Interior Warhington, D.C. 20240 Dual water supplies
DEAR S I R : Urban water resource development is becoming ;I matter of increasing national importance. In a reportreleased in January to the Office of Water Resources Research-the ASCE Urban Water Resources Research Program ( Harvard University) finds that the national investment need over the next 10-15 years will total well over S IO0 billion for municipal water facilities alone. To back u p this national investment need, which is mostly nonfederal, the Federal Government will spend approximately $149 million in fiscal year 1969 on water resources research, ranging from artificial rainmaking to soil conservation practices, advanced waste treatment, desalting, public health aspects, and planning research. It is important, therefore, to use every possible forum to point out problems. and to discuss approaches. solutions. and alternatives. 1. therefore, welcome Daniel A. Okun’s article. “The Hierarchy of Water Quality” (ES&T. September 1968, page 672). particularly if the dual water supply systems he advocates for cities of the future will lead to cleaner water for all uses. I have a n agg i n g s usp i c i on that 0kun ‘s ar guments might be used as an excuse to further pollute our already beleaguered rivers and estuaries when these are not used for drinking water supplies. For example. Okun says, “Dual systems would reduce the requirement for wastewater treatment because the receiving streams would not be a source of drinking water.” Other as some water uses, however-such oyster harvesting, fish propagation. and swimming-may require a quality of water as high as or higher, in some Mays. than drinking water supplies. These uses-protected by state and federal water quality standards-must
Write for Bulletin #132 ’Wa‘ste Disposal Systems”.
Circle No. 28 on Readers’ Service Card
Volume 3, Number 3, March 1969 197