LETTERS Shipping wastes (correction) Dear Sir: Oscar W. Albrecht’s article “Shipping Wastes to Useful Places” ( E S T , May 1976, p 440) contains basic factual errors on freight rate comparisons that make his conclusions on at least two important counts misleading. This is rather unfortunate, considering the obvious time, research and effort that went into this story. Where Mr. Albrecht erred in developing his thesis on the equity or lack of it in freight rates on competing primary and secondary materials was to cite statistics arrived at in a study by the Research Planning Institute (RPI) and Moshman Associates (pethesda, Md.). This study is inaccurate, at least as it relates to comparisons of freight rates on “aluminum scrap” compared with “primary ingot and pig”; and “paper waste” compared with “woodpulp”. In reality, the raw materials that should have been compared for accurate freight rate appraisals are: “Aluminum scrap” and “bauxite or alumina”; “Paper Waste” and “pulpwood”. As in the case of other recyclable scrap metals, aluminum scrap, and aluminum derived from virgin ore (i.e., bauxite and alumina-Standard Transportation Commodity Code Numbers 10513, 1051 1) are in economic competition for use in various product markets. Ingots can be made with either virgin or scrap materials, and these ingots are products and cannot be compared for freight classification purposes with the raw material from which they were manufactured. In this regard, Section 204(e) (2) of The Railroad Revitalization and Regulatory Reform Act of 1976 specifically defines the terms “virgin natural resource material” and “virgin material” to mean “previously unusedmetal or metal orewhich is or which will become-a source or raw material for commercial or industrial use.” In the aluminum industry, virgin bauxite and alumina and recyclable aluminum scrap are the competing “raw materials” from which aluminum ingot, pig, and other aluminum products are manufactured and processed. Correspondingly, paper waste competes directly with virgin pulpwood (STCC No. 2411410) and not with woodpulp, which is a product manufactured from pulpwood. Pulpwood is shipped from the forest to a paper manufacturer, who converts it into woodpulp; the fiber is then used in paper making. Similarly, paper waste is gathered, processed, and shipped to be manufactured into the pulp from which competing paper products are made. Section 204’s definition of the terms 726
Environmental Science & Technology
“virgin natural resource material” and “virgin material” also applies here. Additional recognition that paper waste competes directly with pulpwood can be found in the Interstate Commerce Commission’s order of April 7, 1976, Ex Parte 319 proceeding, wherein the Commission lists the competitive commodity for paper waste as pulpwood. I am sure you can appreciate the fact that in order to have valid data regarding the issue of equity and reasonablenessof current freight rates on recyclables, one has to base his analyses on comparable competing commodities. The results of the Moshman study, unfortunately, have been repeated too often and with equally misleading results. Hopefully, this letter will help set the record straight; indeed, it is to be hoped that the facts outlined here will find a place in the reference libraries of EPA and other agencies so that the inaccuracies will not be repeated in future articles, studies, and reports. John R. McBrlde National Association of Recycling Industries, Inc. New York, N.Y. 10017 Three R’s Dear Sir: The May issue of ES& T contains an excellent series of articles detailing resource recovery and reuse. Unfortunately, in the list of A/E firms active in the resource recovery field our firm, Betz Environmental Engineers, Inc. (B.E.E.) was not included. B.E.E. has excellent capabilities and is experienced in the “three R’s.” Jeffrey J. Houdret Betz Environmental Engineers, Inc. Plymouth Meeting, Pa. 19462 Three R’s Dear Sir: I would like to congratulate you on the special articles devoted to the topic of resource recovery (€S&T, May 1976, pp 422-442). The resource recovery field is one with great potential for providing solutions to environmental problems and energy and materials shortages; however, it has received unfavorable coverage in recent months because of the still-developmental problems of certain large-scale facilities that have been brought on-line. ES&T has presented a more realistic picture. The resource recovery industry has experienced a lull in its growth over the past year. As a contributor to the article, “The Resource Recovery Industry,” and of the MITRE report prepared for EPA, I
have been closely following industry progress for several years. Since the article and report were prepared nearly a year ago, they no longer realistically represent the industry’s position. The basic fact remains, of course, that the industry is looking for business opportunities; but what it has lacked to date have been some genuine successes upon which to hang its hat. The institutional and technical problems have been emphasized by the press more than the virtues and successes of industry efforts. As a result, and extra element of caution in both the public and the private sectors has preventedthe industry from continuing its aggressive stance of 1974-1975. (Note the fewer number of new municipal projects that have been promoted in the past year.) In short, the growth projections stated in the “Industry” article (€S&T, May 1976, p 425) now appear to be somewhat high. It will be a couple of years before each company is able to commit itself to “two new projects annually.” Progress is being made, however. The industry is using this waiting period to firm up its own positions and objectives, and out of it will come a stronger and betterunderstood industry. As an example, Combustion Equipment Associates and Occidental Research have now finalized the cooperative agreement that will benefit a number of resource recovery efforts. In addition, the financial community is firming up its role in the implementation process. The process may be slow but with patience and support of the Saugus and Haverhill, Massachusetts; Bridgeport and Hartford, Connecticut; Akron, Ohio, and other projects, the industry will indeed be able to offer the solutions it promises. Susan A. Schnelder Arthur D.Little, Inc. Cambridge, Mass. 02140 Three R’s Dear Sir: Your coverage of the solid waste field, particularly the coverage in the May 1976 issue, is of great interest to us. In that issue on page 426, Table 2 of the article by Chris G. Ganotis and Richard E. Hopper, a variety of companies are listed but not the name of our firm. We are presently active for the State of Connecticut solid waste and resource recovery program, and we have just completed the first phase of a similar program for the Hackensack Meadowlands Development Commission in New Jersey. Henry Gltterman Burns and Roe Industrial Services Corp. Paramus, N.J. 07652
