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Executive Order for Recycled Paper Products [2]
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AMERICAN
FOREST &
PAPER
ASSOCIATION
August 3, 1993
Ms. Katie McGinty
Mr. Ken Connolly
Office of Environmental Policy
OEOB Room 360
The White House
Washington, D.C. 20500
Dear Katie and Ken,
Thank you for the courtesy of your time, Ken, on Friday. As our industry has
repeatedly stated, TCF should be totally eliminated from the Executive Order and related
documents.
Also, as mentioned in our meeting, the U.S. pulp and paper industry began
conversations with you and others in the Office of Environmental Policy with the objective of
providing the Office with the Printing-Writing Paper Division's recommendation on how to
maximize paper recovery for recycling in their specific paper grades.
Obviously, it has been difficult for those not knowledgeable about paper industry
operations to understand the "less-is-more" concept. Less recycled content per printing-
writing sheet at this stage will bring many more commodity grade paper machines into the
recycled-content market and, thereby, produce significantly more total tons of recycling in the
printing-writing grades and in the overall paper industry. This is because the commodity
machines, representing two-thirds of the installed grade capacity, are the most cost efficient
and the least involved in the current manufacture of recycled content printing-writing papers.
More than 90% of all paper recycling gains since 1988 and into the foreseeable
future will be "post-consumer," since virtually all pre-consumer recovered paper grades are
already in use. Whatever the increases in overall paper recycling, at least 90% of that
increase will come from the post-consumer waste stream. This fact is inescapable regardless
of how terms are defined, however, impractical definitions can serve as obstacles and reduce
the rates of increase for overall paper recovery and recycling.
We provided with you the industry's generally understood definition of a "commodity
paper machine" which is based on the size of the machine (see attached). It is crucial to
understand that both uncoated and coated papers are made on these machines. The other
relevant point is that these machines are typically found in integrated paper mills -- mills
which have already made major investments in pulping operations tied directly to their paper
machines. It is the papers produced on these machines that are commonly understood to be
commodity grades of paper by our customers, Wall Street analysts, the industry and
environmentalists. If you cannot adopt a "50 percent OR 10 percent" approach for all
printing-writing grades, we strongly encourage you to include all coated and uncoated free
1250 Connecticut Avenue NW. Second Floor, Washington, DC 20036
Phone: 202-463-2700 Fax: 202-463-2785
Ms. Katie McGinty
Mr. Ken Connolly
August 3, 1993
Page 2
sheet and groundwood papers produced on these machines at these mills in your Executive
Order definition of commodity grades.
It must again be strongly stated that a 15% minimum post-consumer content standard
for paper produced by machines at these integrated mills will prevent many producers from
making capital investments in expensive, specialized equipment to process recovered fiber for
use in commodity printing-writing papers. While a greater minimum content level of recycled
fiber per sheet of paper may sound better, a 10 percent minimum will result in greater
consumption of recovered fiber.
Those who know best about the manufacture of paper are the papermakers,
themselves. They are the ones who have developed the AFPA Printing-Writing Recycled
Content Initiative to maximize overall recovery and recycling of printing-writing grades.
Under the Initiative, manufacturers have the flexibility to produce and our customers the
option to buy papers meeting either a minimum threshold of 10 percent post-consumer and/or
processed recovered fiber OR a minimum threshold of 50 percent recovered paper fiber, based
on fiber weight. The threshold minimums are designed to encourage the production of as
many grades of recycled content printing-writing paper as possible and use of the greatest
amount of recovered fiber in the production of printing-writing papers overall in the shortest
period of time.
The term "processed recovered fiber" recognizes the need for sufficient supplies of
minimally contaminated and economically available recovered fiber to run through new
processing facilities to recover the fiber for reuse in paper manufacture. Specialized
processing is required of these papers to remove inks, dyes, waxes, and water insoluble
adhesives, etc. before the paper can be used in the remanufacture of recycled content printing-
writing papers. Attached is the latest definition of processed recovered fiber under
consideration at the ASTM.
As you mentioned, the "environmentally preferable" section of the draft Executive
Order is based on policies established by the Office of Federal Procurement Policy (OFPP)
Policy Letter 92-4. However, the Executive Order goes well beyond the scope of that policy
letter without the benefit of public comment.
In the Executive Order, the environmentally preferable language "refers to products or
services that are less harmful to human health and the environment
The inclusion of
human health in this definition expands the category beyond that which was available for
public comment in the draft policy letter in March 1992. While the policy letter was
available for public comment and review, the Executive Order is not. In addition, the OFPP
specifically states "the Policy Letter is not intended to dictate manufacturing nor copying
Ms. Katie McGinty
Mr. Ken Connolly
August 3, 1993
Page 3
practices," - but the Order, in its current form, will dictate manufacturing practices, in our
case totally chlorine free (TCF), thus adversely impacting the overall paper industry.
The draft Executive Order establishes a framework for product testing that includes the
use of life cycle analysis. There is widespread acknowledgement that methodologies for life
cycle analysis are not adequately formulated for use in determining "environmentally friendly"
or "environmentally preferable" products and services, especially as they relate to human
health. In Green Report II, the State Attorneys General state, "Although product life
assessments or cradle-to-grave product analyses are expected to be extremely useful for
evaluating the overall environmental effects of various manufacturing processes and products,
the methodology for this type of assessment has not yet been fully developed." Similarly, the
Federal Trade Commission stated in the agency's Guides for the Use of Environmental
Marketing Claims, "These guides do not address claims based on a 'lifecycle' theory of
environmental benefit. Such analyses are still in their infancy and thus the commission lacks
sufficient information on which to base guidance at this time." Further, EPA, in its February
1993 Life-Cycle Assessments: Inventory Guidelines and Principles states, "Currently there is
no single correct way to conduct a life-cycle assessment."
We understand that EPA and GSA are about to sign a Memorandum of Understanding
(MOU) concurrent with the President's signing of the Executive Order, and that this document
involves purchasing criteria based on environmental preference considerations. We hope the
issues which are such concern to us about environmentally preferable designations in the
Executive Order are not repeated in the MOU.
The subjects we've discussed are crucial to our industry. We urge thoughtful
consideration of these issues in your modification of the final draft Executive Order. Thank
you.
Sincerely,
Cur
Red Cavaney
RC:mk
Enclosures
cc:
R.Rubin
A. Rivlin
C. Browner
Commodity Printing-Writing Paper Machine
A commodity printing-writing paper machine is rated at 200 or more tons per day of
production. The machine has a width of at least 200 inches, and runs at a speed of 2500 feet
or more per minute. Papers made on commodity paper machines include coated and uncoated
free sheet and coated and uncoated groundwood grades used in such products as magazines,
catalogs, copy paper, paperback books, envelopes, business forms, directories, etc.
The paper industry definition of a commodity paper machine is generally understood in the
graphic communications industry.
ASTM TERM TO BE BALLOTED
August 1993
Processed Recovered Fiber - n - (paper) fiber from recovered
paper material that has been treated, to the extent required, to
minimize the effect of inks, dyes, toners, waxes, water insoluble
adhesives or resins, or reactive, plastic, laminated or metalized
coatings on the paper product to be make from it; excluded from
this classification is fiber extracted from pulp substitutes or
fiber from material containing only starch, filler, fiber, dyes
when used in white tinting, fluorescent white dyes, water aqueous
dispersable materials or non-paper manufacturing materials such
as wrappers, baling wire, metal, glass and dirt.
July 1993 PaperAge 41
Guest Editoria
Pulp, Paper, and EPA:
Linking the Environment and the Economy
By Carel Browner
Administrator
U.S. Environmental Protection Agency
As I write these words. and as you
those pollutants and seek apportunities
suduce environmental risk in a coberent.
sead them. the importance of the pulp
for reducing them a the source through
coordinated way. At the same time.
and paper industry stares us right in the
Improved voluntary process changes.
EPA's clusters are intended to simplify
face. Without paper. newsprint. and
design modifications. and improved co-
compliance and lower COSES for regulat-
magazine stock. we would have much
emp efficiency. Preventing pollution be-
ad industries.
Browner
more difficulty communicating with
for in is genermed can reduce environ-
The clumer - have ⑉ up for the
each other advertising our products. or
memal risks. COSTA. and liabilities. while
pulp and paper industry shows the value
dearning about the world around us.
onen improving economic competitive-
of this kind of cross-media. cross-pro-
technology development worldwide and
Without the paper products used in
BELL. Pollution prevention also tends to
gram coordination The Pulp and Paper
the growing demand for environmental-
packaging and construction our society
have beneficial effects across all the co-
Cluster is coordinating the development
by friendly consumer products. in is pos-
would not be able to function. Indeed.
vironmental media - water. and land.
of several major rules that affect your
sible that a chlorine-free process for
the U.S. pulp and paper industry. which
I am committed 10 making pollution
Industry i.e., the revised effluent guide-
kraft mills will become available before
employs over 600.000 people and is the
prevention the guiding principal of all
line for wastewater discharges, the max-
the joint rule is finalized. La that case.
country's tenth largest industry mea-
our environmental efforts a EPA. and I
imum achievable control technology
the new process will be considered as
sured by the value of shipments. is an
applaud the pulp and paper industry's
(MACT) rule for air emissions. a rule
EPA develops performance standards
essential component of our national
significant efforts to date in pursuing
for land application of studges. and a
Besides setting a precedent for in-
economy
prevention opportunities in your facili-
hazardous waste listing determination
termal cooperation at EPA. the joint
AI the same time. according to in-
ties. Industry-initiated pollution preven-
for sludges.
pulp and paper rule also is a first in
dustry-reported data in EPA's Toxic
tion process changes and other facility
But in this case we are taking the
terms of industry / EPA cooperation.
Release Inventory (TR)). the pulp and
improvements have already reduced
closter concept a step further by actually
Individual pulp and paper companies.
paper industry is the third larges source
washewater loadings or dioxins and fu-
Imagrating the any and wear rules. This is
the American Forest and Paper
of toxic pollutants in the country. In
rans by approximately 75 percent at
the first time EPA has unempted a muki-
Association (AFPA). and the National
1991. approximately 620 pulp and paper
bleached papergrade kraft mills since
media. cross-program rulemaking. and
Council for Air and Stream
facilities released 242 million pounds of
the late 1980s. and have reduced load-
we have high hopes and expectations
Improvement (NCASI) have made
soxic pollutants mio the environment. An
ings to other media as well. I strongly
The benefits of 8 joim rulemaking
major contributions to the rule.
additional 56 million pounds WETE sent
support your pollution prevention ef.
could be substantial First since air and
I anthusiastically support this open.
off-site 10 publicly treatment
foru thus far and challenge you. as well
WEST rules will be proposed at the same
cooperative process. because it will re-
works or other treatment or disposal fa-
as your counterparts in other industrial
time. your industry can be more confi-
suh in a rule more likely to meet our
citities In 1991. your industry was the
sectors. to continue to make improve-
dent. more certain that the money you
long-term environmental and economic
largest source of chioroform pollution in
ments in the future.
spend to control pollution anday will BOX
needs I hope it provides the basis for
the United Sustes resulting in 91 percent
Besides emphasizing pollution pre-
be undercui by a new rule tomorrow
engoing cooperation with your industry:
of total national releases. and it was the
verion throughout EPA. I also want to
Second coordinated rulemaking should
and becomes 8 model for EPA coopers-
thard larges source of soluene accounting
make our more traditional regulations
increase the BET environmental gain and
aion with other industries as well
for 17 percent of all national releases.
more sensible Whereve possible. I
lower industry costs. while a the same
Clearly. as we work together 10
Clearly the pulp and paper industry
want to simplify them and reduce the
time reducing the chances of cross-media
meet our national environmental and
touches the lives of virtually every
transaction costs faced by regulated
transfers of pollution. Finally. improved
economic goals. we still have much 10
American. both economically and envi-
business In short. I want 10 reinvent
Agency tearnwork should reduce the COM
do. Environmental quality in the United
ronmentally Your industry is a source of
EPA and make the agency more respon-
of developing rules. an economic benefit
Suites is the envy of the world. but seri-
profits and jobs. and in is I source of en-
give to OUT "customers." one of whom is
the will be appreciated by all taxpayers.
ous problems remain unsolved The U.S.
vironmental risk Thus the question BY
the pulp and paper industry.
This joint rule will encourage m-
economy is continuing to grow: but more
face private business and government
For example. the Agency has begun
dustry to use pollution prevention not
slowly. more sporadically. and with less
agencies alike is straightforw and: how
to use a multi-media approach to reguis-
just end-of-pipe controls to meet re-
job-creating potential than any of US
do we maximize the economic benefits
sor) development which BY call "clus-
quired standards Although the rule will
would like.
of the pulp and paper industry. and how
ters." Traditionally. EPA has regulated
BOI specify process changes or specific
But I believe we're on the right
do minimize its environmental risks?
industries medium-by-medium as dif-
technologies. it will MY a level of per.
smck Government. including EPA. IS be
In the past. these two goals often
Gerent federal laws were passed to pro-
formance that may be met best through
ginning to work bener. as our recent ef.
have seemed contradiciory But those of
sect the air. water. and land. As we
a combination of pollution prevention
form with the pulp and paper industry
6 in the Clinion Administration believe
know. however. regulations to protect
process changes and add-on controls.
suggest Our support for volumery pollu-
the it is possible to spur economic
one environmental medium like water
You will be given the latitude to decide
tion prevention. OUT willingness 10 re.
growth in anys the are environmentally
sometimes do not eliminate pollution
which mix works best in which facility
think traditional regulatory procedures.
surainable. just as in is possible to pro-
but simply transfer it to another medi-
in developing options for the joint
and our commitment to support indus-
sec the environment in usit that boost
sm. as when wastewater studge is
rule. EPA also recognized the importance
try's to) flexibility in meeting mandatory
economic growth. We imend to do both.
dumped on land. Moreover. this regula-
of encouraging and accommodating fu-
standards signal important change, in
and our goals and methods can be seen
tion-by-regulation. pollutam-by- poliu-
ture technological advances. For exam-
how we are doing business a EPA I in-
to the approach we are taking to the
- approach can be complicated. con-
pk. from an environmental perspective.
tend 10 continue LO make changes. to
pulp and paper industry
Busing. and costly for business
estally chlorine-free processes have great
seievent EPA. to work with customers
First we intend to move beyond an
We BY moving to change this to
appeal. Yes I understand the technology is
like the pulp and paper industry in order
exclusive reliance os command-and-
change the any we do business by es-
BOI fully developed. While some milk in
to bink our assional environmental goals
control government regulations to re.
tablishing a series of closters with
the United States. Canada. Europe. and
more closely with OUT economic goals I
dure the environmental risks posed by
Agency representation across all
Scandinavis have developed processes
can think of no bener way to serve the
pulp and paper mills Improved control
media. These clusters are designed to
the - chlorine-free. no kraft mills have
President. the American People. or the
or treatment technologies at The end of
improve the quality of EPA's regulations
yes succeeded in making high-brightness
pulp and paper industry than by protect.
the pipe" b) themselves simply
and decisions by shifting the focus away
pulp from southern softwoods without
ing the American environment and the
won't he good enough We need to look
from individual rules and isolated ac-
using chlorine.
American quality of life.
"wp-tream" imo the process generating
tions and imegrated strategies that
However. given the rapid pace of
Circle No 17 on reader service card.
THE TOTALLY CHLORINE-FREE ISSUE
from an environmental perspective, totally chlorine-free
processes have great appeal. Yet I understand the technology is
not fully developed. While some mills in the United States,
Canada, Europe, and Scandanavia have developed processes that are
chlorine-free, no kraft mills have yet succeeded in making
high-brightness pulp from southern softwoods without using chlorine."
Carol Browner
Administrator
U.S. Environmental Protection
Agency
Paper/Age July 1993
"Despite the widespread research and development, and some
successful production runs, the consensus from the conference was
that TCF (totally chlorine-free) bleaching has not gained the
status of proven technology. Although several mills are producing
TCF grades of bleached kraft pulp for specialized niche markets,
there is no TCF process available which can produce, at competitive
cost, high brightness market pulp, with equivalent properties to
conventionally bleached pulp, from chips with a range of quality
that permits companies to use all available forestry residuals."
Pulp & Paper Canada 94:5 (1993)
Report on Worldwide Conference
on Non-Chlorine Bleaching
Hilton Head, South Carolina (3/93)
400 Attendees/25 Countries
COST/RENEFIT ANALYSIS or TOTALLY CELORINE FREE
(2CP) BLEACHING or PAPERWAYING WOOD PULPS
1. Wood provides the fibrous rav material for 92% of the world's
paper-making pulp; (more than 992 in the US.) US vood pulp
capacity represents more than one-third of the world total, almost
exceeding the SUB of the capacity in the next four countries -
Canada, Japan, the former USSR and sveden. The US is the largest
supplier of bleached chemical paper grade Fulp to the global
market.
2. Chemical wood pulping processes - dominated by the "kraft" or
sulfate process - account for two-thirds of the world's wood
pulping technologies. The recovery boiler system associated with
the kraft process recaptures the original pulping chamicals while
burning spent pulping liquors which contain non-fibrous residues
extracted from the vood. This process makes it possible for kraft
pulp mills to be largely bio-enargy self-sufficient. Additionally,
the kraft process produces pulp fibers which make papers with
stronger performance characteristics such as burst, tear and fold.
(Indeed the word "kraft" means "strong" in Garman.)
The other but minor chemical pulping process - sulfite - does
not commonly have a recovery system and poses an environmental
problem in the disposal of its vasta pulping liquors. In the global
mix of chemical pulping technologies, sulfite capacity has declined
in both absolute and proportional terms.
Mechanical pulping processes comprise the remaining one-third
of the world's vood pulping processes. While they produce so-called
"high yield" pulps - retaining the non-fibrous materials such as
lignin which discolors when exposed to sunlight - they do not have
the strength, Gurability and longevity of chemical pulps.
3. About half of the world's wood pulp manufacture is bleached in
order to brighten the naturally brown color of wood. A whiter paper
provides sharper contrast and clarity for black and colored
printing and writing. Further, by removing most of the remaining
natural wood impurities, bleaching adds to the inherent strength of
papermaking pulps and enhances the archival capability of the
papers made from chemical pulp.
4. For many years, chlorine gas (elemental chlorine) has been the
traditional agent for bleaching wood pulps. It has been not only
the lovest cost option but, of the currently available Commercial
1
wood pulp bleaching agents, it is the most "gentle" to the
papermaking fibers and to the mill machinery. substitution of
chlorine dioxide for elemental chlorine, coupled with extanded
dalignification with exygen, has been increasingly practiced in
order to reduce or eliminate the potential for generating
chlorinated organic compounds believed to result from a reaction of
excess elemental chlorine with precursers, including lignin. Pulps
bleached without elemental chlorine but with chlerine dioxide are
referred to as "ECP", is. elemental-chlorine-fres.
5. Certain pulp bleaching processes which use no chlorine-based
compounds at all are referred to as "TCF" ie. totally-chlorins-
free. These processes can involve exygen, ozane, hydrogen peroxide
and even pre-treatment of unbleached pulp with enrymes. Ozona is
the most "aggressive" of the alternative non-chlorine blasching
agents and calls for particularly sansitive process controls as
well as sophisticated metallurgy in the Bleaching plant.
The Ter bleaching processes typically result in a kraft pulp
which is less bright, has a higher dirt count and produce a weaker
papermaking fiber than from the ECP processes. Indeed, papermakers
in the primary pulp markets served by us producers reject TCF kraft
pulps because of these deficiencies.
6. The global market for bleached kraft paper grade pulp is
currently estimated at 29 million short tons, with global market
domand for TCF bleached kraft pulp currently amounting to perhaps
1.6 million short tons or a little more than st of total world
demand for bleached kraft paper grade pulps. Theoretical market
capacity to produce TCF bleached kraft paper grade pulps is
reported to be approaching 2.5 million short tons but clearly
actual production and capacity utilization rates reflect the such
lower level of current world denand.
None of the 12 bleached kraft pulp mills in 5 countries
reported to have TCP bleaching capability has committed all of its
bleaching capacity to TCP processes and regularly produce ECF pulp.
While one company has announced its intention to install TCP kraft
capacity in an existing US mill, there are currently no commercial
supplies of TCF bleached kraft pulp available from domestic
sources.
7. TCP deaand is purely a European market phanomenon, created
largely by the Garaan pulp and paper industry in response to a
Greanpeace initiative. The Garman industry itself could readily
accomodate the TC7 stipulation because it already manufactured a
TCP pulp in its otherwise absolete sulfite mills - a pulp which
produces a lover strength paper and which has significant
environmental problems.
2
8. Those producers of bleached vood pulps in other countries .
largely in neighboring Svedan and Finland . who have responded to
the Garman market deaand for TCF kraft pulp, (since Germany must
import 60% of its papermaking wood pulp " have done so at
considerable capital costs in order to develop a "niche" market for
their exportable pulps. Prior to the recent 308 devaluation of the
Nordic currencies, those ware the highest cost market pulps in the
world. Novever, in a currently vest global pulp market, consumers
are increasingly unvilling to recompanse those producers for their
higher TCF pulp production costs.
9. When, in 1985, the association of chlorinated organic
compounds vith the bleaching of vood pulp vas first detected, the
Swedish pulp sector elected to respond by modifying its production
processes because - unlike the US industry - it had not previously
installed effective, secondary treatment of mill effluents. As &
result, the US industry's success in addressing the environmental
quality of mill affluents is already ahead of the Swedish industry
which, incidentally, is able to comply with its regulation of AOX -
( a quantitative neasure of chlorinated organics in mill effluents)
-on marely an average basis and not an a "not to exceed" basis as
would be required of us bleached pulp mills.
10. Despite vidaspread research and development and the apparent
success of some TCP production runs, the consensus from the March
1993 Worldwide Conference on Non-Chlorine Bleaching vas that TCF
"has not gained the status of an environmentally sound, proven
technology." TCF processes are clearly more energy intensive than
ECF processes. It remains to be seen whether non-chlorine
bleaching processas would in fact result in any maaningful
environmental improvement over BCF processes since TCP processes
themselves generate unwanted and potentially harmful pollutants.
In that regard, acientific comparisons of bleaching process options
made by the Pulp and Paper Research Institute of Canada have
revealed that "the effluents from totally chlorine free
sequences
vere found to have the greatest chronic toxicity" to
fathead minnow larvas.
11. The proposed White House Executive Order which would direct
federal agencies to set future goals to purchase TCF papers
absolutely contradicts EPA's recent judgement that the best
available technology sconomically achievable (BAT) for US bleached
kraft vood pulp mills by 1998 is one based on a combination of
modified continuous cooking (MCC), the use of exygen
delignification and the substitution of chlorine dioxide for
elemental chlorine, all designed to result in AOX levels of less
than 0.5 kg. par metric tonne of bleached pulp produced. Pointedly,
EPA did not chose TCF.
The US pulp sector is already moving voluntarily in the
direction of the BAT prescription but the cost of converting all of
the existing US bleached Kraft wood pulp capacity to meet EPA's
water-related proposal has been astimated by the Stanford Research
Institute (SRI) to approach $5 billion.
3
12. It is important to understand that the process changes
required by the vater-ralated aspects of DA's proposed BAT
prescription would not provide an incremental step tovards TCF
bleaching should that process ultimately be required of US bleached
kraft pulp mills. Indeed, if the antire us bleached BUID sector
vare to implement the proposed BAT prescriptions by 2998 and then
subsequently have to switch to totally independent TCF
technologies, at least half of the estimated $5 billion cost of
meeting the water-related aspect of BAT through chlorine dioxide
substitution will have been entirely vasted.
In addition, a substantial pertion of the $1 billion already
spent by the industry over the last for years on process
acdifications to reduce its discharges of chlorinated organic
compounds . which relied heavily on chlorine dioxide substitution -
would also be vassed.
A subsequent svitch to the TCP bleaching option after
implemanting the BAT prescription would imposs at lasst an
additional capital cost on the us industry, estimated to axceed
$3 billion.
13. If us government agencies vere to specify TC7-based paper in
their purchases, they would be obliged to seet supplies from
foreign sources st significantly higher sost, incurring the
additional panalty of reducing domestic employment and a videning
of the nation's trade imbalance. Foreign producers with excess TCP
pulp espacity would walcome such a "Trojan Herse" as a seans to
anter the us market for bleached kraft pulp - the largest single-
country market for bleached kraft pulp in the world.
14. From an overall environmental perspective, there is the very
real prespect that 8 requirement of TCP bleaching processes on the
US pulp and paper industry would load to reduced paper recycling.
Civen the veaker performance characteristics of wood fibers
bleached with non-chlorine agants, their ability to withstand the
rigers of repeated recycling would be impaired.
15. The bleached kraft pulp sector of the US pulp and paper
industry has already voluntarily made significant strides in
improving che anvironmental performance of its mills. should The
White House send s signal through fedaral agencias endersing TCP -
after the IDA conterporaneously promulgated BY as BAT it would
certainly add confusion to the domastic marketplace, increase
uncertainty in the development of environmentally sound us
regulations and impose a competitive disadvantage on the world's
largest wood pulp and paper industry.
July 28, 1993
4
08/02/93 11:09 MPA 4632785
NO.840 P002
Magazine Publishers of America
575 Lexington Avenue New York, New York 10022 212 752 0055
MA
DONALD D. KUMMERFELD
President
July 28, 1993
Ms. Kathleen McGinty
Deputy Assistant to the President & Director
Office of Environmental Policy
Room 360
old Executive Office Building
Washington, D.C. 20501
Dear Ms. McGinty:
The Magazine Publishers of America (MPA) understands that the
President is considering issuance of an Executive Order requiring
federal agencies to purchase recycled content papers and "total
chlorine free" (TCF) papers. We also understand that, in the
Order, the threshold standard for recycled content for most
printing and writing paper grades (including the coated paper used
by most magazines) would be set at 50% total recovered fiber, with
a minimum of 15% post-consumer content, to be raised to 20% in
three to four years.
I. We urge that this Executive Order be reconsidered, and that the
Environmental Protection Agency (EPA) be allowed to continue its
process for developing reasonable federal procurement standards.
As you know, the Environmental Protection Agency is carefully
addressing many of the issues involved in this area. Through its
own activities and through the work of the Recycling Advisory
Committee (RAC), it has consulted extensively with paper producers,
paper users, and environmental groups to develop federal
procurement standards. We urge that EPA's deliberations be
permitted to continue without being by-passed by issuance of this
Executive Order.
In the EPA consultations, there has been a clear recognition that
coated and uncoated papers should not have the same requirements
since coated papers have unique challenges in using recycled fiber.
These challenges include the difficulty of coating paper that
contains contaminants present in recycled fiber and the need for
strong fiber, since part of the paper is composed of weak coating.
The RAC, in 1992, recommended lower recycled content levels for
coated papers; and, in March 1993, both the Environmental Defense
Fund (EDF) and MPA recommended to EPA that coated papers have only
a post-consumer standard, not a total recycled content standard.
II. While we support the federal goal of increasing the use of
recycled paper, we believe that setting the threshold as high as
50% total recovered fiber with 15% post-consumer fiber may actually
08/02/93 11:09 MPA + 4632785
NO.840 P003
- 2 -
impede the ultimate goal of increasing the use of recycled fiber.
Therefore, we oppose the contemplated 50%/15% standard.
First, the 50% total recovered fiber standard is clearly too high.
A recent Franklin and Associates study stated that a full 98% of
all pre-consumer waste paper is currently being recycled. Since a
federal procurement standard is likely to become a de facto
industry standard, a 50% total recovered fiber standard will likely
cause a shortage of pre-consumer waste paper to be used in recycled
paper both for government and for private industry. This will
result in the price of recycled paper being driven up, without any
guarantee that more material will be diverted from the waste
stream.
Second, lightweight coated papers containing 50% total recycled
fiber are not currently economically or technologically feasible
for large-scale producers who use large paper machines. As a
result, all recycled lightweight coated paper meeting the current
de facto industry standard of 50% total recycled fiber with 10%
post-consumer fiber are only produced on smaller machines owned by
smaller-scale paper producers. The resulting quantity is not
sufficient to supply high-circulation publications. For example,
while Time Inc. prints the Canadian edition of Time and five other
U.S. titles on recycled paper containing 50% total recycled fiber
with 10% post-consumer fiber, it is unable to obtain enough of this
paper to print its entire U.S. edition of Time on this paper, as it
would like.
Third, regarding the 15% post-consumer standard, it is questionable
whether many large mills will be able to reach this standard in the
near future, especially in high grades such as lightweight coated
paper. These mills were designed to use virgin wood pulp and
cannot efficiently substitute large amounts of post-consumer
recovered fiber (which contains contaminants) without causing
costly machine breakdowns. While progress is being made by paper
companies in producing coated paper in progressively lighter
weights with progressively higher levels of both pre- and post-
consumer fiber, there are significant technical difficulties to be
worked out.
By beginning with a 10% post-consumer standard without a 50% total
recycled content requirement, 'more mills would be encouraged to
make recycled paper, resulting in the use of a greater amount of
recycled fiber and the diversion of more post-consumer waste from
the waste stream. Thus, magazine publishers who cannot now buy
adequate supplies of recycled coated paper would be able to do so.
Fourth, a federal procurement standard may well be regarded as a de
facto industry standard and be incorporated into federal and state
environmental labelling laws. If the standard for calling paper
"recycled" is raised to 50% total recycled content with 15% post-
08/02/93 11:09 MPA + 4632785
NO.840 P004
- 3 -
consumer content, those publishers currently using "recycled" paper
with 50% total recycled content including 10% post-consumer content
(a considerable number) will have no incentive to use that paper,
and may well revert to using 100% virgin paper.
III. We believe that the Executive Order for printing and writing
paper procurement should contain a single standard of 10% deinked
fiber content.
The use of a deinked fiber standard or a "post-consumer or
comparable" standard, such as that recommended to the EPA by the
RAC, is important. All wastepaper containing inks requires
deinking for recycling, whether the wastepaper is pre-consumer or
post-consumer. Therefore, the distinction made should be whether
the paper is inked, rather than whether it has reached the hands of
the final consumer.
IV. we urge that an Executive Order mandating federal purchases of
"total chlorine free" (TCF) paper be reconsidered.
First, under existing production technologies, totally chlorine
free bleaching results in lower brightness and whiteness in paper,
with no guarantee that the alternative bleaching processes are more
environmentally benign. Magazines require coated papers with high
whiteness and brightness to produce the high quality images
associated with the medium. At the present time, this level of
whiteness and brightness can only be produced with the use of some
form of chlorine bleaching. A reduction of image quality would
place many magazines at a serious disadvantage in competing with
television and other media for advertising, thus threatening their
economic survival.
Second, there is no evidence that alternatives to chlorine
bleaching are more environmentally benign than certain chlorine
bleaching methods. As you may know, bleaching processes using
elemental chlorine result in the emission of dioxin, which is
harmful to the environment. However, bleaching processes using
chlorine dioxide result in a reduction of dioxin emissions to below
measurable levels. We know of no research evidence that indicates
that totally chlorine free bleaching (eliminating even the use of
chlorine dioxide) will result in further reduction of dioxin
emissions than is achieved through the use of chlorine dioxide.
MPA applauds the move by a growing number of paper mills to
substitute chlorine dioxide for elemental chlorine, thus reducing
dioxin emissions to below measurable levels. While we would
support a phased-in elimination of elemental chlorine, we urge that
alternative bleaching processes be studied more carefully before an
Executive Order mandating government purchases of TCF papers is
made.
08/02/93 11:10 MPA + 4632785
NO.840 P005
- 4 -
We strongly urge you to reconsider the draft Executive Order.
Enclosed is our statement on federal procurement standards,
presented at the public forum that was held by the EPA in March.
Sincerely,
Donald Kummerfeld
cc: The Honorable Al Gore
Mr. Thomas F. MacLarty
JAAKKO PÖYRY
JAAKKD POYRY CONSULTING. INC.
RECYCLED FIBER USAGE: A LOOK AT LEGISLATIVE AND OTHER TRENDS
Arthur C. Veverka
Jaakko Poyry Consulting
560 White Plains Road
Tarrytown, NY 10591
Presented at the:
1993 HARD COPY CONSUMABLES CONFERENCE
June 23, 1993
Good afternoon. I want to start by thanking bis strategic decisions for the opportunity
to address this conference. Although paper recycling is not the main theme of the
conference, I am pleased to be with you today to share the thoughts and perspectives
of the Jaakko Pōyry organization on the impact that legislation is having on recycled fiber
usage. In the course of this speech I will also touch upon other trends which are
affecting usage and will finish up by offering some observations on how we might best
proceed in the legislative arena with some very simple programs.
Let me begin by pointing out that the usage of recycled fiber by the U.S. Paper Industry
has increased dramatically over the last three years. In 1990, the industry utilized just
under 22 million tons of recycled fiber. By 1992 this figure had climbed to over 26 million
tons - - an increase of approximately 20% or 4.3 Million tons. This advance was sparked.
by four major factors. First and foremost is the industry's commitment the use of
recycled fiber. This commitment is both real and permanent since the industry has had
to invest millions of dollars in order to be able to use these increased quantities.
Market demands have also accounted for some of the increase. As long as people want
certain types of products with certain characteristics, includir 3 recycled fiber content, the
paper industry has a history of responding to the marketplace.
Mandatory recycling laws have help to create new and additional supplies of recycled
fiber. This in turn has encourage the industry use this valuable source of raw material.
Lastly, the threat of legislative action has caused the industry to voluntarily use more
recycled fiber rather than face the possibility of some ill defined legislative requirements.
The increased use of recycled has been centered on three major grades. In newsprint,
a de facto 40% usage of recycled fiber has been more or less accepted as the industry
goal without any need for legislative requirements. The containerboard industry has also
increased its used of recycled fiber primarily because of technological advances which
have made possible incremental capacity additions for which recycled fiber was the
1
JAAKKO POYRY
JAAKKO POYRY CONSULTING. INC.
perfect choice to fill the fiber needs. New capacity additions, based almost exclusively
on recycled fiber, have fueled its use in the tissue area - the third of the product or grade
areas.
However, in the printing and writing grades - the grades of most importance to the
participants in this conference . the increases have been relatively small. in total, it would
appear that only about 200,000 - 300,000 tons of additional recycled fiber have been
used in these grades over the period of the last three years.
But why the lag in recycled fiber usage in printing and writing grades? There are two
primary reasons. First there is tremendous confusion over standards, guidelines, criteria
- call it what you may. This confusion essentially leads to inaction on the part of the
industry because they are not sure what it is they are going to have to comply or try to
comply with, and they are not sure whether or not it might change in the near future. The
second reason is a decided lack of economics for the use of recycled fiber within the
printing and writing sector of the industry. Let me expand on both of these points.
On the legislative side, Federal, state, and local legislative and regulatory 8 Ctivities fall into
three main categories. The first is solid waste reduction which includes separation of
materials for recycling, mandatory recyclables collection, and product bans. All of this
is driven by the perception that we are running out of landfill space and something must
be done about the crisis.
The second category is minimum content standards. Here the object is to establish the
minimum threshold level below which a product cannot be called recycled or to mandate
a minimum level of recycled material to be used. Normally, there is some kind of
proposed penalty on the manufacturer or seller if the minimum content requirement is not
met.
Procurement preference laws are the third category. These laws are aimed at
establishing or promoting markets for recycled products. Preference laws set up rules
and regulations whereby government agencies can purchase recycled content paper
even if it is more costly than the virgin fiber based products.
Most legislative activity is directed at reducing the amount of material entering the solid
waste stream. A secondary target is the establishment of mandatory recycling programs.
Solid waste reduction goals at the federal, state and local levels vary between 25-50% to
be achieved in the next 5-10 years. These laws are causing greater amounts of material
to be collected and are attracting new companies to the marketplace for collecting,
sorting, cleaning, and marketing of wastepaper.
2
JAAKKO PÖYRY
JAAKKO POYRY CONSULTING. INC.
State and local regulatory activities have taken a variety of approaches to solid waste
reduction and recycling issues. However, most states allow local municipalities to meet
source reduction or recycling goals in any matter they see fit. Only four states actually
require municipalities to report their progress . minnesota, california, new jersey, Id
rhode island.
On the federal level, the primary bill governing solid waste management is the resource
conservation and recovery act (or rcra). Although the potential reauthorization and
proposed amendments to rcra were not passed in 1992, they could get new life in the
clinton/gore administration. These new amendments, if passed, could have significant
implications for the supply and demand balance of recovered paper within the U.S. The
rcra amendments would have set national goals for 1995 and 2000. The bill establishes:
A 10% source reduction of waste by the year 2000
Recycling of 25% of the municipal solid waste stream (with certain
exceptions) by the year 1995
2000. Increased recycling of the municipal solid waste stream by 50% the year
Some of the bill's other provisions have strong implications for the recovery of paper, as
well as specific directives for encouraging demand for recycled paper products. Among
those affecting the paper and paperboard industry are minimum annual recovery rates
that would have to be achieved by the year 1995. Under the bill, if these overall rates
were not achieved by the deadline, the epa would be required to set minimum recycled
content standards for those grades not in compliance. These proposed minimum
recovery rates are as follows: newsprint- 52%, corrugated containers . 60%, mixed paper
- 20%, high grade deinking - 50%, and pulp substitutes - 100%. It should be noted that
all of these minimum recovery rates are well within the limits of what we believe are the
maximum practical recovery rates for these paper grades.
This provision of RCRA, is an attempt to put the american forest and paper association's
(AFPA) recovery goal of 40% into law. However, afpa does not set specific end use
product recovery goals, even though several products are likely to achieve the RCRA
recovery rates. The only goal is an overall 40% recovery of both pre-consumer and post-
consumer paper. Interpretation of the rcra amendments seem to indicate a 40% recovery
of post consumer paper - a much more difficult goal to reach by 1995. By the time the
reauthorzation actually happens, 1995 and 2000 goals set in the current amendments
would likely be revised to later years.
Other existing regulations and guidelines at the federal level are already having an impact
on the demand for recycled content paper. Many of these regulations are aimed at
government purchasing requirements. The Environmental Protection Agency (EPA) has
issued a rule mandating the use of recycled content paper by any government agency
(state or local) using at least $10,000 of federal funds. The Federal Trade Commission
3
JAAKKO PÖYRY
JAAKKO POYRY CONSULTING. INC.
issued guidelines in 1992 to prevent the false or misleading use of terms such as
"recycled content". The joint committee on printing has set policy guidelines and general
specifications for paper purchases by the government printing office, the general services
administration and other federal agencies. in 1990. this committee issued four new
recycled paper specifications for:
offset book
groundwood forms bond
plain copier paper
25% bond paper
The first three of these specification require a 50% secondary fiber content with post-
consumer fiber encouraged but not required. The last specification requires that 75%
recovered materials must be used of which not less than 25% must be either cotton or
linen fibers. Again, post-consumer fiber is encouraged.
Many of the state, and also local, initiatives in the recycling areas have been aimed at
market development. These include;
price preferences which allow government agencies to pay more for
recycled content product.
paper procurement goals which set some sort of target levels for
purchasing recycled fiber products
tax credits for direct investment in recycling facilities
outright grants and loans to encourage people to invest in recycling
technical assistance, mainly in the collection and sorting area.
Earlier I mentioned there was some confusion over the standards for recycled grades for
printing and writing papers. Let me briefly elaborate on this. The debate is over three
specific areas.
First what should be the minimum content level, that is, the level of recycled fiber
contained in in a product, in order for it to be called recycled?
Second, should both pre- and post-consumer materials be included in the recycled fiber
specifications or standards?
Third, should there be 1 or 2 standards? That is, a standard for total recycled content
and/or a standard for post-consumer content.
To make matters worse there are a multititude of standards or guide!ines being
pulmagated by what appears to be an alphabet soup list of agencies. Some of these are
industry groups, others are private companies, some government agencies, and some
public interest groups. In addition, individual states have set some of their own standards
4
JAAKKO POYRY
JAAKKO POYRY CONSULTING INC.
and on top of it all we have canada issuing standards or guidelines of its own.
Let us look for a moment at a few of the proposed rac standards for content requirement.
As you can see the newsprint requirement is for all post consumer fiber with the level set
at 40%. As mentioned earlier, this has been a standard which the industry has accepted
in an overall sense, that is all newsprint taken together would have a 40% recycled
content. This would allow the industry to produce a mixture of 100% recycled newsprint
and also some 100% virgin newsprint and still be in compliance with the law.
in the printing and writing area, you can see that the total recovered or secondary fiber
requirements are in the 40 . 50% range. However, the post consumer fiber content
requirements are significantly lower - 10-15%. This difference in requirements is a
recognition of the fact that It is more difficult to successfully use recycled fiber, particularly
the post-consumer variety, in printing and writing grades and still maintain the product
specifications required by the end users. (Note: I said more difficult, not impossible.)
With all of this uncertainty, one could easily expect that companies producing printing and
writing grades would be sitting on their hands. This is simply not the case. Evidently,
there are in excess of 800 brands of printing and writing papers with varying amounts of
recycled fiber contents offered for sale in the u.S.
When we look at the dilemma facing the printing and writing paper segment of the
industry, we really have to step back and ask ourselves the question - what are we trying
to achieve? There are really three potential goals we could be seeking to achieve:
solid waste reduction
conservation of raw materials, (that is, trees)
promotion of market demand
I do not believe we have to choose among these goals if we follow a rather simple, two
step approach to the problem. On a legislative level we have to set goals for the overall
recovery of paper. AFPA's 1995 goal of a 40% percent recovery rate is one such target.
ft is at least a reasonable goal, but one could debate outside this forum whether or not
it needs to be reviewed and revised upward, particularly in later years.
The second simple legislative action would be a labeling requirement for any product
claiming to be made from recycled fiber. The Labeling requirement would be to disclose
the exact recycled fiber content as a percentage of the total fiber that is contained in the
product. In order for a product to be called recycled at all, Ht should probably have some
minimum content, say something like 10%.
Let us look a little bit more at these two simple steps. First an overall recovery target is
easily set based on realistically achievable recovery rates for each of the various grades
of recovered paper. It is also measurable. Lastly, it satisfies the first two goals, that is,
5
JAAKKO PÖY Y
JAAKKO POYRY CONSULTING. INC.
it reduces solid waste and conserves virgin raw materials.
The second step recycled content labeling - doesn't require costly tracking of recycled
fiber sources. It allows the marketplace to decided what products they are going to buy
and what level of recycled content they will be satisfied with. This simple step also
eliminates "politics" whereby various agencies compete with one another to see who can
establish the "best" standards for a recycled content product. Finally, this step satisfies
the third goal in that it does promote the market demand for recycled content products.
I might also mention that it also satisfies the first goal reduction of solid waste.
Conspicuously absent from the two simple steps is any discussion of pre vs. Post
consumer fiber sources. The reason that I have not included this is very easy. Basically
all pre-consumer fiber is currently being recovered and reused. Therefore, any real
increase in recovery and reuse of recycled fiber will have to be of the post-consumer
variety simply because there is no appreciable amounts of additional pre-consumer
material available. This being the case, why try to put into law something which doesn't
need to be legislated?
I would now like to briefly delve into the second premise for why the use of recycled fiber
in printing and writing grades has not accelerated like it has in other grades. There are
significant economic dis-incentives for both integrated and non-integrated mills. A non-
integrated mill is one which does not have an on-site chemical pulp mill, although it may
have its own mechanical pulp mill. Therefore, the mill relies on market pulp purchases
of chemical fiber. On the other hand, an integrated mill is one that is fully integrated from
the forest right through the end of the paper machine and has all of its own pulping
facilities. It requires very little or no purchases of market pulp.
For a non-integrated mill, recycled fiber can be a very costly option. For the integrated
mill, the significant capital investment in the existing pulping facilities may effectively
prohibit the economic use of recycled fiber.
One of the most effective ways for the industry to add to the use of recycled fiber in any
given grade is to have a new capacity be based on the use of recycled fiber. In the
printing and writing area, there is already excess capacity today and as a result prices
within this sector are under considerable pressure. Any meaningful new capacity will not
be required for several more years. On top of all of this, there is the overhanging threat
of the paperless office in the future. Will this become a reality? Will it greatly lessen the
requirements for paper? We do not currently have the answers to these questions but
they do create an uncertainty when one is considering adding new and costly capacity.
Non-integrated mills are usually smaller in size than integrated mills and will generally
have a much more limited financial capacity for capital expenditures. This is particularly
true if a mill is considering adding its own deinking plant which can cost in the 50-100,000
million dollar range. Assuming an integrated mill is purchasing market deinked pulp (or
6
JAAKKO PÖYRY
JAAKKO POYRY CONSULTING. INC.
dip). its current price of $500-575 per metric ton (depending on post consumer content)
far in excess of the current market price for northern bleached hardwood kraft pulp.
The latter is currently around $400 per metric ton. Southern hardwood pulps can be
purchased at less than $400 a ton, making the disparity with deinked pulp even greater.
On top of all this, the market place premium for a recycled grade is currently at about the
5% level. However, it is shrinking and we believe that within the next several years will
essentially disappear. The essence of what the marketplace is saying is that we will we
not pay you any more for recycled fiber content than we will for a virgin fiber based
content product.
As mentioned before, an integrated mill can have a fairly significant fixed investment tied
up in its pulp mill. This can easily be at the $500 million level. Thus, the displacement
of significant virgin pulp with recycled fiber would create a fairly costly situation for
)
integrated mill. For example, a mill with a 600,000 t/y pulp line would experience
approximately a 10% increase in its virgin pulp costs If its replaced as little as 100,000
tons. This would raise its cost by more than $2 million per year. Hence, it a
tremendous dis-incentive for an integrated mill to displace virgin pulp with deinked pulp.
However, there are some positives for an integrated mill. First because of its significant
size and financial stability, it is usually able to absorb the high costs of deinked pulps, if
the amounts are limited. Second, the mill could also afford the capital for its own
deinking plant, if such a facility is economically viable. Lastly, these types of large
integrated mills are more likely to have incremental capacity increases for which recycled
fiber may be the perfect fiber source rather than an expensive expansion of the virgin
fiber pulping facilities.
Conclusions
As we move forward into an increasing amount of recycling, 1 would urge that we try to
accomplish the following four items. First, keep the regulations and guidelines as simple
as possible. Legislative initiative has helped to promote recycling to some extent.
However, it has also hindered progress when the regulations have become too
complicated and where they conflict between various agencies. Second, we need to set
some overall paper recovery goals as the primary emphasis of our efforts. This will
ensure that we reduce the amount of solid waste and at the same time provide an
abundance of materials the industry has demonstrated a willingness to use. Third, we
need to allow the marketplace to determine the prices that will be paid for recycled fiber
containing products and also the content levels at which they will purchase these
products. If we allow the marketplace to work its will, companies will respond to it.
Fourth, don't impose costly capital and operating costs on producers and their
production facilities, particularly when these are not needed in order for us to achieve a
reasonable set of goals when it comes to recycling.
7
LETTER TO PRESIDENT ABOUT AFPA
SEP 10 '93 11:56 NRDC NEW YORK OFFICE
P.1/2
NR
DC
PLEASE
DELIVER
FAX TO:
Pat.
Natural Resources
Defense Council
ORGANIZATION: Office for Domestic Pulicy
white House wor wing 2nd Floor
THIS TRANSMISSION IS
2
PAGES, INCLUDING COVER SHEET.
FAX IS
FROM:
Jennifer Burns
Natural Resources Defense Council, Inc.
40 West 20th Street
New York, New York 10011
IF THERE ARE PROBLEMS WITH THIS TRANSMISSION
PLEASE CONTACT:
AT (212) 727- 4479
NRDC'S NEW YORK OFFICE FAX NUMBER: (212) 727-1773
SEP 10 '93 11:56 NRDC NEW YORK OFFICE
P.2/2
NR
DC
Natural Resources
SEP 10 HELD
Defense Council
40 West 20th Street
New York, New York 10011
Please deliver this fax
212 727-2700
Fax 212 727-1773
TO:
Ms. Carol Rasco
Assistant to the President
For Domestic Policy
West Wing, Second Floor
The White House
FROM:
Allen Hershkowitz, Ph.D.
Senior Scientist
DATE:
September 10, 1993
You should receive
1
page (s).
If this fax is not properly received or you have any questions
regarding it please call Jennifer Burns at 212 727 4479.
Thanks.
MEMO
The copy of the letter from John Adams to President Clinton that
you received this morning via Federal Express and Fax should have
indicated in the first paragraph on page two that "an investment of
approximately $800 million is needed to provide the federal with
all the printing and writing paper it requires " I regret any
confusion our previous communication may have caused.
C This fax represents a
"Correction" to attacked fax)
pr
ROZ
9-10
1
We need to find out from Podesta are
whomever just who is handling
the letter to Pres. - or is this to serve as
original?
2
In meantime send a CC
10003 Recycled Proer
1350 New York Are., N.W.
71 Stevenson Street
of all off South to Olive Krean Street Burke 212 Merchant an Quite
203
Washington, DC 20005
Sun Francisco. CA 94105
Los Angeles, CA 90014
Honolulu, Hawaii 96813
202 783-7800
415 777-0220
213 892-1500
808 533-1075
Fax 202 783-5017
Fax 415 495-5996
Fux 213 629-5389
Far 808 521-6841
SEP 09 '93 19:23 NRDC NEW YORK OFFICE
P.1/6
NR
DC
Natural Resources
Defense Council
40 West 20th Street
New York. New York 10011
Please deliver this fax
212 727-2700
Fax 212 727-1773
TO:
Ms. Carol Rasco
Assistant to the President
For Domestic Policy
West Wing, The White House
FROM:
John H. Adams
Executive Director
DATE:
September 9, 1993
You should receive
6
page (s) .
If this fax is not properly received or you have any questions
regarding it please call Jennifer Burns at 212 727 4479.
Thanks.
10040 Recycled Paper
1350 New York Are., N.W.
71 Stevenson Street
017 South Olive Street
212 Merchant St., Suite 203
Washington, DC 20003
San Francisco. CA 94105
Los Angeles, CA 90014
Honolutis, Hawaii 96813
202 783-7800
415 777-0220
213 892-1500
808 533-1075
Fux 202 783-5017
Fax 475 405-5006
Fux 273 620-5380
Fux 808 521-6841
SEP 09 '93 19:12 NRDC NEW YORK OFFICE
P.2/6
Natural Resources
Defense Council
40 West 20th Street
New York, New York 10011
212 727-2700
September 8, 1993
Fax 212 727-1773
The President
BOARD OF TRUSTEES
The White House
Frederick A. O. Schwarz. Jr.
Chair
Washington, D.C. 20500
Stephen P. Duggan
Founding Chair
Adrium W. DeWind
Chair Emeritus
RE: RESPONSE TO AFPA LETTER AND MEETING REQUEST
Adam Albright
Vice Chair
Burks B. Lapham
Vice Chair
Dear Mr. President:
Michael Melniosh
Vice Chair
A September 3, 1993 letter to you from a trade association,
Dr. George M. Woodwell
Vice Chair
the American Forest & Paper Association (AFPA), purports to
Dr. Dear E. Abrahamson
respond to a letter sent to you on September 1, 1993 and
Richard E. Ayres
signed by more than 80 civic and environmental groups,
Dr. Eula Bingham
Robert O. Biake
including the Natural Resources Defense council. The letter
Henry R. Breck
we signed urged that you include a requirement for the use of
Richard Cotion
John Eckohank
at least 15% post-consumer paper in your forthcoming Executive
Robert 1. Fisher
order on Procurement of Printing and Writing Paper. In its
David Hahn-Baker
Francis W. Hutch. 11.
letter to you AFPA also attempts to respond to a separate
Alam riom
letter sent by NRDC urging that you include higher recycling
Michael Huffington
Hamikon F. Kean
goals in the Executive Order as well as goals for the purchase
Charies E. Koob
of paper made without the use of chlorine bleaching. I find
lenathan Z. Larsen
Peter A. Morton
that AFPA's response to both of these letters grossly distorts
Carol R. Noyes
the problems Americans now face regarding paper waste, paper
loins D. Oakes
Adabaya Oyunlesi
recycling and the effort of the U.S. paper industry in
Franklin E. Parker
responding to those problems.
Robert Redford
Nathemiel P. Read
Crus Reynoso
*
AFPA asserts that 200 U.S. mills now use
John K. Robinson
Lawrance Rocketeller
"recovered" paper in their production processes
Dr. Thomas W. Roush
despite the absence of a federal standard. AFPA
Christme H. Russell
John Sheeness
fails to mention that this occurred in large part
James Gustave Sputh
because more than half of all states in the U.S..
james Taylor
Frederick A. Terry, Jr.
as well as many private sector organizations, do
Thomas A. Trover
have a recycled paper procurement policy. Moreover,
Jacqueline B. Weld
Phylis M. Wyerh
the Executive Order you are now contemplating will
john H. Adams
not be a "federal standard." Rather, it will
Executive Director
simply attempt to reward those companies that have
made investments into environmentally superior
paper-making technologies (and those that are
planning to make these investments) by giving them
preference in federal government procurement
decisions.
This comports with your
Administration's goal of making the U.S. government
a leader in purchasing environmentally superior
products. In fact, that more than 200 mills
operating in the U.S. already rely "exclusively on
100% Recycled Puper
1350 New York Ave.. N.W.
71 Stevenson Street
617 South Olive Street
212 Merchan: St., Suite 203
Washington, DC 20005
San Francisco, CA 94105
Los Angeles, CA 90014
Honolulu. Hawaii 96813
202 783-7800
415 777-0220
273 892-1500
803 533-1075
Fax 202 783-5917
Fax 415 495-5996
Fax 213 629-5380
Fax 808 521-6841
SEP 09 '93 19:12 NRDC NEW YORK OFFICE
P.3/6
recovered [sic] paper for their raw material"
belies AFPA's claim that a 20% post-consumer
procurement standard will pose a costly burden on
the U.S. paper industry. Indeed, if AFFA's claim
that $7.5 billion worth of investments into de-
inking capacity are in fact being contemplated by
the paper industry, this provides even more reason
why the federal government should purchase paper
made with at least 20% post-consumer fiber so that
these investments remain viable. You should note
that an investment of only $800 is needed to
provide the federal government with all the
printing and writing paper it requires (300,000
tons) at 100% post-consumer content (and without
chlorine bleaching), Since American taxpayers
spent approximately $11 billion last year alone in
disposing of paper waste, this is clearly a jobs
producing investment worth making.
AFPA'S contention that a 15% procurement standard
would result in less paper being recycled than no
standard at all is absurd. It is belied by
America's experience in the field of newsprint
recycling, where state and local procurement
requirements caused the shift to much greater uses
of post-consumer fibers than would have otherwise
occurred. And it belies our experience in the
field of printing and writing papers as well, where
state and local mandates are virtually the sole
reason post-consumer fibers are incorporated into
mill use at all. U.S. mills that blend de-inked
fiber into their production processes currently do
so almost entirely in response to procurement
specifications.
*
AFPA states we have provided no data to support our
claim that "the supply of post-consumer paper
significantly exceeds demand. We do so now. As
the attached chart from EPA's consultant Franklin
Associates Ltd. indicates, total use of post-
consumer paper in 1995, including exports (which
account for more than 25% of total use), will be
less than half of total supply (total use is
projected to be 40,185,000 while supply is
projected to be 97,670,000 tons). Since more than
one-quarter of total use is exported to jobs
abroad, there is certainly no doubt that supply
exceeds demand. Ask any recycling coordinator in
any U.S. city if better markets are needed for
mixed residential papers and they will certainly
confirm this. (See attached chart.)
2
SEP 09 '93 19:13 NRDC NEW YORK OFFICE
P.4/6
*
AFPA's claim that they are not arguing for a
replacement of RCRA's definition of "post-consumer"
paper when they argue for a vaguely defined
category called "post-consuner/processed recovered"
paper is doublespeak. The management by paper and
printing companies of overissues, printed
converting scrap, (referred to as "processed
recovered fiber") is not the waste management issue
instigating so many local battles throughout the
U.S. about whether tax dollars should be spent on
incinerators and landfills or spent on recycling
programs. The municipal waste problem is the solid
waste problem our nation is now coming to terms
with. It is not the solid waste problems faced by
the paper industry that we read about daily in the
headlines of newspapers throughout America, as
public officials battle constituents about the
design of their solid waste strategy: it is the
problems faced by municipal officials as they try
to deal with the public health problems posed by
the mismanagement of municipal solid wastes.
Rewarding a "processed recovered fiber" standard or
including overissues and converting scraps in a
definition of post-consumer paper will reduce by
not even one pound the amount of wastes these
officials will have to manage at taxpayer expense.
It would be wrong for the Administration to purport
to address our nation's interest in recycling
municipal wastes while in fact addressing the very
narrow interests of a few paper companies.
*
AFPA claims the U.S. is the world's largest
recycler of paper. This is misleading since is
relates merely to tonnage, not to percentage of
materials recovered from the waste stream and
reintroduced in mills as raw materials. Since the
U.S. has a greater population than any European
nation we will generate more tonnage. But the
relevant issue is how do we compare in recycling
relative to production. In this regard a recent
report of the Congressional Research Service is
clear. According to the Congressional Research
Service "The U.S. rate of paper recycling also lags
most of Europe and Japan: of 18 [OECD] countries,
the U.S. ranked 15th
1
McCarthy, J.E., CRS Report for Congress: Recycling and
Reducing Packaging Waste: How the United States Compares to Other
Countries, (Washington, D.C: Congressional Research Service, The
Library of Congress, Nov. 8, 1991)
3
SEP 09 '93 19:25 NRDC NEW YORK OFFICE
P.5/6
AFPA'S argument that demand for chlorine free
products is not increasing is disingenuous since
AFPA itself has been aggressively fighting the
expansion of these markets, as it is doing now with
this Executive Order, in state and localities
throughout the U.S. and within the private sector.
The reference to a position offered by
Administrator Browner is taken entirely out of
context, since she actually indicated support for
the type of non-regulatory market incentives this
Executive Order would provide. The fact remains
that U.S. paper companies relying on chlorine
bleaching cannot market their product to major
markets including Germany, Sweden and The
Netherlands. This costs us American jobs.
Moreover, AFPA's statement about the presence of
chlorine in paper being recycled ("there is simply
no such product" as chlorine-free recycled paper)
is a red herring. NRDC and others have offered a
definition of chlorine free recycled paper
production processes that takes account of the
chlorine contamination now characteristic of paper
manufactured in the U.S. Our proposal refers only
to the chlorine found in the virgin component of
recycled paper. If the U.S. paper industry would
stop relying on environmentally destructive
chlorine bleaching technologies, which are
commercially viable and thriving abroad, we would
not have to worry about this issue and, indeed,
many of the adverse impacts associated with dioxin
in our waterways and our municipal waste disposal
system would be avoided as well.
It is unfortunately clear to us that the U.S. paper industry
is indeed in a situation the U.S. auto industry was in twenty
years ago. At that time, consumer demand for a fuel efficient
car was viewed as a temporary phenomenon by U.S. auto
executives who failed to make the requisite decisions to
invest into the commodity consumers wanted, i.e. a high milage
vehicle. On the other hand, responding to that consumer
interest, the German, Swedish and Japanese auto manufacturers
were simultaneously able to capture a greater market share,
modernize their manufacturing facilities and, in so doing,
increase the efficiency of their auto-production process
overall. The rest is history. Efforts by the environmental
community to promote federal fuel efficiency standards
actually worked to preserve some of the auto industry's
fragile market. We are doing so again today in the field of
recycled paper production.
It is unfortunate that a trade association such as AFPA
insists on offering Americans "lowest common denominator"
4
SEP 09 '93 19:14 NRDC NEW YORK OFFICE
P.6/6
trade group politics in lieu of economically competitive and
environmentally beneficial public policies. In SO doing they
are completely out of sync with the majority of Americans who
want to see a federal recycling procurement policy.
We reiterate our request that your Executive Order require a
20% post-consumer content in the year 1994 and a 40% post-
consumer content five years from now, as well as incorporating
a goal encouraging paper to be made without the use of
chlorine bleaching. Not doing so would cause us to lose a
truly historic opportunity.
We hope you find these clarifications helpful as you consider
your Executive Order and we would like to reiterate our
request to meet with you or Vice President Gore prior to its
signing.
Respectfully,
John adams
John H. Adams
Executive Director
CC: vice President Al Gore
Thomas F. McLarty, Chief of Staff
Leon E. Panetta, Director of OMB
Robert E. Rubin, Assistant to the President for
Economic Policy
EPA Administrator Carol Browner
Carol H. Rasco, Assistant to the President for Domestic
Policy
Kathleen McGinty, Director, Office of Environmental
Policy
Alice Rivlin, Deputy Director of OMB
5
Table 10
RECOVERED PAPER NECESSARY TO MEET REQUIREMENTS UNDER PROPOSED OR ACTUAL STÂNDARDS, 1995 (1)
(In thousands of tons)
P.7/6
Proposed or Actual Standards (3)
1995
RAC Proposed
EPA Guideline
New York State
California State (7)
New
Traditional
Postconsumer
Post-
Post-
Sec-
Post-
Product Line
Supply (2)
Total
Postconsumer
(or Comparable)
Total
consumer
Total
consumer
ondery
consumer
Newsprint
15,500
1,824
1,624
1,624
1,459
1,459
1,660
1,550
2,188
2,188
Printing-Writing Papers
26,270
2,019
0
1,414
283
1,414
283
Uncoated P-W Papers
19,113
1,365
300
410
Conted P-W Papers
9,157
419
70
105
Tissue Papers
6,400
2,731
1,800
2,389
631
631
2,048
1,024
1,707
341
Construction Paper
1,800
800
600
650
0
0
0
0
500
100
Uncoated Paperboard
Corrugated Containers
28,500
7,600
6,500
6,650
5,542
5,542
1,140
499
9,600
1,900
Folding Cartons, Other
5,430
5,732
3,400
3,439
Conted Paperboard
6,920
2,076
1,200
1,038
Boxboard, Other
12,350
1,098
1,098
3,335
1,297
3,431
686
Paper Packaging
4,850
216
80
106
27
27
243
97
269
54
23
Total for Standards
97,670
22,761
LR
YOUR
10,775
LAW
9,729
AND
19,008
6.652E
Other uses of recovered paper
Products varying from standard (4)
6,089
5,264
7,273
18,075
12,282
19,122
16,289
9,842
15,488
Nel Exports (5)
10,515
7,752
8,762
10,515
7,752
10,515
7,752
10,515
7,752
Other Uses (6)
820
820
820
820
820
820
820
820
820
SEP 09 '93 19:15 NRDC NEW YORK OFFICE
Total Use of Waste Paper (6)
40,185
29,610
33,466
40,185
29,810
40,185
29,610
40,185
29,610
Notes:
(1) Requirements calculated based on standards for each product (Table B). on market share of product meeting each standard
(Table 9), and on yield loss for each grade (Table 11).
(2) From Table A-2 and A-9.
(5) See Table 6 for definitions of standards. Calculations Include an adjustment for yield loss In manufacturing
process (except for New York State, which bases its standard on recovered paper used, rather than content).
(4) Obtained by difference. Some paper products will contain recovered paper In excess of the standards; some will contain less; and some
will contain no recovered paper. No basis for estimating this amount was determined.
(5) From Table A-4.
(6) Insulation, enimal bedding, etc. From Table A-4.
(7) California standards for newsprint apply to postconsumer only.
Source: Franklin Associates, Ltd.
Table 10
RECOVERED PAPER NECESSARY TO MEET REQUIREMENTS UNDER PROPOSED OR ACTUAL STANDARDS, 1995 (1)
(in thousands of tons)
P.7/6
Proposed or Actual Standards (3)
1995
RAC Proposed
EPA Guideline
New York State
California State (7)
New
Traditional
Posiconsumer
Post-
Post-
Sec-
Post-
Product Line
Supply (2)
Total
Postconsumer
(or Comparable)
Total
consumer
Total
consumer
ondery
consumer
Newsprint
15,500
1,824
1,824
1,824
1,459
1,459
1,550
1,550
2,188
2,188
Printing-Writing Papers
26,270
2,019
0
1,414
283
1,414
283
Uncoated P-W Papers
18,113
1,385
300
410
Coated P-W Papers
9,157
419
70
105
Tissue Papers
6,400
2,731
1,600
2,389
531
631
2,048
1,024
1,707
341
Construction Paper
1,800
800
600
650
0
0
0
0
500
100
Uncoated Paperboard
Corrugated Containers
28,500
7,600
5,500
6,650
5,542
5,542
1,140
499
9,500
1,900
Folding Cartons, Other
5,430
5,732
3,400
3,439
Coated Paperboard
6,920
2,076
1,200
1,038
Boxboard, Other
12,350
1,098
1,098
3,335
1,297
3,431
686
Paper Packaging
4,850
216
60
108
27
27
243
97
269
54
23
Total for Standards
97,670
22,761
UNA
10,775
1,7581
9,729
WITH
19,008
85824
Other uses of recovered paper
Products varying from standard (4)
8,089
5,264
7,273
18,075
12,282
19,122
16,289
9,842
15,486
Net Exports (5)
10,515
7,752
8,762
10,515
7,752
10,515
7,752
10,515
7,752
Other Uses (8)
820
820
820
820
820
820
820
820
820
SEP 09 '93 19:27 NRDC NEW YORK OFFICE
Total Use of Waste Paper (6)
40,185
29,610
33,466
40,185
29,610
40,185
29,610
40,185
29,610
Notes:
(1) Requirements calculated based on standards for each product (Table 6), on market share of product meeting each standard
(Table 9). and on yield loss for each grade (Table 11).
(2) From Table A-2 and A-9.
(3) See Table 6 for definitions of standards. Calculations include an adjustment for yield loss in manufacturing
process (except for New York State, which bases its standard on recovered paper used, rather than content).
(4) Obtained by difference. Some paper products will contain recovered paper in excess of the standards; some will contain less; and some
will contain no recovered paper. No basis for estimating this amount was determined.
(5) From Table A-4.
(6) Insulation, animal bedding, etc. From Table A-4.
(7) California standards for newsprint apply to postconsumer only.
Source: Franklin Associates, Lid.
AMERICAN
FOREST &
PAPER
ASSOCIATION
September 10, 1993
Mr. Peter Yu
National Economic Council
The White House
Washington, D.C. 20500
Dear Peter,
The question #3 "answer" is essentially correct, however an amplification of the points
raised would significantly increase understanding of the issue and help the President with his
decision.
There is no technical barrier to producing most commodity grade uncoated printing-
writing papers with 15% postconsumer content. The exceptions are on the lightweight end of
the grade spectrum. On the coated side, the lightweight grades are currently limited to 10%
but, over time, can get to 15%. Generally speaking, coated grades are a greater technical
challenge.
Before moving to the next and most relevant point, I wanted to underscore a related
point of vital importance to overall increases in printing-writing recycling. This point has
been frequently dismissed by some members of the Administration in conversations involving
the Executive Order (EO).
With the exception of the four or five papers cited in the earlier draft Executive Order
as "commodity grades" and, therefore, out from under the 50% total recovered fiber
requirement; all other true commodity grades will be subject to the 50% as well as a
postconsumer content level. Under this approach, the EO disregards decades of worldwide
industry practice and nomenclature in using the term "commodity" which will wreak havoc
and create untold confusion in an already confused and much, much larger private sector
marketplace for printing-writing papers.
Extensive industry research shows that a confused marketplace is a known and
acknowledged deterrent to the expansion of recycling in the printing-writing grades. The
results of this research are what prompted the printing-writing producers to develop their
initiative, which is simple in its definitions yet flexible, because it focuses on minimums and
relies on marketplace competition to drive the recycled-content levels higher, while allowing
everyone to participate.
1250 Connecticut Avenue NW. Second Floor, Washington, DC 20036
Phone: 202-463-2700 Fax: 202-463-2785
Mr. Peter Yu
September 10, 1993
Page 2
Additionally, no other true commodity papers, other than those cited as such in the
EO, will be considered by the marketplace as bona fide printing-writing recycled content
papers. This is because of the impossibility of commodity machines to effectively use 50%
recovered fiber in the printing-writing grade structure, and why the producers adopted a "50%
or 10%" as their minimum. In this approach, the smaller machines get the advantage of
higher numbers for total recovered fiber, while the bigger machines can be cost competitive
but with lower levels. Remember, all the small machines are already in use, and they will not
opt out. It's getting the big machines in that is necessary to significantly increase supply.
Returning back to the second point addressed specifically in the question #3 "answer,"
the economic/technical barriers which were the subject of half of the overall answer.
Given industry's current condition, few totally new "greenfield" mills will be built over
the next five years. Capacity expansions, upgrades and conversions will provide the only
available paths to growth. Therefore, one must look at existing mills and installed equipment
as the basis for rating future growth potential, particularly in the printing-writing grades.
While 15% postconsumer doesn't seem that much more, it is half again as much as
10% in an operational environment not presently equipped nor designed to handle wide or
broad tolerances in fiber composition. Given the non-uniform texture of recycled pulp
compared to virgin; clearer understanding, engineering-in, and dealing with broader tolerances
on huge, high-speed paper machines are a must. Operating these machines is not for the faint
of heart, and "just 5% more" is no small matter. These machines are almost as wide as a
football field, almost three football fields long, and spew out over one-half mile of paper per
minute. The stock preparation systems, feeding systems and, most particularly, the coating
blades and finishing systems must be re-engineered. This involves time, money and
experience and cannot be dismissed lightly.
Site-specific mill economics, not just how much new and scarce capital is needed, is
the deciding factor in adding recycled-content. Additionally, and as has been pointed out
before, for the printing-writing commodity producers who represent almost two-thirds of the
total production of these grades, there is not only a very big difference between 10% and
15%, but a very big fiber consistency difference between postconsumer and
postconsumer/processed recovered fiber.
What has also not been factored into the answer to question #3 is the most basic of all
axioms involving recycled content printing-writing papers -- "I can't make it, if I can't get the
raw material." Unlike all other recycled content products, printing-writing grades can only
utilize in volume the top-most, highest-valued recovered fibers because of the very strict
performance and consistency specifications required of the products they produce. There is
not a respected consultant who has studied the matter, who has not expressed very real
concerns about lack of available supply of acceptable postconsumer recovered fiber for use as
a raw material, once the commodity machines begin to move into the recycled content grades.
Mr. Peter Yu
September 10, 1993
Page 3
One can imagine what the law of supply and demand will do to the cost basis, when
limited supply constraints set in for those who have converted their mills to recycled-content,
and you can appreciate the cautiousness and reticence of going forward by all those who are
"on the fence" about whether or not to enter into these markets with their commodity
machines.
To the specific point of 10% versus 15% postconsumer, the printing-writing sector's
most recent survey shows that between 6-12% of the total commodity grade capacity of 17.5
million tons will manufacture recycled content paper at the 15% postconsumer level. At the
10% postconsumer level, that figure jumps significantly to 25-30% of capacity. The 15%
postconsumer level estimate is aggressive, while the range for 10% is on the conservative
side.
Peter, no one disputes that to mak more meaningful gains in decreasing paper flows
to landfills, the big commodity paper machines must get involved. While the government is
only a small percentage purchaser, its role with President Clinton's leadership will be
immense in this critical area. Don't let him march out with high numbers on the front end
expecting big success, because there are very real factors involved here. This is not an issue
that should be decided on emotion alone.
As you can see from the attached letter to the President, no one is a bigger recycler
than our industry. We want to grow much bigger, and we want President Clinton to be able
to be a part of this growing success story. We are not out to low-ball the Administration,
rather to help you understand that having your actions positively impact the broadest range of
industry players will result in diverting the most paper. Paper diversions reduce landfill
burdens. A focus on the bigger picture will produce bigger total volumes of recycling in the
printing-writing grades; focusing small will get bigger numbers in fewer papers, will divert
fewer total paper tons from solid waste, and will minimize any potential claim of Presidential
leadership tied to meaningful results in helping reduce the burden on our nation's landfills.
Please give me a call if any of this needs clarification and, again, thank you for the
opportunity to clarify this issue.
Sincerely,
Sea,
Red Cavaney
President
RC:mk
Attachment
AMERICAN
FOREST &
PAPER
ASSOCIATION
Red Cavaney
President
September 3, 1993
The President
The White House
Washington, D.C. 20500
Dear Mr. President
A September 1, 1993 letter to you from environmental groups, and others Interested in the draft Executive
Order pertaining to federal procurement of recycled goods, contains several misstatements, including the
following:
The letter asserts that "a standard of at least 15 percent post-consumer content is the lowest
level of recycled content that will provide an incentive to the paper industry to increase investments
in recycling." This stands in stark contrast to the facts. Currently, there is no federal standard
pertaining to post-consumer content in printing and writing paper, yet the paper Industry has 200
mills operating in the United States which rely exclusively on recovered paper for their raw
material. Again, with no federal action on the horizon, the paper Industry in 1990 embarked upon
a voluntary Increase in recycling capacity which, by 1995, will encompass more than 130 facilities
and involve approximately $7.5 billion in investments over the 1988-1995 Investment cycle.
The writers contend that, "Adopting a procurement policy that requires less than 15 percent post-
consumer content would be worse for recycling than no action at all." As was noted in AFPA's
August 6 letter to Peter Yu of your staff, requiring a 15% post-consumer content in printing and
writing papers will result in less recovered paper being used, not more. Only five to ten
commodity machines are likely to produce on a reqular basis paper meeting the 15 percent level.
At the levels suggested by the printing-writing producers, approximately twice as much post-
consumer/processed recovered fiber could be used - and possibly much more, with an optimal
industry forecast of 50% percent industry participation (see attached chart).
The letter provides no supporting data that, "the supply of...post-consumer paper significantly
exceeds demand..." Increases in the use of recovered paper in the printing-writing grades will
come primarily from used office paper, which is currently being recovered in line with growth in
recycling capacity. EPA's consultant, Bill Franklin, projects a shortage of many types of recovered
paper, including newspapers and corrugated containers, by 1995, and office papers beyond. Over
the longer term, the industry has very real concerns about the supply of quality, source-separated
recovered paper.
1250 Connecticut Avenue, N.W. Second Floor, Washington, D.C. 20036
Phone: 202-463-2700 Fax: 202-463-2785
The printing-writing producers are not suggesting that the Executive Order change or expand the
definition of "post-consumer". Rather, they are asking that a larger universe of recovered paper -
- clearly identified as "post-consumer/processed recovered fiber" - be included in the Executive
Order.
in its recent news release, the Natural Resources Defense Council (NRDC), a signator of the earlier
referenced letter, also makes numerous errors. Among them that the U.S. ranks below the European
Community in paper recycling. The facts are as follows:
The U.S. is the world's largest recycler of paper. We recover more paper than any other region
of the world. in 1991, the last year for which worldwide data were available, the U.S. recovered
28 million tons of paper. The entire European Community accounted for 20 million tons (with
Germany at 7.5 million) and Japan recovered 14.7 million tons. Our rate of recovery essentially
matched the average of all EC countries at 37% Only two EC countries exceeded a recovery rate
of 40% (where the U.S. will be this year), and over half the EC was under the U.S. recovery rate.
In 1991, the U.S. accounted for one-third of all paper recovery. Source: Pulp and Paper
International, October 1992, page 32.
The U.S. paper industry is not where the auto Industry was 20 years ago. During a time of
economic difficulty, the industry has invested at an unprecedented rate on modernization, new
capacity - Including recycling capacity - and in environmental improvement To that end, in its
recent survey, Fortune rated only two industries as earning an "A" on their report card for
International competitiveness; the U.S. forest and paper Industry was one.
It is also worth noting, that while well over 90% of the projected increase in U.S. paper recovery will be
from post-consumer sources, no other country outside North America makes the pre-/post-consumer
distinction. in other countries, "post-consumer" paper is anything outside the paper mill.
Contrary to NRDC's contention, a rush to impose totally chlorine free (TCF), a technology whose
time has not come, will hurt, not help, American industry's competitiveness in the world. The U.S.
pulp and paper industry's efficient use of environmentally sound bleaching practices using chlorine
compounds has allowed it to become the world's top producer of pulp, paper and paperboard.
in fact, exports are the major engine of the industry's demand growth. Sixty percent of production
increases since 1988 were derived from foreign demand.
NRDC's contention that demand for TCF products is growing is just not true. The fact is that
demand has stabilized at a very low level. The reasons are primarily related to the inability of
current TCF technology to meet customer requirements. First, as EPA Administrator Browner
acknowledged, "the technology is not fully developed" and "no kraft mills have yet succeeded in
making high-brightness pulp from southern softwoods without using chlorine." Second, there are
other customer needs, such as high absorbency, low dirt counts and superior strength, that cannot
be met without bleaching with chlorine compounds.
2
What NRDC refuses to acknowledge is that while the industry has every reason to feel confident
of maintaining its International competitiveness, TCF paper purchasing goals will jeopardize Its
position in our country. The only announced U.S. manufacturer of TCF bleached kraft pulp
recently decided to shut down operations for the remainder of 1993. As a consequence, the
Federal government would find Itself buying virtually all its purchases from foreign suppliers and
underwriting solely foreign jobs.
NRDC's allusion to "chlorine-free recycled paper* also is misleading: there simply is no such
product. The fact is that since chiorine compounds are found in cellulose fibers in wood, they are
a component of all paper-Including TCF paper. Since there is no commercially available method
to remove chlorinated compounds from any paper, regardless of the process used, no paper
products can be literally chlorine free.
It is equally important to know that paper made from conventionally bleached pulp is actually more
desirable for recycling than TCF paper because chiorine or chlorine compounds only minimally
impact cellulose fibers as they remove the lignin and other unwanted components from wood.
Chemicals used in TCF processes, in contrast, are far less gentle, producing paper with weaker
fibers. This difference is critical because the stronger fibers found in conventionally bleached
paper make that paper stronger and amenable to being recycled numerous times. On the other
hand, TCF paper fibers make it weaker and limit its recycling potential.
We hope you will find these clarifications helpful in your consideration of the pending Executive Order, and
wish to renew the industry's request to meet with you prior to signing the Order.
Respectfully,
Red Cavaney
Mr0903.pre
cc:
Vice President AI Gore
Thomas F. McLarty, Chief of Staff
Leon E. Panetta, Director of OMB
Robert E. Rubin, Assistant to the President for Economic Policy
EPA Administrator Carol Browner
Carol H. Rasco, Assistant to the President for
Domestic Policy
Alice Rivlin, Deputy Director of OMB
Kathleen McGinty, Director, Office of Environmental Policy
3
Printing-Writing Use of Postconsumer/Processed Recovered Fiber
P-W Recycled Content Initiative & Alternatives
TONS
(Millions)
26
Initiative
Alternative
Alternative
24
2.2
50% Participation
Initiative Maximum Potential
2
Initistive/Alternative Would Add
1.8
AFPA Capacity Survey Projections
1.6
1.4
1.2
1
es
0.6
0.4
0.2
o
1992
1995
1995
1993
10% Postconsumer/
15% Postconsumer/
10% Postconsumer
Processed Recovered Fiber Processed Recovered Fiber
Adverse Economic Impact of Current Federal Initiatives
on the U.S. Pulp & Paper Industry
The U.S. paper industry has spending underway, or anticipated, to address the following
eas of interest to the federal government: (1) At a minimum, EPA's current cluster rulemaking
(combined air and water) will require almost $6 billion (EPA estimate) in new industry capital
prior to 1998. (2) Conversions and expansions to increase the use of recovered paper in
industry recycled and recycled-content products are currently projected at $7.5 billion for the
1988-1995 time frame. (3) The new taxes to be levied upon the industry annually as part of the
deficit reduction package will reach a minimum of $300 million.
The cumulative impact of several additional non-coordinated, major federal policy initiatives
has the potential to severely impact the paper industry just as it completes a decade-long
investment cycle to secure its global competitiveness for the future. The following additional
claims on industry capital provide virtually no incremental benefits to the public but will adversely
impact the industry's international competitiveness, exports making up 60% of the industry's
growth over the past five years:
The inclusion of unneeded oxygen delignification in the EPA cluster rulemaking will
add an additional $4 billion in capital costs and millions in additional operating costs
on top of the $6 billion earlier cited.
Inclusion of chlorine-free provisions in the President's Recycled Goods Executive
Order, if translated to the broader private marketplace which has been the historical
case with recycled content guidelines and printing-writing papers, will cost the industry
approximately $3 billion in capital costs and hundreds of millions of dollars of
increased annual operating costs on top of all of the earlier mentioned potential levies.
And, it will render as obsolete over $1 billion in recent investments to reduce organo-
chlorines. More Importantly, sufficient technology does not presently exist to
manufacture the full range of quality pulp & paper products utilizing U.S. fiber sources.
The application of a narrow post-consumer definition and high recycled-content levels
fcr printing-writing papers in the President's Recycled Goods Executive Order will
require hundreds of millions of dollars of capital spending for inefficient investments
which will not significantly increase the amount of paper recovered from the solid
waste stream for recycling.
In addition to these potential capital requirements, the Clinton Administration proposes to
reduce timber harvests on federal forests in the Pacific Northwest and northern California by 6
billion board feet annually. The wholesale value of this in today's lumber market is $2 billion.
The lost production opportunity will cost 85,000 direct and indirect jobs.
Taken together, these developments will drain the Industry's cash flow by billions of dollars
annually and will lessen the industry's financial strength. Paper's position as a globally
competitive industry, offering secure, well-paying jobs for three-quarters of a million American
workers, will clearly be jeopardized if these additional Impositions on the industry are
realized.
8/11/93
Protecting the Environment & Maintaining
Competitiveness
- A Balanced Solution
Paper's Growing Share
Of Manufacturing Employment
%
3.9
3.8
3.7
3.6
3.5
3.4
3.3
3.2
80 81 82 83 84 85 86 87 88 89 390 91 92 93
Source: Bureau of Labor Statistics
American Forest & Paper Association
1250 Connecticut Avenue, NW
Washington, DC 20036
Introduction to the Paper Industry
Production Of Paper And Paperboard
000 short tons
100
80
60
40
20
0
U.S.
Japan
Canada'
China
Germany
Source: 1992 AFPAVoreign association data
The U.S. is the world's #1 producer of pulp, paper, and
paperboard. U.S. mill output of paper and paperboard is greater
than the combined total of the next four largest producing
nations -- Japan, Canada, China and Germany.
The paper and allied products industry employs some 700,000
people in 42 states at 544 mills. Indirect employment accounts
for an additional 2,800,000. With sales of $125 billion, it is
among the nation's top ten manufacturing industries.
As a result of massive capital expenditures devoted to
modernization, streamlining of production and environmental
improvements, the U.S. paper industry has succeeded in
enhancing its competitive position in world markets and
generating export jobs.
Paper Industry Capital Intensity
Net Plant And Equipment
Per Employee
000 $
Paper
All Manufacturing
120
100
80
60
40
20
0
80
81
82
83
84
85
86
L8,
88
89
90
91
92
Source: BLS, Dept. of Commerce, AFPA
The paper industry is the most capital-intensive manufacturing
industry in the nation, with each employee being supported by
more than $100,000 of plant and equipment -- twice the average
of other domestic manufacturing industries.
The paper industry has invested almost ten cents of every sales
dollar to maintain global competitiveness, improve
environmental performance and increase recycling.
Investing for the future has made the paper industry more
efficient -- productivity has risen 47 percent since 1980 --
helping to protect the industry's job base by enhancing its
competitive position in world markets.
Expenditures for Environmental Improvements
Capital Expenditures For Pollution Abatement
(Paper & Paper Products)
billion $
1.4
1.2
1980-89 Total: $4.1 Billion
1990-92 Total: $3.6 Billion
1
Grand Total
$7.7 Billion
0.8
0.6
0.4
0.2
0
80
81
82
83
84
85
86
87
88
89
90
91
92
Sourer National Council for Air and Street Improvement
The industry's capital expenditures for environmental improvements now exceed $1.0 billion per
year, up sharply from a decade ago.
Pulp and paper companies have provided major support for EPA's "33/50" voluntary
pollution prevention initiative - being early to join the program and achieve a high level of
participation, and meeting the 1992 goals early in many cases.
The industry developed innovative and pioneering technologies to minimize dioxin (an
unwanted by-product) in its processes, resulting in a 90 percent reduction in its dioxin
generated since 1988 based on current available data. Industrywide, only four ounces are
generated annually from pulp bleaching.
Over the past 20 years, industry efforts have resulted in:
-
70 percent reduction of biological oxygen demand through wastewater treatment;
-
60 percent reduction in water use per ton of product; and
-
air controls for particulate removal of more than 97 percent.
Fossil fuel use and purchased energy consumption per ton of paper has been reduced 46
percent over the last 20 years. Cogeneration accounted for 87% of total in-plant electricity
generated in 1990.
All of these accomplishments took place while the industry increased production by 50 percent.
Spending to Remain Competitive
Paper, Paperboard And Market Pulp
Production Growth: 1988 Through 1992
Production For
Domestic Use
40%
3.9 Mil Tons
Exports 60%
5.7 Mil Tons
Paper & Paperboard: 7.7 Mil Tons
Market Pulp: 1.9 Mil Tons
Source: U.S. Commons Bures/AFPA
Total Procution: 9.6 Mil Tons
Exports have served as the major engine of demand growth for the U.S.
paper industry during recent years - 60% of the industry's production
growth since 1988 has derived from foreign demand.
In 1992, the U.S. became a net exporter of paper and paperboard
products.
The industry's global success is the combined result of a world class
work force, high and sustained capital investment and a cost-competitive
fiber resource base.
High operating rates are demanded - averaging 92% over the long term.
Operating rates of less than 90% cannot be sustained without severe
financial consequences.
Participation in global markets is essential to maintain high operating
rates over the business cycle.
Remaining globally competitive is absolutely essential to the paper
industry's continued viability.
Recycling-Related Investments
Paper Recovery And Discards To Landfill
Million Tons
50
Landfilled
40
30
Recovered
20
10
0
1985
1986
1987
1988
1989
1990
1991
1992
1993
Source: Franklin Associates
The paper industry is approaching its voluntary goal to recover 40% of
all paper used in the U.S. in 1995 and expects to announce a new higher
target this year.
This dramatic progress has been expensive. Cumulative plant and
equipment expenditures (since 1988) aimed at meeting the 40% goal will
total some $7.5 billion.
The amount of paper landfilled annually has decreased by 10 million tons
since 1988. Over the same period, the amount of paper consumed
annually in the U.S. has increased by nearly 3 million tons per year.
Due primarily to increased paper recycling, the amount of paper
recovered in the United States in 1993 will exceed the amount landfilled.
Nearly 60% of all containerboard and 55% of all newsprint was
recovered in 1992.
Cost Estimates for EPA BAT/MACT Control Options
Estimated Costs To Meet EPA Options
Capital Costs
Annual Operating
Costs
Effluent Guidelines
$5.69 Billion
$101 Million
MACT
4.20 Billion
705 Million
Totals
$9.89 Billion
$806 Million
Source: NCASI
Complying with the effluent guidelines best available technology (BAT) water and maximum
achievable control technology (MACT) air options currently being considered by EPA would
cost the pulp and paper industry almost $10 billion in capital expenditures and more than
$800 million a year in incremental operating costs. Estimates were made by the National
Council of the Pulp and Paper Industry for Air and Stream Improvement (NCASI).
Costs were calculated for bleached papergrade kraft, dissolving kraft, paper grade sulfite,
dissolving sulfite, and unbleached mills.
The underlying technologies for effluent guidelines costs estimates include:
100 percent chlorine dioxide (CIO₂) substitution for chlorine, oxygen delignification,
elimination of hypochlorite, and upgrades to recovery boiler capacity.
The technologies for MACT air standards cost estimates include:
Process Sources: Collection and incineration of all pulp mill vents, except deckers;
collection and scrubbing of bleach plant vents; and steam strippers for wastewater.
Combustion Sources: Current new source performance standards (NSPS) for existing
recovery furnaces, lime kilns, and smelt dissolving tanks.
Capital Availability
Cash Flow And Capital Expenditures
(Paper and Allied Products)
Billion Dollars
20
15
Capital
Expenditures
10
5
Cash Flow
0
80
81
82
83
84
85
86
87
88
89
90
91
92
93
Source: Burtee of Economic of the Comm
Government data show that capital spending by the U.S. paper
industry has significantly exceeded cash flow since 1989.
Having just completed a major capacity expansion cycle, the
industry must realize the "back end of the cycle" returns and
cash flow from those investments in order to be competitive
through the next business cycle.
It is critical that policymakers enable the industry to prioritize its
capital spending to balance the goals of safeguarding the
environment and remaining competitive in world markets.
EXECUTIVE ORDER DRAFT LANGUAGE ON RECYCLING SHOULD BE CHANGED
As the White House considers language to include in its Executive Order on Recycled Goods, it is
recommended that the key elements of the paper industry's voluntary Printing-Writing Recycled
Content Initiative aimed at maximizing recycling be incorporated.
Initiative Highlights
A printing-writing paper to be considered a recycled content paper must contain a
minimum of 50 percent recovered fiber OR a minimum of 10 percent post-consumer and/or
processed recovered fiber, measured by fiber weight.
The flexibility of two options enables both large and small paper machines to produce recycled
content products.
The minimum 50% threshold recognizes capital investments already made at mostly small
mills which currently supply the greatest portion of recycled content papers, allowing
these mills to continue to participate.
The minimui.. 10% threshold creates the opportunity for commodity type grades of
printing-writing paper commonly produced on large paper machines at integrated mills
(with their own pulping operations) to use recycled fiber where previously it was not used.
Commodity type grades include uncoated and coated grades of paper commonly used in
commercial printing; offices; publications including magazines, books, and directories; and
advertising. The draft executive order list - copier, offset, forms bond, computer printout,
carbonless, file folder and white wove envelope papers - includes only some of the above
printing-writing papers. Use of the term "commodity" by the White House in the draft
executive order will create broad confusion in the marketplace. Therefore, if the term
commodity is to be used, the generally recognized definition of the term as it applies to
grades of paper should be adopted.
By establishing minimum thresholds which make it possible for recovered fiber to be used in many
grades and in smaller percentages per sheet but in greater volumes of paper overall, the goal of
helping to reduce the amount of paper in the waste stream is being achieved.
The term "processed recovered fiber" is key. Processed recovered fiber is similar to
postconsumer fiber in that it comes from paper to which materials such as inks and dyes were
added. These materials must be removed in order to obtain the fiber for reuse in a printing-
writing paper. Processed recovered fiber includes printer overruns and returned, unsold
magazines from the newsstand which are excluded from the RCRA definition of "postconsumer
fiber."
Allowing "processed recovered fiber" to count encourages its use by recycled printing-writing
mills, giving them needed flexibility in sourcing recovered paper for processing and opening the
door to greater investment in facilities to produce recycled content papers. Because the fiber
must be processed, its inclusion will still require the kinds of investment that the Executive Order
is designed to encourage.
AFPA Printing-Writing Paper Division
August 30, 1993
20 May 1993
ISSUE PAPER ON PRINTING-WRITING PAPERS AND RECYCLING
Overview
The U.S. paper industry has a long and proud history in recycling. In 1992, 33.6 million
tons -- over 38 percent of all paper and paperboard used in the U.S. -- were recovered for
recycling. Clearly, substantial progress has been made in diverting paper from disposal -- in
1993, more paper will be recovered for recycling than will be sent to landfills. The amount of
paper destined for landfills has been reduced 10.6 million tons since 1988, the base year for the
industry's unprecedented commitment to recover by 1995 40 percent of all paper used in the
U.S. -- a goal the industry expects to exceed by as much as five percent, and to do even more.
An important opportunity exists to further reduce the amount of paper destined for the
solid waste stream -- minimize the obstacles that stand in the way of increased utilization of
recovered paper in printing-writing papers, a segment that represents 30 percent of total industry
output. To that end, the American Forest & Paper Association (AFPA) Printing-Writing
Division has launched a Recycled Content Initiative with three basic objectives: 1) to eliminate
marketplace confusion over what constitutes a recycled-content printing-writing paper; 2) to use
more recovered fiber in printing-writing papers; and 3) to make more recycled-content paper
available in the marketplace.
Administration support for the Initiative is the most expeditious way to achieve greater
use of recovered paper material in the short term. The current AFPA mill capacity survey
shows only four new paper machines are planned for start-up in the next three years. Therefore,
modifications which can be made to existing pulp and paper operations to include recycled fibers
are the most attractive approach to near term increases in recycling. If operations, especially
large paper machines, are changed to use incremental quantities of recovered fiber, sizable
increases in total recovered fiber consumption will result sooner. The Administration can also
facilitate this process by encouraging greater source separation of clean paper from the solid
waste stream as recommended by AFPA, the National Office Paper Recycling Project and
others.
The Printing-Writing Recycled Content Initiative
The Printing-Writing Recycled Content Initiative is a voluntary program in which the
manufacturers of these products have agreed to establish a recycled content threshold which the
product must meet in order to use a recycling symbol. To qualify for the Initiative, participants
have established that a product must contain a minimum of 50 percent recovered paper OR a
minimum of 10 percent post-consumer/processed recovered fiber, measured by fiber weight.
The 50 percent threshold is an important component of the Initiative because it recognizes
mills that have already made changes to use recovered fiber. These smaller, non-integrated mills
(i.e. mills generally without on site pulping capability) are equipped with smaller paper machines
and are often close to urban areas and, thus, have ready supplies of recovered paper for their
operations. These are the mills most responsible for the current use of recovered paper in
printing-writing products.
The 10 percent post-consumer/processed recovered fiber option opens the universe for
larger integrated mills (i.e. mills with on site pulping capability) to the use of recovered fiber.
By enabling these mills to produce printing-writing papers that meet an achievable threshold for
recycled content, the Initiative's 10 percent post-consumer/processed recovered fiber option
significantly incentivizes investments in increased recovered fiber capacity.
Rationale
If between one-quarter to one-half of the large paper machines (200 or greater tons per
day output) producing printing-writing papers were to use recovered fiber at a 10 percent
recycled content threshold, the potential incremental use of recovered paper by 1995 would be
between 400,000 to 800,000 tons. If the recycled content threshold level were raised to 15
percent, there would be a significant drop in incremental usage to below 200,000 tons. An
increase in the recycled content threshold to 20 percent or 25 percent would virtually eliminate
increased use of recovered paper in the near term by the existing large printing-writing paper
machines. As explained herein, economic operation of these existing, large machines is
adversely affected by the addition of external fiber, such as deinked or processed fiber, for
which the machines were not designed. In short, the higher the percentage, the fewer machines
capable of producing a marketable recycled content product.
Key factors affecting the greater use of recovered paper by printing-writing paper mills
are: 1) supply of recovered fiber, 2) technology, 3) quality and performance requirements, and
4) economics.
1) Supply of Recovered Fiber - Mills must have a reliable supply of quality recovered
paper and the flexibility to use it.
2) Technology - Historically, large mills were built to use primary wood pulp as their
source material. Because pulping is a continuous and energy-intensive operation connected to
the paper machine, these existing mills cannot efficiently substitute large percentages of
recovered fiber over a sustained period of production without incurring excessive performance
deterioration and operating cost penalties. Imbalances in energy use, waste treatment and
material flows are created which require physical changes to the mills that take significant capital
investment and long periods of time to implement.
2
3) Quality & Performance Requirements - The operating parameters necessary to
produce a high-quality sheet of paper on a modern high-speed machine have little margin for
variations in feedstock contaminant levels. Greater levels of recovered fiber usage result in
increased exposure to contaminants. The cost penalties of a contaminant-induced breakdown on
a 3,000 foot-per-minute, 200 inch-wide paper machine are enormously greater than on a smaller
200 foot-per-minute, 60 inch-wide machine.
4) Economics - Existing modern paper mills represent a $300-$500 million capital
investment, on average, and support a considerable direct and indirect employment base. The
mills are balanced among pulp production, energy recovery and paper production. Many are
dedicated to producing commodity papers. The economic viability of these commodity mills
depends on low cost, high volume, consistent quality production, enabling these mills to compete
in the global marketplace. Printing-writing papers are the industry's second largest dollar-valued
export. Any cost increase is a serious competitive problem for these commodity mills. Since
the largest single cost of paper production is fiber, a substantial increase can quickly make an
operation noncompetitive. The costs of significantly under-utilizing the pulp operation are
prohibitive. Furthermore, use of large amounts of recovered paper may require increased
reliance on fossil fuels and, therefore, additional pollution-control equipment and purchased
energy costs.
Conclusion
Since a great deal of private sector buying takes its lead from EPA's procurement
guidelines, it is vital for the Administration not to set unrealistically high recycled content levels
for printing-writing papers. Too high a level will discourage investments in capacity to use
recovered paper or make the output economically uncompetitive. With imports already at 15
percent of U.S. printing-writing consumption, more foreign production can easily displace
noncompetitive U.S. output, costing American jobs.
In only Canada and the U.S. is the term "post-consumer" used to define a segment of
recovered paper. In Europe, for example, all paper from the printing/converting process is
considered to have been used by consumers, significantly reducing foreign producers
collection/usage costs. With no test available to determine the recycled content of paper, how
will the U.S. government, let alone a customs agent, ensure that imports meet the exact same
definitional constraints placed on U.S. producers?
By supporting the Printing-Writing Recycled Content Initiative levels in EPA's federal
procurement guidelines, the Administration and the U.S. industry can move toward a common
goal as partners, confident that much greater use of recovered paper in the printing-writing paper
sector will be achieved and that a globally competitive U.S. industry will be able to continue
growing its markets and work force.
a:whstalk.pt3
3
Draft Presidential Executive Order on Federal Recycling
Totally Chlorine-Free
I.
There is no full-scale production of TCF pulp in U.S. bleached kraft mills. The
practical effect of the Executive Order (EO) will be the widespread, increased
purchase of imported paper at the expense of U.S. production and jobs. There
has been no cost/benefit analysis of the impact of this action, nor substantiation
that TCF mills and products are superior to modern conventional mills using
enhanced process modifications and pollution prevention techniques.
The mere mention of TCF, even as a goal, in the Executive Order is a cause of
concern because of the historical linkage under which the purchase behavior of
the private sector toward printing-writing papers closely follows the federal
government purchase" "guidelines" regarding recycled content. A TCF "goal"
will be accepted and implemented as a "guideline" for all paper grades.
To capitalize on demand created by the EO, Scandinavian producers, whose
fiber base for TCF pulps is much different than that of the U.S., will rush into
the U.S. market, fill their order books and create a stronger overall presence
within our attractive domestic market, displacing U.S. products and jobs.
Given the United States' strong reliance on southern pine and the kraft pulping
process, the U.S. pulp and paper industry cannot immediately mount a counter
offensive to reclaim lost domestic markets, even if the financial resources were
available.
II.
The environmental impact of TCF is largely unknown, and there is a possibility
the impacts may be greater than had been assumed.
Mills employing modem conventional bleaching have been enhanced with
extensive process modifications and pollution prevention techniques. Products
from conventional bleached mills actually have lesser concentrations of
chlorinated compounds such as dioxins than common everyday materials.
The environmental effects of TCF processes have not been adequately
evaluated. Scientific comparisons of bleaching process options made by the
Pulp and Paper Research Institute of Canada have revealed concerns with some
TCF effluent discharges.
III.
TCF is not proven technology for U.S. bleached kraft mills.
EPA Administrator Browner has recently acknowledged that TCF technology is
"not fully developed," and that "no kraft mills have succeeded in making high-
brightness pulp from southern softwoods without using chlorine."
"Despite the widespread research and development, and some successful
production runs, the consensus [from the Worldwide Conference on Non-
Chlorine Bleaching at Hilton Head, SC, March, 1993] was that TCF bleaching
has not gained the status of proven technology. Although several mills are
producing TCF grades of bleached kraft pulp for specialized niche markets,
there is no TCF process available which can produce, at competitive cost, high
brightness market pulp, with equivalent physical properties to conventionally
bleached pulp, from chips with a range of quality that permits companies to use
all available forestry residuals."
TCF is not one process, rather a wide variety of options -- oxygen, ozone,
hydrogen peroxide and enzymes. To date, the kraft pulps of this process are
less bright, have a higher dirt count, produce a weaker papermaking fiber and
are more costly to produce.
IV.
The limited TCF production which is occurring is driven by local factors; it is
market forces that are driving the demand. TCF capacity must be differentiated
from TCF production; capacity is not я surrogate for demand.
The first North American mill to produce TCF pulp was shut down and offered
for sale when its owners found customers "unwilling and unable to compromise
on product quality."
The two U.S. mills which are currently championing TCF are doing so for
commercial reasons. One is a sulfite mill that is not representative of the
processes or products produced by 95% of the U.S. industry's bleached mill
output. The only U.S. kraft mill to announce a totally chlorine-free pulp
advertises that it will not be in full production until well into 1995, and that
mill is a producer of pulp, not a maker of paper. This mill is the only mill in
the lower forty-eight states not to have made the very significant investments
necessary to install secondary treatment.
The only market with significant interest in TCF is Germany -- a market of
historical and particular concern to Scandinavian producers.
TCF mills produce TCF only intermittently. It is important to distinguish
between TCF capacity and TCF production; the latter is more related to actual
market demand, which continues to fall far short of supply. For example, the
manufacturer most committed to TCF in Europe (Sodra, Sweden) continues to
devote only one-third of its capacity to TCF, largely because the market
penalty (about 15% higher) and end-user concerns have limited demand.
V.
It would be inequitable for the federal government to force U.S. companies down
a different (and very capital intensive) path than that under which they were
previously regulated.
EPA does not find TCF to be the best available and economically achievable
technology for U.S. bleached kraft mills.
For decades, the U.S. government has regulated its pulp and paper industry to
utilize secondary, biological treatment. As a result, the industry's mills meet
the world's most stringent overall environmental regulations.
Our government should not now break faith with this history and force the U.S.
pulp and paper industry to a new standard, which is an outgrowth of a different
pollution control strategy employed in Scandinavia.
In Scandinavia, governments did not earlier require the installation of
secondary biological treatment, which has been employed by U.S. mills since
the 1970's. In now playing "catch-up" with regard to environmental controls,
some Scandinavian competitors tout processes which do not use chlorine
compounds but continue to avoid secondary treatment.
U.S. permits are on a "not to exceed" basis, a much more stringent standard
than the Scandinavian use of "average."
VI.
TCF is counterproductive to increased use of recovered materials.
Paper from conventional bleached pulps are convenient for recycling because
the fibers are strong and can be recycled numerous times; TCF fibers are less
strong.
TCF processes do not yet allow efficient use of softwood forestry residuals to
the extent achievable with modern conventional bleaching. Since one quarter
of the fiber used at U.S. paper and paperboard mills comes from wood
residues, the widespread application of TCF would result in an increase in the
volume of residuals requiring solid waste disposal, and increased demand for
roundwood.
Finally, there is no commercially available method to remove chlorides and
other chlorinated compounds from any paper. No paper products can be
literally chlorine free.
August 12, 1993
American Forest & Paper Association
Draft Executive Order on Federal Recycling
Purchase Guidelines for Recycled Content Printing-Writing Papers
I.
While a higher content level of recycled fiber per printing-writing sheet of paper
may appear better, 2 10 percent minimum content level per sheet will result in
greater consumption and diversion from landfills of recovered fiber.
A 15% minimum post-consumer content standard for paper produced by
commodity machines at vertically integrated mills will prevent many producers
from making capital investments in expensive, specialized equipment to process
recovered fiber.
Getting commodity machines involved in recycled content is the only
way to markedly increase recycling in the printing-writing grades.
Commodity machines represent two-thirds of the installed printing-
writing capacity, and are the most cost efficient and the least involved
in the current manufacture of recycled content printing-writing papers.
Most current recycled content printing-writing papers are produced on
smaller, less efficient machines. The industry's generally understood
definition of a "commodity paper machine" is based on the size of the
machine (76,000 tons/year and larger), and both uncoated and coated
papers are made on these machines.
At 15% minimum post-consumer content, only 6-12% of the total
commodity machine capacity is estimated to convert in the near term.
World-class, vertically integrated mills are "balanced" for pulping,
bleaching, energy, waste combustion, etc., and more than 10% post-
consumer content under-utilizes these various mill processes,
uncompetitively raising costs.
If a "50 percent OR 10 percent" minimum content approach for all
printing-writing grades cannot be embraced, language including all
coated and uncoated free sheet and groundwood commodity grade
papers as qualifying for the lower number should be included in the
Executive Order.
II.
Requiring specific higher recycled content standards for future years in the
Executive Order is a disincentive.
Some producers willing to make the necessary recycling investment
because they feel they can "stretch" to the minimum content level may
opt not to go forward out of concern that they cannot see how to reach
the higher levels, which are already "etched in stone."
The EPA Administrator already has the authority to review the
standards at his/her discretion. In fact, that process is currently
underway.
As minimum content levels are moved higher, a grade-by-grade
differentiation must be considered because some grades will be better
able to contain higher percentages of recovered fiber than others.
Therefore, EPA Administrator flexibility in designating review times
and recommending content levels based on real performance will
achieve greater recycling than one "etched in stone" number that applies
to all grades.
III.
Regardless of what increases overall paper recycling, at least 90% of that increase
will come from the post-consumer waste stream.
More than 90% of all paper recycling gains since 1988 and into the foreseeable
future will be "post-consumer," since virtually all pre-consumer recovered paper
grades are already in use.
This fact is inescapable regardless of how terms are defined, yet impractical
definitions can serve as obstacles and reduce the rates of increase for overall
paper recovery and recycling.
IV.
The AFPA Printing-Writing Recycled Content Initiative was developed to
maximize overall recovery and recycling of printing-writing grades.
Under the Initiative, manufacturers have the flexibility to produce and
customers the option to buy papers meeting either a minimum threshold of 10
percent post-consumer and/or processed recovered fiber OR a minimum
threshold of 50 percent recovered paper fiber, based on fiber weight.
The threshold minimums are designed to encourage:
the production of as many grades of recycled content printing-writing
paper as possible, and
use of the greatest amount of recovered fiber in the production of
printing-writing papers overall in the shortest period of time.
The term "processed recovered fiber" recognizes the need for sufficient supplies
of minimally contaminated and economically available recovered fiber to run
through processing facilities to recover the fiber for reuse in printing-writing
paper manufacture. Specialized processing is required of these papers to
remove inks, dyes, waxes and water insoluble adhesives, etc. before the paper
can be used in the remanufacture of recycled content printing-writing papers.
August 12, 1993
Printing-Writing Division
American Forest & Paper Association
Draft Presidential Executive Order on Federal Recycling
"Environmentally Preferable" Products and Services
I.
The "environmentally preferable" section of the draft White House Executive Order
goes well beyond the scope of the March 1992 Office of Federal Procurement Policy
(OFPP) policy letter without the benefit of public comment.
The "environmentally preferable" language used in the draft White House Executive Order
"refers to products or services that are less harmful to human health and the environment..."
The inclusion of "human health" in this definition expands the category beyond
that which was available for public comment in the March 1992 draft policy
letter.
While the March 1992 draft policy letter was available for public comment and review, the
Executive Order was not made available.
II.
The Executive Order, in its current draft, will dictate manufacturing practices -- in the
case of the pulp and paper industry totally chlorine-free (TCF) -- which is directly
contradictory to the language of the OFPP 1992 policy letter.
The OFPP specifically states, "the Policy Letter is not intended to dictate
manufacturing nor copying practices,"
III.
Many industries are concerned about reliance on Life Cycle Assessment (LCA)
methodologies to determine "environmentally preferable" products.
There is widespread acknowledgement that methodologies for life cycle analysis are not
adequately formulated for use in determining "environmentally friendly" or "environmentally
preferable" products and services, especially as they relate to human health.
In Green Report II, the State Attorneys General state, "Although product life
assessments or cradle-to-grave product analyses are expected to be extremely useful
for evaluating the overall environmental effects of various manufacturing processes
and products, the methodology for this type of assessment has not yet been fully
developed."
The Federal Trade Commission stated in the agency's Guides for the Use of
Environmental Marketing Claims, "These guides do not address claims based on a
'lifecycle' theory of environmental benefit. Such analyses are still in their infancy and
thus the Commission lacks sufficient information on which to base guidance at this
time."
EPA, in its February 1993 Life-Cycle Assessments: Inventory Guidelines and
Principles states, "Currently there is no single correct way to conduct a life-cycle
assessment."
August 12, 1993
American Forest & Paper Association
TALKING POINTS ON INITIATIVE AND EXECUTIVE ORDER
August 31, 1993
BACKGROUND
Early in September, President Clinton is expected to sign an Executive Order covering,
among other provisions, federal guidelines for purchasing printing-writing papers, defining
terms and mandating specific recycled-content percentages for the various grades of printing-
writing papers purchased by the United States government.
There has already been national media coverage of the draft document. As a paper
manufacturer and a member of the Printing-Writing Division of the American Forest & Paper
Association, you may be asked how this Executive Order will affect your company and how
it will affect the Recycled Content Initiative. The following talking points clarify how
customer specifications, such as those in the Executive Order, fit in the broader context
of the Recycled Content Initiative.
TALKING POINTS
The Printing-Writing Division of AFPA commissioned research to determine what
customers and others knew about recycled printing-writing papers, and found
widespread confusion in the marketplace. Acting on the research results, printing-
writing paper manufacturers created the Recycled Content Initiative to
accomplish three goals: clarify what constitutes a recycled-content printing-
writing paper; meet demand for these products in the marketplace; and
ultimately reduce the amount of paper in the wastestream. The Initiative,
announced in March 1993, will accomplish these goals in a way which takes into
account existing equipment capabilities and operations in the industry.
Under the Initiative, printing-writing paper is considered to have sufficient recycled
content to be labeled "recycled" if it contains at least 50 percent recovered fiber OR
10 percent post-consumer and/or processed recovered fiber. These thresholds create a
voluntary base level for participating companies.
The general idea of the Initiative is that less will be more. Through its workable
minimum thresholds, the Initiative makes it possible to use recycled fiber in the
widest range of printing-writing papers. Thresholds that require less recycled
content per sheet of paper will bring more papermaking machines and processing
equipment on line, which will, in the aggregate, lead to the use of more recovered
fiber. The Initiative will divert more paper from the waste stream than narrow
definitions or "quick-fix" high recycled-content levels could.
more --
Under the federal guidelines, only post-consumer materials will qualify for the
minimum content threshold of recycled-content paper. "Post-consumer" means paper
products which have been used in a certain way or by a certain user a magazine
which has been read, a piece of printed paper which has been written on or read, etc.
This limits manufacturers' incentives to recover printed paper from all possible sources
and makes collection and processing more costly, and ultimately results in higher costs
for recycled-content papers.
On the other hand, the Initiative encourages use of post-consumer and/or
processed recovered fiber, especially on the largest paper machines, at minimum
threshold levels or higher for printing-writing paper, to maximize diversion of
paper from the waste stream. "Processed recovered fiber" includes post-consumer
and other printed papers which may not have been read, such as an unsold magazine
returned from the newsstand. These products are collected, processed and returned to
the papermaking process. "Recovered fiber" is from any paper generated beyond the
papermaking process, including unprinted scrap from converting and finishing
operations. All these definitions include the equivalent recovered fiber for cotton-fiber
papers.
The Executive Order specifies minimum recycled-content levels only for printing-
writing papers purchased by the Federal government. Other purchasers of printing-
writing papers may establish specifications for recycled-content paper, just as the
federal government has done through the Executive Order. The Initiative, however,
establishes minimum recycled-content thresholds applicable to all types of
printing-writing paper, so all purchasers will know what they are buying and
will have a greater selection and volume of recycled-content papers to meet their
needs.
The proposed executive order also sets different minimum content standards for
certain papers, even though there may be no basis for distinguishing between them
from a manufacturing or use standpoint. Two grades of paper made on the same
paper machine must meet different standards even though the technology and
economic challenges to adding recycled fiber are the same.
Paper manufacturers want to offer customers a choice of products. They are also
committed to increasing recycling. Using the minimum thresholds for recycled
content established in the Initiative, printing-writing paper manufacturers can continue
to provide customers a wide array of recycled-content products from which to choose.
# # #
AUG 05 '93 15:59
P.2
DOBBERS
UNITED PAPERWORKERS INTERNATIONAL UNION
CHILL
WL-CIB,
WAYNE E. GLENN
August 5, 1993
Office of the President
President Bill Clinton
The White House
1600 Pennsylvania Avenue, NW
Washington, D.C. 20500
Dear Mr. President:
When 1 wrote you July 76, I expressed my union's concern that a proposed executive order,
originally developed by your environmental policy staff to regulate and encourage the federal
government's use of recycled paper, contained provisions related to government purchases
of totally chlorine-free paper (TCF).
Since then, I have had a chance to review a draft of that order. Sec. 503 of this draft would
require each federal agency under the control of the executive branch to set specific goals
for the amount of TCF paper it plans to purchase by 1995. I would like to know where they
will get the paper? As of now, there is only one small sulfite mill in the entire United States
that can produce TCF paper. By 1995, only one other mill in the U.S. will be producing
TCF pulp. If the agencies were forced to observe the TCF goals in this proposed order,
they would have to buy paper from foreign producers--if they could buy is si all.
This is not my only concern. The recycling issue is entirely separate from the question of
colorine vs. elemental chlorine-free (ECF) VS. TCF. Even if it were appropriate to begin
encouraging the use of TCF puper, an executive order on recycling is not the way to do it.
The chlorine-bleaching issue is a subject of intense controversy, both in the scientific
community and in the political arena. Whatever the environmental merits of switching to
ECF or TCF, there is no question It will cost the paper industry billions of dollars 10 make
such a change. It is not simply 1 matter of taking chlorine out of the bleaching pol and
putting ozone in. It is a matter, rather, of changing significant components of bleaching
processes that as a whole can cost hundreds of millions of dollars.
Again, an issue this significant for the pulp and paper industry should not be decided
through an executive order, particularly one designed to address a different problem. The
chlorine-bleaching issue needs to have b public airing on its own merits before any executive
or legislative action is taken.
INTERNATIONAL P © BOX 1675 NARMYELF. 11
31
TELEPHONE (BIS) 830.8300
AUG 05 '93 15:59
P.3
Page Two (2)
When I wrote to you in July, I expressed my concern that we had received no notice of this
proposal until it was within days of being finalized. This issue is of direct and immediate
concern to the vast majority of our 225,000 members. There is no question we should have
been consulted much earlier in the process of designing the proposal. There was a failure
to communicate here. Your administration needs to be open to workers, not closed.
Therefore, I respectfully request you remove all references of any kind to TCF pulp or
paper from the proposed executive order on recycling. I ask further that, if the federal
government wishes to sei goals and standards related to the purchase of chlorine-free paper,
it do so only after R full public hearing involving all points of view on the issue carried out
in conjunction with a thorough cast-benefit analysis by the OMB.
I would be pleased to meet with you and appropriate members of your staff at the earliest
reasonable time to discuss this issue in more detail. It is of crucial importance to the pulp
and paper industry, and to our members who have worked to contribute to the success of
your administration.
Thank you for the opportunity to share these comments. And again. best wishes for your
continued success.
Sincerely,
Wayne E Glenn
Wayne E Glenn
PRESIDENT
WEG:pme
CC:
UPIU International Executive Board
&
DEPARTMENT
UNITED PAPERWORKERS INTERNATIONAL UNIO
BRICE a
WAYNE E. GLENN
JAMES H. DUNN
President
Secretary - Treasurer
July 26. 1993
President Bill Clinton
The White House
1600 Pennsylvania Avc., NW
Washington, DC 20500
Dear Mr. President:
I have been informed that a proposed Executive Order on federal procurement of recycled paper will include
some form of requirement for the federal government to purchase chlorine-frue paper. This concerns me
a great deal.
If the contents of the proposed order are such that it ignores the economic and technological realities of this
industry. the price will be high. Only two mills in the U.S. are able to produce paper without using chlorine
chemicals. This means the order could force the government to rely on imports to meet its needs for paper.
Hundreds. perhaps thousands of jobs could be shipped overseas. Dozens of small and medium-sized
communities throughout the United States could be damaged, perhaps fatally.
The delegates to our 1988 Convention called for the phase-out of harmful chemicals in the pulping process.
We believe this must be done in ways that preserve our jobs and the nation's industrial base, as well as
protect the environment. I urge you to very carefully consider whether or not your order. as presently
proposed. meets this criterion.
It is impossible for me to conshent in more detail since neither I nor my staff have been informed of the
details of this proposed order. L troubles me that a policy move which could affect so many of our members
and determine the direction of the American pulp and paper industry for the next decade or longer was not
brought to my attention sooner. This is a policy issue which needs and deserves more, not less, than the
usual level of public input. And again, let me emphasize. this is no time to even appear to be shipping
America's industrial jobs overseas. Buy American should be the theme of our federal government.
I look forward to the opportunity to speak with you on this issue. If I can be of any additional assistance,
please let me know.
My best regards for your continued success.
Wayne Sincerely, E Glenn
Wayne E. Glenn
President
INTERNATIONAL HEADQUARTERS P.O BOX 1673 NASHVILLE TENNESSEE 37202 TELEPHONE (015) 834.8690
FIBER USED AT
U.S. PAPER AND PAPERBOARD MILLS
1992
Wood Residues
(24.4%)
Primary Fibers
(45.9%)
Recovered Paper
Provide (29.5%)
Other Fibers
(0.2%)
INTERALTIONAL
UNITED PAPERWORKERS INTERNATIONAL UNION
ORIGINA AFL-CIO.CLC HOIRE
WAYNE E. GLENN
JAMES H. DUNN
President
Secretary . Treasurer
July 26, 1993
Carol M. Browner, Administrator
U.S. Environmental Protection Agency
401 M Street SW, Mail Code A-100
Washington, DC 20460
Dear Ms. Browner:
It has come to my attention that the rules EPA plans to propose this year to regulate the liquid
effluent from pulp mills may severely impact a number of the mills where our members are
employed. I have in fact been informed that some mills will be unable to operate under the new
guidelines.
I cannot emphasize too much the need for any regulation EPA issues to be consistent with the
overall health of one of America's most successful industries. It's an industry that is at the
economic core of many of our small towns and cities. If it is true that EPA's new regulations will
force otherwise economically-viable pulping operations to close, the potential job loss will be an
absolute catastrophe for dozens of these communities.
The UPIU, which represents 225,000 members, believes in safe, healthy communities and safe
healthy jobs. In 1988 we called for the phase-out of harmful chemicals in the pulping process.
We believe this can be done, when needed, in a way that both preserves jobs and protects the
environment.
For example, the timing of mandates that force changes in the way pulp is bleached-if these
are unavoidable-should be synchronized with the life-cycles of the bleaching plants. The EPA
needs to carefully consider whether there is a real, as opposed to a purely political, need to limit
AOX emissions to less than 1.5 kilogram per ton of production. Some exceptions need to be
made for older mills, which may have difficulty complying with any mandate that requires
substantial new investment.
Whatever happens, it is clear that regulations requiring substantial new investment will drive up
the cost of domestically-produced paper. This in turn will tend to give foreign competitors of our
U.S. producers, some of which are not likely to be subject to these stringent mandates in the near
future, a price advantage. It is not fair to regulate the content of American production, when
imports are not required to meet the same standards. I cannot believe it is the EPA's intent to
drive our pulp and paper industry off-shore.
NASHVILLE
Therefore, I respectfully request EPA to reconsider both the content and the timing of its new
proposals. Regulations that respect the economic, technical and public-health realities associated
with pulp and paper mills can contribute to a viable, clean and growing industry. Regulations that
do not take these realities into account will severely damage the industry.
I look forward, in the near future, to the opportunity to discuss these issues with you and your
staff in more detail. Thank you very much for your time and consideration.
Sincerely,
Wayne E. Glenn
President
cc:
President Bill Clinton
Vice President Al Gore
FEDERAL RECYCLING, ACQUISITION AND USE OF ENVIRONMENTALLY
PREFERABLE PRODUCTS AND SERVICES
Fact Sheet
Recycled Printing and Writing Paper
Content Standards
On Earth Day President Clinton called for an Executive Order directing every agency of the
federal government to increase their efforts to buy and use recycled products. A section of the
Executive Order calls for new minimum content standards for recycled printing and writing paper and
requires agencies to buy only recycled paper. Below are a few facts regarding the standards.
Message
o
The new content standards will create a solid market for recycled printing and writing paper
containing postcosumer material, providing incentives for the paper industry to invest in new
technologies which utilize high quantities of recyclable material diverted from landfills.
o
Industry investment in new technologies and demand for recyclable materials will create many
new jobs in a number of different sectors of the economy.
o
Demand for recyclable materials will relieve the burden on cities, who cannot find markets for
these materials, and reduce the need to build new landfills and incinerators.
o
Recycling conserves energy and preserves precious natural resources.
Paper Production
o
According to the American Forests and Paper Association (AFPA), over 55% of total paper
production in the U.S. is printing and writing paper.
o
EPA estimates that the federal government accounts for 2% and state and local governments
account for 5% of the national paper market.
o
EPA's previous paper procurement guideline was issued in June of 1988 with implementation
in June of 1989. These guidelines require 50% of the fiber contained in printing and writing
papers purchased by the Federal government be made from recovered materials, if the paper is
available at a reasonable price.
o
The 50% wastepaper definition proved to be a barrier to large paper mills wishing to make
recycled printing and writing paper. In addition, mills primarily used preconsumer waste in
the production of this product, including mill scraps and sawdust. Very little recycled material
was diverted from the waste stream to make this 50% recycled paper.
o
Recognizing that these standards were weak, many state governments adopted strict standards
in an effort to include postconsumer waste in recycled printing and writing paper. States such
as Arizona, California, Illinois, Kentucky, Minnesota and Rhode Island require 50% recycled
paper and at least 10% postconsumer waste.
New Markets
Cities, counties and towns across the country are searching for markets for their collected
recyclable paper. In an attempt to boost the market for recyclable materials, OEP decided to
seriously consider the industry's proposal to replace the 50% wastepaper standard with a lower
percentage postconsumer standard to ensure that larger mills would be able to make a low cost
recycled printing and writing paper.
o
The industry estimates that about 75% of its capacity to make high grade commodity papers is
at mills that contain large, fast, state-of-the-art paper machines.
The Standards
o
The new standards require Federal agencies to procure high grade recycled printing and
writing paper containing 15% postconsumer waste (pcw) by 1994, 20% pcw by 1996 and 25%
pcw by 2000. By removing the 50% wastepaper standard we ensure that larger mills will
begin to utilize high quantities of postconsumer waste in their production of printing and
writing paper.
Non-commodity or lower grade papers must also meet the above content standards but also
include 50% wastepaper. This preserves a market for small mills where these papers are
made.
The AFPA estimates that a majority of its large mills can easily make a recycled printing and
writing paper containing at least 10% postconsumer material/processed recovered fiber.
Though unpredictable, the EPA estimates that a number of large recycled paper printing and
writing mills can produce a 15% pure postconsumer paper.
As the large mills begin to produce this new recycled paper prices will drop, removing an
additional barrier to agencies wishing to buy this product. The costs to produce 50% total
recycled content paper at a large commodity mill was almost 30% higher than the production
of virgin. The cost to produce 15% postconsumer content will only be 9 to 12% higher.
Paper as Solid Waste
o
According to EPA, paper and paper products constitute 37.5% of the municipal solid waste
stream. A study conducted by EPA revealed that paper and paper products represent
approximately 77% of office wastes in a typical federal agency.
o
EPA estimates that 20 million tons of recyclable printing and writing paper are disposed of
annually. Current federal government procurement of recycled printing and writing paper
diverts less than 2,000 tons of postconsumer materials from landfills. If all printing and
writing paper purchased by GSA and GPO met the proposed 15% postconsumer materials
content standard, approximately 55,000 tons of postconsumer materials would be used.
Assuming that state and local governments and 20% of private sector purchases adopt the 15%
standard, over 1 million tons of postconsumer material will be used.
FEDERAL REYCLING, ACQUISITION AND USE OF ENVIRONMENTALLY
PREFERABLE PRODUCTS AND SERVICES
Questions and Answers
Recycled Printing and Wrting Paper
Content Standards
and Total-Chlorine-Free Paper Goals
Recycled Paper Content Definitions
Q.
Why does the Executive Order focus on recycled content standards for printing and writing
papers?
A.
Currently, despite the fact that EPA has established recycled content standards for printing and
writing papers, the Federal government is not purchasing appreciable quantities of many kinds of
printing and writing papers. For example, the General Services Administration reports that, last
year, less than 8 % of xerographic papers and none of the computer paper purchased by the
Federal government contained recovered materials.
o
The principal reason that little or no xerographic and computer papers containing
recovered materials were purchased is that they cost substantially more (between 25 and
33 % more) than comparable virgin papers.
Q.
Why do recycled printing and writing papers cost more than virgin papers?
A.
Not all recycled printing and writing papers cost more than virgin printing and writing papers.
There are many printing and writing paper products (e.g., text, cover, bond papers) that cost about
the same whether they contain recovered materials or not. This is because they are "specialty"
grades of papers that are manufactured on smaller paper machines that compete with one another.
Because of the nature of these "specialty" papers, they are not mass produced on the larger, faster
machines used by industry to produce so-called commodity grades of papers (e.g., xerographic,
off-set printing, computer, and forms papers).
At the present time, commodity grades of printing and writing paper containing recovered
materials cost more than commodity grades made from virgin materials. This is because
commodity grades containing recovered materials are currently produced on small to medium
sized paper machines at non-integrated paper mills (mills that do not have the ability to convert
wood chips or whole trees into pulp and then into paper; these mills purchase pulp made at other
mills and produce paper from the purchased pulp). These small to medium sized machines are
less efficient than the large, fast machines used to make commodity grades from virgin materials.
o
Industry estimates that about 75 % of its capacity to make commodity grades of paper
(e.g., xerographic, computer, off-set printing, and forms papers) is at mills that contain
large, fast, state-of-the-art paper machines. These mills are fully integrated and rely on
wood chips or whole trees as their exclusive raw material source. They take advantage
of economies of scale and can make paper at a lower cost than the small to medium sized
mills where recycled xerographic and other commodity grade papers are made.
Q.
What is the Executive Order trying to accomplish?
A.
The purpose of the Executive Order, among other things, is to provide an incentive for mills with
the larger, faster paper machines to use recovered materials, not just virgin materials, to make
paper. This will provide markets for paper recovered from the municipal solid waste stream and
ultimately result in substantially lower prices for commodity grade papers that contain recovered
materials.
o
For paper recycling to flourish, it will be necessary for mills to use recovered paper in
addition to virgin materials on their larger, faster paper machines. EPA's current paper
guideline requires that 50 % of the fiber contained in printing and writing papers
purchased by the Federal government must be made from recovered materials, if the paper
is available at a reasonable price.
o
We have found that this 50 % content standard is a barrier for the large, integrated mills
where the major portion of commodity grade papers are made. To meet this standard
would require that the mill close down one-half of its pulping operation and purchase an
equivalent amount of pulp made at a deinking mill from recovered paper. We estimate
that this would increase production costs by at least 30 %, with no likelihood that the
increased production costs could be passed on to customers. This would be a bad
business decision and one that the industry has appropriately decided not to make.
Q.
How does the Executive Order provide an incentive for the larger paper machines to begin
using recovered materials to make paper?
A.
The Executive Order establishes content standards for commodity grade printing and writing
papers that are substantially more modest than the 50 % level currently contained in EPA's paper
procurement guideline. The level is initially set at 15 % postconsumer recovered materials and
would escalate to 25% in the year 2000.
We believe that the 15 % level is technically achievable on the high speed machines and will
have substantially less impact on production costs than the current 50 % recycled content standard
contained in EPA's existing paper guideline. Over time, as the mills become more familiar with
using recovered materials on their high speed paper machines, they will be able to increase the
amount of recovered materials they use relative to virgin materials. Additionally, by providing
industry with a clear signal that it is the Federal government's intent to purchase paper with a 25
% recycled content in the future, the industry will be able to make plans to meet the government's
demands. We anticipate that individual companies will elect to construct their own deinking
plants to make pulp from recovered materials and will substantially reduce their fiber costs when
compared to purchasing deinked pulp from others.
Q.
Why won't the 15 % postconsumer recycled content standard be a technological barrier to
the large, virgin integrated mills where commodity grade papers are made?
A.
Based on conversations with numerous paper industry representatives, there are apparently no
technical reasons why all of these mills could not make commodity grade papers with 15 %
postconsumer recovered material content. Mills do not need to retrofit their plants to feed deinked
fiber into the paper machines.
Q.
Are there any other barriers that would preclude the large, virgin integrated mills from
meeting the 15 % postconsumer recycled content standard?
A.
Based on discussions with industry representatives, materials provided by individual paper
companies, and our own analyses, we are convinced that, over the short term, it will cost these
large, virgin integrated mills more money to make paper that contains recovered materials than
if they continue to use only virgin raw materials. Thus, the cost of recycled commodity grade
papers in the near term will be higher than equivalent virgin papers if the industry chooses to pass
these increased costs on to their customers.
Q.
How much more will it cost?
A.
We do not know for sure what the increased costs will be over the short term. We know that the
incremental cost will increase as the amount of recycled content increases. This is because the
large, virgin integrated mills do not have the ability to produce their own deinked pulp and must
purchase it from other sources. Simply put, it costs them less to make virgin pulp at their own
facility than to buy deinked pulp from another manufacturer. [One source reports that purchased
deinked pulp costs $400 per ton more than virgin pulp made at its mills.]
Based on data received from industry, we have made some crude estimates of the likely cost
increase for various levels of recycled content at a large commodity grade mill:
50 % total recycled content:
at least 30 %
15 % postconsumer content:
9 to 12 %
10 % postconsumer content:
6 to 8 %
[NOTE:
An off-the-record conversation with one paper company official indicated that
cost increases to meet a 10 % recycled content standard would be about 10 %,
consistent with our estimates.]
Q.
Over the long term, do you anticipate that the cost of recycled commodity grade papers will
exceed the cost of virgin commodity grade papers?
A.
As mills become more familiar with the properties of recovered materials, it is likely that they will
find it easier to use them. Additionally, as companies make the decision to build their own
deinking plants, their costs will decrease because they can make deinked pulp at lower costs than
they can pay to have someone make it for them. Thus, we expect that over the long term the cost
of recycled commodity papers will approach the cost of virgin commodity papers. We do not
have the data or information that would enable us to predict when that might occur, but it is
reasonable to assume that it may take more than one investment cycle (an investment cycle is
about 5 years).
Q.
In this time of severe budget constraints, it appears that your approach will end up costing
the government and, therefore, the taxpayers more money. Can you explain?
A.
We are very concerned about any action that would increase the government's costs of doing
business. Thus, in addition to establishing minimum recycled content standards for paper, the
Executive Order caps government paper purchases at typical spending levels for the various
agencies. We anticipate that any increased paper costs will be offset by reductions in the amount
of paper used by the agencies. This provides an incentive for agencies to implement waste
prevention techniques such as double-sided copying and use of electronic communications
methods. Thus, agencies will be able to purchase recycled paper without increasing their current
budgets.
Q.
Your focus seems to be on the large mills. Will the smaller mills still be able to conduct
business with the Federal government?
A.
The small mills typically produce so-called specialty products, such as text and cover, bond, and
writing papers. The Federal government has been able to buy these kinds of printing and writing
paper with recycled content, and is likely to be able to do so in the future. The Executive Order
establishes separate recycled content standards for these kinds of papers. The standards reflect
the current state-of-the-art at the small mills where these papers are made. They would require
50 % total recycled content of which 15 % would be postconsumer recovered materials. The
postconsumer content standard would increase to 25 % in the year 2000.
This approach ensures that small mills will be able to market their recycled paper products to the
Federal government. They will continue to compete with one another for the government's
business.
Q.
What reactions do you anticipate from the paper industry regarding the recycled paper
content standards contained in the Executive Order?
A.
We expect that the paper industry will react unfavorably to the 15 % postconsumer content
standard. They are seeking as much flexibility as possible. They want the content standard to
be as low as possible and strongly prefer that both preconsumer and postconsumer recovered
materials be allowed to count toward the content standard.
o
Industry has argued that the best way to build markets is to get every mill to participate
in the production of recycled paper. They want every machine and every company,
including the larger, faster commodity grade mills, to be able to utilize scrap paper in
their production processes.
o
The industry is advocating two equivalent standards: (a) 10 % postconsumer/processed
recovered fiber (this includes postconsumer recovered materials as defined in RCRA and
printers and other preconsumer wastes that have coatings or have been printed on); and
(b) 50 % recovered paper (this includes all preconsumer and postconsumer recovered
materials). They argue that this approach allows both big and small mills to compete
across all grades.
o
We have some concerns about this approach--paper companies will be able to meet the
government's needs by using only preconsumer recovered materials. There are enough
coated and printed preconsumer wastes to allow the industry to use only these materials
in the paper they sell to the government. Thus, we favor an approach that stimulates
markets for postconsumer materials that are being recovered from the waste stream
through such activities as office paper recycling programs and curbside collection
programs operated by local governments. Industry's approach does not do that.
Q.
What reaction do you anticipate from State and local government officials?
A.
State and local government officials should generally be supportive of the Executive Order. They
have been strong advocates of postconsumer recovered materials content standards for printing and
writing papers. Because they are responsible for running our nation's recycling programs, they
want to ensure markets for the materials that are diverted from the solid waste stream. In fact,
if we do not include postconsumer content standards, it is likely that our effort will be largely
ignored by many State and local governments. This would lead to a myriad of different standards
that the industry would have to meet if they choose to market their products to the various
Federal, State, and local government agencies.
Q. What reaction do you anticipate from environmental groups?
A.
Environmental groups will support our goal of encouraging the large, integrated mills to recycle
postconsumer recovered materials. These groups have been strong advocates of postconsumer
recovered materials content standards for printing and writing papers and will believe that the
Executive Order is focused on the "right" kind of recovered materials. They have been extremely
critical of industry for not using postconsumer recovered materials in manufacturing printing and
writing papers. They have also criticized EPA for not establishing postconsumer content standards
in the paper guidelines the Agency issued in 1988.
These groups would like to see higher content standards than the 15 % standard contained in the
Executive Order. They have generally advocated higher levels on the order of 20 to 25% in the
short term escalating to 50 % over time. We believe that it is premature to expect the large,
integrated mills to increase postconsumer content standards from the current level of 0 % to a
level of 20 %. We believe that it is much more likely that companies will elect to upgrade their
facilities by adding deinking equipment if we provide sufficient lead time before they must
achieve levels on the order of 20 to 25 %. Thus, the Executive Order establishes a 15 % standard
to be achieved one year from issuance of the order and establishes a 25% standard to be achieved
by the year 2000. This will provide the lead time necessary for companies to do the advanced
planning needed to modify their existing facilities.
These groups are adamantly opposed to the approach suggested by industry. They would view
adoption of industry's approach as a sell out. They favor standards that reward the use of
postconsumer, not preconsumer recovered materials, and clearly believe that a 10 % standard
would reward industry for what they would view as a "baby step."
PHOTOCOPY
PRESERVATION
Total Chlorine Free
Q. How will the proposed Executive Order affect TCF?
A.
The draft Executive Order requires agencies to establish goals for the purchase of TCF paper by
1995. It also requires federal agencies to eliminate unnecessary brightness specifications to
encourage the purchase of recycled paper.
Q. What environmental or health problems are associated with the use of chlorine in bleaching?
A.
The widespread use of chlorine in pulp bleaching has led to a variety of environmental problems,
including chloroform air emissions and dioxins, furans, and other chlorinated organics in
wastewater. Two years ago, EPA began a reassessment of the risks associated with exposure to
minute traces of dioxin. While that study is not yet complete, it is likely to suggest that levels
of dioxin below current detection limits may contribute to significant noncancer health effects.
Q. Why is "Totally Chlorine Free" bleaching a good idea?
A.
Given current uncertainty surrounding the health effects of minute traces of dioxin and other
hazardous chlorinated organics, the Executive Order encourages TCF, which eliminates the root
causes of dioxin by eliminating chlorine altogether. Inclusion of TCF in the Executive Order is
consistent with the regulatory and policy direction of the EPA. The integrated water/air rule for
the pulp and paper industry, to be proposed in October 1993, is moving the industry toward low
and non-chlorine bleached production of paper products.
Q. What will be the industry reaction to TCF?
A.
The industry has opposed TCF because it results in less white paper for which the industry has
suggested there is no market. Kraft mills will be able to meet the standard without completely
eliminating chlorine use. However, some companies (most notably Louisiana Pacific) are
committing to TCF technology. LP has argued that the procurement executive order must include
incentives for government purchases of TCF paper.
Q. What will be the reaction from the environmental community?
A.
The environmental community completely supports efforts to move to TCF procurement. A
number of environmental groups are conducting a campaign to force the EPA to further regulate
chlorine discharges from the pulp and paper manufacturing process.
Q. Is this TCF goal unfair to the industry?
A.
Under the language included in the draft executive order, we are not requiring industry to do
anything; we are simply letting agencies determine goals for themselves. Industry may choose
to switch to TCF production if it is in their economic interest to do so. Pulp and paper companies
are undergoing major upgrades and renovations now, and will be making more changes as a result
of the integrated water/air pulp and paper rule. If TCF is the direction we would like industry to
move, we should be promoting TCF paper in the Executive Order.
PHOTOCOPY
PRESERVATION
But one participant at the meeting
were whether jobs might be lost under
the Administration hard, since every
White House Nears a Decision on Recycled Paper
today, Alan Hershkowitz of the Natural
various approaches and whether the
ton of paper that is recycled and bought
Resources Defense Council, said he
industry would be able to supply all the
by the Government is a ton that need
was confident that the Administration
Government's needs if the stricter
not go into municipal landfills or dis-
would call for a strong new standard.
standard was adopted.
posed by other means.
By JOHN H. CUSHMAN Jr.
Government.
processors.
Mr. Hershkowitz noted that Vice
Special to The New York Times
Those who favor a major Govern-
The Administration circulated a
Influencing Market
Federal policy calls for the nation to
President Al Gore had called for such
recycle 25 percent of all solid waste,
WASHINGTON, Sept. 27 - The
ment intervention want to see an exec-
draft this summer that pleased those
measures in his book on environmental
Although no single customer domi-
said David Gatton, environmental ad-
White House, which is about to decide
utive order requiring that all printing
who wanted the more aggressive ap-
issues, published while he was a Sena-
nates the paper market, the Govern-
visor at the National Conference of
whether the Government should buy
and writing paper used by the Govern-
proach.
tor, and had even offered legislation
ment buys 300,000 tons of printing and
Mayors, who attended the meeting at
more recycled paper, today called in
ment include a minimum proportion of
Two weeks ago, environmental advo-
calling for half of all material bought
writing paper a year, giving it a mar-
the White House. But only 17 percent of
representatives from industry, envi-
recycled paper, starting at 20 percent
cates began contending that the Ad-
by the Government to be made 50
ket share of 1 percent dr 2 percent of
waste is currently being recycled.
ronmental groups, labor unions and
and increasing later.
ministration, after heavy lobbying by
percent from waste.
total consumption and making it
"If we don't have a Federal procure-
cities for a last round of debate on the
Others, including big paper compa-
the industry, appeared to be backing
At today's meeting, no decision was
among the very largest buyers. Its
ment policy that helps push the mar-
hotly contested details.
nies, oppose this on grounds that it
away from its original plan.
announced, but one is expected within a
procurement standards would clearly
kets, and the private sector, to use
At issue is how to fulfill President
would disrupt production and cost jobs.
The most senior Democrats in the
few days. The meeting was led by the
influence the whole industry.
more recycled content materials, we
Clinton's promise, made in April at
They prefer a rule that calls for only 10
House and Senate, Speaker Thomas S.
President's top environmental aide,
The Administration's decision could
are never going to make it to 25 per-
Earth Day festivities, to give a vigor-
percent recycled content and perhaps
Foley of Washington and Senator
Katie McGinty, and by Alice M. Rivlin,
mean big financial rewards to compa-
cent," he said.
ous stimulous to the market for recy-
uses a looser definition of recycling
George J. Mitchell of Maine, both of
deputy director of the White House
nies that can meet the new require-
cled paper by putting the buying power
that includes materials like magazines
whom have big constituencies in the
Office of Management and Budget.
ments, and some in the paper industry
of one of the biggest single consumers
that were published but never bought,
forest product industries, were said to
Participants said they were asked to
favor the more aggressive approach.
Get new ideas on the Op-Ed Page.
on the side of recycling, the Federal
or even certain scrap from the paper
be pushing for the looser standard.
discuss several questions. Among them
Local governments, too, are pushing
family is seeking payment of about
or obey their signals to land. Peru
on April 5, 1992. He shut down the
U.S. and Peru at Odds Over Death of Airman
$900,000, which an Air Force analysis
claims its pilots feared that the large
Congress and the courts, in an effort to
calculated would be the present value
transport was carrying drugs.
stop corruption and combat the leftist
of the sergeant's earning power over
Yet, if the Helms amendment is ap-
guerrilla group called the Shining Path.
his expected lifetime. Peru is offering
proved over the next few days by a
Though strongly supported by Peru-
By NATHANIEL C. NASH
the family of Sgt. Joseph Beard.
Peru, but there hadn't been any move-
to pay between $100,000 and $150,000.
House-Senate conference committee,
vians, he became almost an interna-
Specialio The New York Junes
Sergeant Beard fell from the Ameri-
ment on compensating the Beard fam-
In a country with so much poverty, a
Mr. Fujimori will have little choice if
tional pariah and has been struggling
LIMA. Peru, Sept. 24 - The attack
can C-130 military transport at 20,000
ily for months," a member of Senator
deep recession and average monthly
Peru is to get the much-needed aid.
since to convince Western nations that
feet off the northern coast of Peru,
Helms's staff said in a telephone inter-
wages of about $60, a payment of al-
"The position of the Peruvian Gov-
his actions were his only recourse to
on a United States military transport
plane by two Peruvian jet fighters in
when strafing by Peruvian fighters
view. "This is a very sensitive issue in
most $1 million to the family would
ernment and the results of the investi-
prevent the Shining Path from toppling
blew a hole in the fuselage, on April 24,
the Congress because the death of a
unleash criticism. There is also fear
gation were clear, that there does not
the Government.
April 1992, in which an American air-
1992. His body has never been found.
United States serviceman is involved,
man was sucked out of the plane, has
that if Mr. Fujimori agreed to such a
exist the responsibility in reference to
In the wake of what is called the
The amendment, sponsored by Sena-
and responsible nations, when this kind
payment, it would cause deep resent-
this case," Mr. Fujimori said. "But the
Fujimori coup, the United States
come back to haunt the Government of
tor Jesse Helms, Republican of North
of thing happens, do what they can to
ment in the armed forces, which still
Government of Peru, on humanitarian
stopped all but relief aid. When less
President Alberto K. Fujimori and
strain relations with the United States.
Carolina, has the support of Democrat-
compensate the families."
assert that they were justified in shoot-
grounds, is trying to compensate for
than three weeks later the Peruvian
A foreign aid appropriations bill
ic senators, and seems to reflect the
The amendment also instructs the
ing at the plane.
the debts.'
jets strafed the American C-130, it only
Clinton Administration's policy of us-
United States to urge international
Mr. Fujimori repeated the Govern-
According to Peruvian officials, the
added to the acrimony.
passed by the Senate on Thursday in-
ing foreign aid to Peru to improve the
lending organizations to withhold loans
ment's claim that Peru was not respon-
cooling of tensions between Peru and
"Our point is that even when we
cluded an amendment prohibiting the
United States from disbursing $100 mil-
Fujimori Government's record on hu-
to Peru until a settlement on the Beard
sible for the incident, and that the
the United States is important for Mr.
know we are tracking a plane loaded
lion in aid planned for the Peruvian
man rights and respect for internation-
issue is reached.
shooting was provoked by the pilots of
Fujimori, since he travels to the United
with drugs, we don't shoot it out of the
al codes of conduct.
The case presents thorny issues for
the American plane, who refused to
Nations next week to present his case
sky," said a State Department official
Government in the 1994 fiscal year,
"The desire is not to be punitive with
Mr. Fujimori and Peru. The Beard
communicate with the Peruvian pilots
for seizing almost dictatorial powers
who asked not to be identified.
until Peru settles damage claims with
THE NEW YORK TIMES, TUESDAY, SEPTEMBER 28, 1993
ID:
SEP 20'93
11:12 No. 003 P.01
NR
FAX TO BRIAN BURKE
DC
Natural Resources
Defense Council
1350 New York Ave., N.W.
Washington, DC 20005
202 783-7800
Tur 202 783-5917
9/20/93
Brian:
As promised, here is georgia Pacific's declaration to
the public that they will not make TCF products
even if their customers want them.
Also for your information, an editorial
from 1991 warning US producers that chlorine-
dependent technologies are "stopgap" (transitional)
Ones.
When will US manufacturers get the message? ^.
Jessica Landman
202-624-9341
10040 Kerycled Paper
10 West 20th Street
71 Slevenson Street
617 South Olive Street
212 Merchant St., Suite 203
"
New York, New York 10011
San Trancisco, CA 94105
Los Angeles, CA 90014
Honolulu, Hawaii 96813
212 727-2700
415 777-0220
213 892-1500
808 533-1075
Fax 212 727-1773
Tax 415 495 5996
Fax 213 629 5389
Fax 808 521-6841
ID:
SEP 20'93
11:12 No. 003 P.02
COMMENT
G-P takes a position on chlorine-free pulps
T he issues of dioxin. chlorine.
CHLORINE DIOXIDE INVESTMENT. We
chlorinated organics, and adsorbable organic
have reached a point now where we must
halogens (AOX) have been topics of great.
decide whether to continue to invest in
debate in our industry for several years. As
increased chlorine dioxide substitution with
the largest supplier of market pulp in the
a long-term goal of virtual elimination of
world. Georgia-Pacific Corp. has devoted
elemental chlorine from our bleach plants. or
tremendous time and resources toward
to abandon our assets and these plans in a
understanding these issues. We have now
quest for bleaching processes that utilize no
reached decisions that will be the basis for
chlorine ions. The cost of seeking
our business strategy In the coming years.
nonchlorine compounds for the bleaching
First, let me assure you we did not make
process would be enormous without any
these decisions lightly. The stakes for
corresponding health benefit offset and
Georgia-Pacific and for you are enormous. We
would force Georgia-Pacific from our position
A.D. "PETE" CORRELL
must continue our corporate heritage of
as the largest and most competitive market
is president and chief
environmental stewardship balanced against
pulp supplier. We find no scientific rationale
operating officer of
8 commitment to you. our customers, to
for such an ill-conceived move and have
Georgia-Pacific Corp.
provide a cost-effective raw material so that
rejected the Idea. We will continue to invest
The following is taken
you can compete in the increasingly competi-
in chlorine dioxide substitution at our bleach
from a letter Mr.
tive world paper markets. We have used the
plants.
Correll sent to G-P's
best scientific expertise available. much from
The key question is. "What does this mean
pulp customers.
research that we have supported. to assist us
to you. our valued pulp customer?" First, it
in reaching our decision. We will continue to
means that Georgia-Pacific will continue its
support research and monitor all scientific
commitment to be the environmentally
and technical findings in this area.
sensitive. low-cost producer of the highest-
quality market pulp to the industry. We are
NO HEALTH RISK FOUND. The fact is
convinced that our business stratogy is sound
that Georgia-Pacific can find no scientific
and are continuing to fund our market pulp
evidence to indicate measurable
business in spite of these very difficult times.
environmental or health Impacts linked to
Second. it means you can plan your supply
the release of properly treated mill effluents
needs around that commitment. If you feel
from our pulp and paper mills that use
you must have "chlorine-free" bleached
chlorine in the United States. Despite many
pulps which cannot have used even
claims by environmental groups to the
chlorine dioxide and your markets will
contrary. the scientific evidence indicates
accept the differences in quality and
that our level of use of chlorine is
performance. then G.P can no longer be a
environmentally safe.
supply source.
When it became known that minute levels
Georgia-Pacific has an impressive array of
of dioxin were formed as an unwanted by-
world-class market pulp mills located in low-
product of the chlorine bleaching process,
cost fiber baskets. Our softwood mills at
Georgia-Pacific moved aggressively to
Brunswick [Ga.] and Leaf River [III.] are
understand the issue. Any dioxin formation
among the world's best. Our hardwood mills
at our mills was incredibly small and near or
at Ashdown [Ark.]. Woodland [Maine], Port
below conventional detection limits. None-
Hudson [La.]. Leaf River, and Palatka [Fla.]
theless. we invested more than $100 million
produce cost-effective pulps that can reduce
to reduce those minute amounts by more than
your pulp cost and improve your quality. At
85% to levels that are beyond any human
all of these mills our commitment to serve
health risk, even using the most conservative
you and protect the environment is
assumptions. Our operating strategy has been
enduring. We are convinced these strategic
to increase use of chlorine dioxide, and
decisions will serve all of us well in the
decrease amounts of elemental chlorine.
coming years.
188
PULP & PAPER APRIL
ID:
SEP 20'93
11:13 No. 003 P.03
Industry on threshold of nonchlorine era
*
In recent months. the world paper
CIO, for Cl) rose dramatically as mills spent
industry has taken some meaningful steps
an average of $15 million/20 tons of
toward nonchlorine bleaching of chemical
generating capacity. Spending for this stopgap
pulps. Currently, only two mills are reported
technology is continuing. U.S. environmental
to be using or are in the process of installing
expenditures this year, for example, will
commercial-scale. nonchlorine capacity:
increase to $1.4 billion. compared with only
Union Camp Corp. at Franklin Va., and
$465 million two years ago. A high percentage
Lenzing AG at Lenzing, Austria. But more
of this spending is for additional chlorine
companies are looking at ozone/oxygen/
dioxide capacity.
peroxygen-based bleaching. and others will
In the very near future. many of these
surely follow the lead of these two mills.
same mills will again be asked to invest
Ozone technology is not new. Several
heavily in ozone generation capacity. Again.
paper companies have been exploring and
the economic burden will be heavy. but one
developing alternative ozone-anchored
potentially major side benefit is the
KEN PATRICK
sequences for more than a decade. The
opportunity to finally close up pulp mill
is editor in chief
commercial feasibility of a high-brightness,
effluent streams. Elimination of waste
of Pulp & Paper.
nonchlorine bleaching sequence for even
treatment represents I considerable
southern softwood kraft pulps has been
economic incentive for most mills, but,
WHAT' S
known for some time. and eventually most
possibly more importent, it could remove the
modern. large chemical pulp mills worldwide
paper industry from many environmentalist
AHEAD
will no doubt be weaned entirely from the
hit lists. What a relief that would be.
use of elemental chlorine and even chlorine-
containing compounds.
THE NEXT CENTURY. Two articles in
POWER AND
Obviously. some process and economics
this issue look at emerging trends in chemical
STEAM
complications still have to be resolved. Keys
pulping. Beginning on page 110. vanguard
Analysis of requirements for
to the efficient and economical use of ozone
bleaching developments being installed at
recovering steam from à
include a fairly low kappa number to the
mills today are traced into the next century.
thermomechanical pulping
Probable sequences are explored based on
system; welding-based repair
bleach plant and carefully controlled pH and
of turbine rolors offers 8 viable
temperature. Recent advances in the cooking
successes and failures of several new
alternative for pulp and paper
stages. including Kamyr's MCC/EMCC
approaches. A hypothetical case study of a
mills; guidelines for
systems for continuous digesters and Beloit's
bleached softwood kraft mill of the next
turbogenerator maintenance in
RDH and Sunds Defibrator's Super Batch
century (p. 57) analyzes not only future
paper industry power plants:
Green Bay Packaging reduces
technologies for batch digesters. have opened
technology in relation to anticipated
tube failure and boller
the door for lower kappa pulps while
environmental demands but also looks at the
downtime by eliminating Iron
maintaining respectable. or even improved.
detailed costs of installing and operating it.
oxide deposition in returned
strength properties.
A special Pulp & Paper report on pulping
mill dryer condensate
Advances in oxygen delignification are
and bleaching technology of the twenty-first
TRAINING
also playing a major role in getting kepps
century will be published separately and
Examination of deficiencies
numbers down to "ozone-level" bleaching
distributed with a near-future issue of the
and problems with traditional
particularly for kraft softwood pulps. Kamyr,
magazine. This report will examine not only
training methods in
Impco, end Sunds are ploneering some new
new pulping technologies but also the driving
comparison with newer, more
Innovative approaches;
approaches to both oxygen delignification
forces behind their implementation during
Canadian pulp and paper mill
and bleach plant design that should help
the next 10 to 15 years.
Improves operator and
usher in a nonchlorine era later this decade.
Also as part of our continuing coverage of
maintenance personnel skills
current and future pulping and bleaching
with computer-simulation
developments, Pulp 8 Paper, along with
training system: profile of
MONEY WELL SPENT. The paper
computer-based training
industry has taken big steps toward reduced-
Emerging Technology Transfer Inc., is
programs at two Southeastern
and nonchlorine bleaching. After the "chloro-
sponsoring a conference on nonchlorine
paper mills
toxin" problem in bleach plant effluents was
bleaching March 2-5, 1992, at Hilton Head.
first discovered only a few years ago, mills
S.C. This special meeting will examine the
EXPANSION/
moved quickly to get levels of dioxins and
current status of reduced- and nonchlorine
MODERNIZATION
Canadian Pacific Forest
furans, in particular, within hastily imposed,
bleaching in Europe, Scandinavia, North
Products brings new newsprint
stringent government requirements.
America. Australasia, and several third world
machine and deinked fiber
Investments in chlorine dioxide
countries. More information is available on
system online at its Thunder
generation capacity (to boost substitution of
page 100 of this issue.
Bay. Ont., mill
PULP & PAPER NOVEMBER 1991
9
EDF
ENVIRONMENTAL
DEFENSE FUND
Capital Office
1875 Connecticut Ave.. N.W.
Washington. DC 20009
(202) 387-3500
Fax: 202-234-6049
RECOMMENDATION FOR A FEDERAL PROCUREMENT STANDARD
FOR PRINTING AND WRITING PAPER
AND
RESPONSE TO AFPA'S PROPOSED DEFINITION AND STANDARD
July 29, 1993
The establishment of a federal procurement standard is not the equivalent of a
mandatory recycled content standard; it is a voluntary program with respect to participation
by paper manufacturers. Those companies that choose not to (or cannot) produce paper that
meets the standard are in no way excluded from the marketplace; they simply pass up the
opportunity (not a right by any means) to sell their paper to the federal government.
EDF Recommendation
EDF recommends a one-tier post-consumer standard, rather than a two-tiered (e.g.,
pre- and post-consumer or total and post-consumer) standard. We also recommend the
standard be based on a strict post-consumer definition, not on a "deinked" or "processed"
recovered fiber definition, as proposed by AFPA.
We further recommend that a federal procurement standard specify at least 20% post-
consumer content for the purchase of printing and writing paper by federal agencies. For
grades of paper that are very difficult to produce with this level of recycled content, such as
lightweight coated papers, the post-consumer content level could be relaxed to 15%. (These
numbers are offered on a fiber weight basis.)
These levels we regard as quite modest and readily achievable in the short term if not
immediately. It is essential, however, that the minimum content level be increased over time.
This will serve the important function of providing a clear signal to paper manufacturers as
they consider near-term investments in future capacity. We regard as feasible in the medium
term minimum post-consumer content levels of 25-30%, and recommend that any federal
standard specify such levels.
Response to AFPA Definition and Standard
1.
Why shouldn't the definition of materials to which the procurement standard
applies be expanded beyond post-consumer materials to include other "processed
recovered fiber" sources, as proposed by the American Forest and Paper
Association (AFPA)?
The two major categories of materials included in "processed recovered fiber" that are
not post-consumer materials are: (1) converting scrap; and (2) over-issue/returned materials.
There are several major reasons why these materials should not be given "credit" under the
procurement standard.
a. Inclusion of these materials at this time would amount to changing the rules in the
middle of the game, unfairly penalizing paper manufacturers that have made the investments
in processing equipment required to handle post-consumer materials.
Post-consumer paper is almost always more contaminated, more difficult to process by
paper mills, and more uncertain as to its content (i.e., types of contaminants and fibers) than a
pre-consumer equivalent (e.g., newspaper recovered in a curbside collection program vs. over-
issue newspapers returned by distributors). Post-consumer paper is thus the overwhelming
focus of concern for municipal and private recycling collectors, and for all those who seek to
reduce the amount of waste going to landfills and incinerators.
A strict post-consumer standard provides a clear signal that the paper mills that invest
in R&D and technology to recycle more difficult-to-process post-consumer paper -- and
thereby make the most direct and measurable contribution to reducing paper disposal -- will
receive the greatest reward in the marketplace. Conversely, a less rigorous standard, such as
the AFPA proposal, rewards mills that have not made investments in equipment to handle
post-consumer fiber, because their product will gain the same "recycled" label as that from
mills that are using post-consumer fiber.
The AFPA proposal also ignores the fact that the post-consumer definition has been
well established in federal and state law for many years and is the defacto standard in the
private market. A wide array of state and local laws have for many years utilized a strict
definition of post-consumer materials in procurement.
In addition, numerous large corporations, such as Wal-Mart, McDonald's, The
Prudential, Hallmark, Time-Warner, AT&T, Bristol-Myers Squibb, Proctor & Gamble,
Kelloggs, General Mills and others, require post-consumer content in the recycled content
printing and writing paper that they purchase and/or label post-consumer content on their
packaging. Bank of America and Pacific Gas & Electric Co. have organized a group of over
twenty major West Coast companies that are committed to buying printing and writing paper
with post-consumer content.
2
b. Post-consumer waste paper is the problem. It constitutes the overwhelming
majority of waste paper disposed of in landfills and incinerators. In contrast, recovery rates
for converting scrap and over-issue materials are high and rising, due to their relative quality
and ease of collection and processing.
Figure A and Table 1, taken from a study conducted in 1992 for the Recycling
Advisory Council (RAC), demonstrate that 98% of waste paper disposed of in 1990 and
projected to be disposed of in 1995 are post-consumer materials. Converting scrap and over-
issue materials each constitute about 1% or less of disposed waste paper in 1990 and 1995;
disposal of printed converting scrap (which would be included under the AFPA's "processed
recovered fiber" definition) is even lower, only 0.2% in both 1990 and 1995.
As for recovery rates for these materials, Figure A and Table 1 also show that the
great majority of converting scrap and over-issue materials are already being recovered. and
will continue to be even in the absence of any action by government.
94% of all types of converting scrap was recovered in 1990 and the same rate
is projected for 1995. Recovery rates for all types of printed converting scrap
-- which one might think is more difficult to process -- are just as high, for
both 1990 (93%) and 1995 (94%).
Recovery rates for the subset of converting scrap derived from printing and
writing (P&W) paper -- the material most relevant here -- are even higher:
Recovery rates of both unprinted and printed P&W paper converting scrap are
98% for both 1990 and 1995.
62% of all types of over-issue materials was recovered in 1990. and this is
projected to grow to 83% by 1995 in the absence of any action by government.
While only 41% of P&W-derived over-issue materials was recovered in 1990,
this is projected to grow to 81% by 1995.²
In contrast, post-consumer materials were recovered at a rate of only 28% in
1990, projected to grow to only 36% by 1995.
In sum, converting scrap and over-issue materials are taking care of themselves. due to their
economic value (resulting from the facts that they are relatively free of contaminants and easy
to collect) and the already well-established industry recovery practices. Post-consumer.
materials are where the problem lies with respect to both disposal and slow growth in
recycling, and that is where federal procurement policy should be directed.
3
c. Giving "credit" to converting scrap and over-issue materials will essentially reward
the status quo, and will discourage new investment needed to increase waste paper recycling.
Adoption of the AFPA definition of "processed recovered fiber". runs the risk of
allowing much or most of all P&W paper produced in the U.S. to virtually instantaneously
qualify as "recycled" without increasing recovery of post-consumer materials by one ounce.
Table 2 presents an analysis of data from the RAC report that indicates how much
P&W paper could potentially qualify as recycled if the AFPA's proposed definition and 10%
standard were adopted -- all of it achieved by using recovered printed converting scrap and
over-issue materials, and not any post-consumer materials.
It should be noted that we have been very conservative (i.e., restrictive) in our
interpretation of what would be included under AFPA's definition of "processed recovered
fiber" (which has yet to be clearly defined by AFPA):
Our analysis includes only that subset of printed converting scrap and over-
issue materials derived from P&W paper, thus excluding: (1) other potential
sources of printed converting scrap and over-issue (e.g., those derived from
newsprint, bleached paperboard, and specialty papers) that could well be used
to make P&W paper; and (2) unprinted materials that would require processing
because of the presence of coatings, fillers, other additives, or other non-fibrous
components.
We used the RAC study's estimates for printed converting scrap, which the
authors stated as probably representing underestimates. Even so, the authors
assumed that 47% of all types of converting scrap would qualify as
"processed."3 In contrast, the values we used were limited to recovered.
printed, P&W-derived converting scrap; these represent only 24% of the total
amount of P&W-derived converting scrap, and only 9% of all types of
converting scrap.
The results of our analysis (Table 2) indicate that, under the AFPA's expanded definition and
proposed 10% standard, in 1990 there was sufficient recovery of printed. P&W-derived
converting scrap and over-issue material to incorporate 10% "recycled" content into 48% of
all P&W paper produced in the U.S. -- without including even one ounce of post-consumer
material. And by 1995, almost two-thirds of all P&W paper to be produced in the U.S. could
potentially qualify as "recycled" under the AFPA definition and standard -- again, without
touching any post-consumer materials!
The more than 18 million tons of P&W paper that could be produced at the AFPA's
10% level in 1995 without using post-consumer material dwarfs the federal government's
procurement of paper (a mere 300,000 tons annually) by more than a factor of 60! Even at a
15% level, over 12 million tons of P&W paper could "qualify" under the AFPA definition --
4
still more than 40 times the level of federal procurement. (At ratcheted-up levels of 20% and
25%, more than 9 million and 7 million tons, respectively, would qualify even today.)
Herein lies the danger in not adopting both a strict post-consumer definition and
sufficiently high content standards: in their absence, a federal procurement standard will do
nothing more than enshrine the status quo, except possibly to spur some more even spatial
distribution of converting scrap and over-issue materials to facilitate wider compliance with
the standard. In fact, given that a 10% post-consumer standard already exists defacto in the
marketplace, adopting the AFPA proposal would actually be a major step backward.
2.
Is there currently sufficient capacity to produce paper meeting the Executive
Order's post-consumer definition and standard?
The answer is an overwhelming yes. Table 3 presents a summary, and Table 4 a
detailed compilation, of existing and near-future expected deinked pulp capacity in the U.S.,
along with amounts of paper that are or could be produced at these mills containing various
levels of post-consumer content. Figure B presents the post-consumer pulp and paper
capacity data graphically. These data demonstrate that there is plenty of post-consumer
deinked pulp available to meet the government's needs.
There are two sources of deinked pulp made from post-consumer wastepaper: (1) pulp
mills that produce deinked pulp to sell on the open market, and (2) integrated paper
manufacturers that use the deinked pulp they produce to make paper on their own paper
machines. Today, over 1,500 tons of market post-consumer deinked pulp are produced daily
in the U.S. (amounting to more than 525,000 tons annually).4 Even if only the available
market pulp from U.S. mills was incorporated into P&W paper at a 15% post-consumer
content level, the industry could supply about 4.5 million tons of paper this year. If the same
paper contained 30% post-consumer content, the amount available would be 2.25 million tons.
These numbers are enormous relative to current federal government demand of about 300,000
tons annually.
By 1995, expected capacity for this market pulp will more than triple -- to over 5,000
tons of post-consumer deinked market pulp produced daily in the U.S. Using this pulp, 7.3
million tons of P&W paper with a 30% post-consumer content or 14.6 million tons of P&W
paper with 15% post-consumer content could be produced. If we add the available capacity
in Canada and that from the integrated pulp producers, these figures are even larger: 9.5
million tons of P&W paper with 30% consumer content or 19 million tons of P&W paper
with 15% post-consumer content could be produced in North America in 1995.
5
ENDNOTES
1. Franklin Associates Ltd., Evaluation of Proposed New Recycled Paper Standards and
Definitions, January 27, 1992, prepared for the Recycling Advisory Council.
2. The reason for the low rate in 1990 was primarily attributed to low recovery of magazines
(17%), a category that goes primarily into newsprint and is therefore not very germane to
government purchasing. More relevant are business forms, which are the next largest source
of over-issue materials; these were recovered at a high rate of 75% in 1990, projected to grow
to 80% in 1995.
3. Franklin Associates Ltd., Evaluation of Proposed New Recycled Paper Standards and
Definitions, draft dated October 8, 1991, Appendix A, p. A-6.
4. EDF confirmed, through published sources and telephone interviews with mill personnel,
that each of the existing sources (and all of the projected sources that could be checked) listed
in Table 4 produce (or will produce) deinked pulp from post-consumer waste paper.
6
Relative Disposal and Recovery of Major Types of Wastepaper
1990 (actual) and 1995 (projected)
100%
100%
80%
80%
% of all wastepaper disposed
60%
60%
40%
40%
% of wastepaper type recovered
20%
20%
0%
0%
% Disposed in 1990
% Disposed in 1995
% Recovered in 1990
% Recovered in 1995
Post-Consumer Paper
Converting Scrap
Over-Issue Material
SOURCE: Franklin Associates, Evaluation of Proposed New Recycled Paper Standards and Definitions. January 27. 1992
(Prepared for the Recycling Advisory Council)
FIGURE A
POSTCONSUMER PAPER IS OVERWHELMINGLY WHERE THE PROBLEM LIES FOR AMOUNT DISPOSED AND AMOUNT RECYCLED
1990
1995
1990
1995
1990
1995
Quantity
Quantity
Quantity
Quantity
Quantity
Quantity
(thousand tons)
Generated
Generated
Recovered
Recovered
Disposed
Disposed
Post-consumer
72704
82515
20014
29610
52690
52905
Converting scrap
All types
8117
9230
7648
8715
469
515
P & W only
3097
3563
3035
3491
62
72
Printed conv. scrap
All types
1854
2120
1722
1996
132
124
P & W only
753
882
738
864
15
18
Over-issue
All types
2045
2250
1265
1860
780
390
P & W only
1147
1208
476
973
671
235
Magazines
588
660
100
561
488
99
Business forms
391
361
293
289
98
72
1990
1995
1990
1995
1990
1995
% of Total
% of Total
% of Total
% of Total
% of Total
% of Total
Generated
Generated
Recovered
Recovered
Disposed
Disposed
Post-consumer
86%
86%
65%
70%
97%
98%
Converting scrap
All types
10%
10%
25%
21%
0.9%
1.0%
P & W only
4%
4%
10%
8%
0.1%
0.1%
Printed conv. scrap
All types
2%
2%
6%
5%
0.2%
0.2%
P & W only
0.9%
0.9%
2%
2%
0.0%
0.0%
Over-issue
All types
2%
2%
4%
4%
1.4%
0.7%
P& W only
1.4%
1.3%
2%
2%
1.2%
0.4%
Magazines
0.7%
0.7%
0.3%
1.3%
0.9%
0.2%
Business forms
0.5%
0.4%
1.0%
0.7%
0.2%
0.1%
1990
1995
1990
1995
% Recovered of
% Recovered of
% Disposed of
% Disposed of
Amt. Generated
Amt. Generated
Amt. Generated
Amt. Generated
Post-consumer
28%
36%
72%
64%
Converting scrap
All types
94%
94%
6%
6%
P & W only
98%
98%
2%
2%
Printed conv. scrap
All types
93%
94%
7%
6%
P & W only
98%
98%
2%
2%
Over-issue
All types
--
62%
83%
38%
17%
P & W only
--
--
41%
81%
59%
19%
Magazines
--
--
17%
85%
83%
15%
Business forms
--
75%
80%
25%
20%
SOURCE: Franklin Associates, Evaluation of Proposed New Recycled Paper Standards and Definitions, January 27, 1992,
prepared for the Recycling Advisory Council
TABLE 1
Very conservative estimates indicate that at least half of all the P&W paper produced in the U.S. could easily and immediately qualify as
"recycled" under the AFPA definition (i.e., contain 10% "processed recovered fiber" ("PRF")) without using ANY post-consumer materials.
1990
1995
1995
Quantity
Quantity
Maximum
(1000 tons)
Recovered
Recovered
Potential (1)
Printed converting scrap
738
864
882
from P & W paper
Overissue P & W paper
476
973
1,208
TOTAL QUANTITY RECOVERED (2)
1214
1837
2090
AMT. OF P&W PAPER THAT COULD BE
12,140
18,370
20,900
PRODUCED AT 10% "PRF" LEVEL (3)
TOTAL U.S. P&W PAPER PRODUCTION
25,067
28,270
28,270
% OF ALL U.S. P&W PAPER PRODUCTION
48%
65%
74%
REPRESENTED BY AMT. OF PAPER
THAT COULD BE PRODUCED
AT AFPA'S 10% "PRF" LEVEL
NOTES:
(1) These quantities represent 100% recovery of the printed converting scrap and over-issue P&W-derived materials.
(2) These values are very conservative estimates, as they do not include other potential sources of converting scrap and overissue that could qualify as
"processed recovered fiber" as defined by the AFPA.
(3) These values are 10 times the total quantity recovered, and assume the recovered material is equally distributed across the printing and writing paper
into which it is incorporated.
SOURCE: Franklin Associates, Evaluation of Proposed New Recycled Paper Standards and Definitions,
January 27, 1992, prepared for the Recycling Advisory Council
TABLE 2
PRINTING AND WRITING PAPER VOLUMES BY POST-CONSUMER CONTENT
1993 AND EXPECTED IN 1995
30
28.6
25
20
19.0
LEGEND - PULP SOURCES
CAPACITY
INTEGRATED MFG PULP 1995
(Millions of tons
14.3
per year)
15
CANADIAN MKT PULP 1995
11.4
US MKT PULP 1995
9.5
INTEGRATED MFG PULP 1993
10
CANADA MKT PULP 1993
US MKT PULP 1993
US GOVT PURCHASES
(0.3 million tons per year)
5
0
10%
15%
20%
25%
30%
POST-CONSUMER CONTENT LEVELS
Notes: (1) Paper volumes are based on a 350 day production year and they assume that 80% of the paper is fiber by weight.
(2) A paper company produces integrated mfg pulp , deinked post-consiumer pulp, for its own papers.
Sources: Pulp and Paper Week; 1992 North American Pulp and Paper Factbook; 1993 Lockwood-Post's Directory; Paper Recycler,
March 1993; Resource Recycling, April 1993; interview.
FIGURE B
WHEXC LB001
PRINTING AND WRITING CAPACITY WITH ST-CONSUMER FIBER SUMMARY
Present and expected additional capacity by 1995
DEINKED PULP
CAPACITY FOR PAPER WITH POST-CONSUMER CONTENT AT (2)
CAPACITY (1)
10%
15%
20%
25%
30%
Tons per day
DEINKED MARKET PULP IN 8/93
Thousands of tons per year (3)
US
1,550
6,781
4,521
3,391
CANADA
2,713
2,260.
105
459
306
230
184
153
TOTAL
1,655
7,241
4,827
3,620
2,896
2,414
DEINKED MARKET PULP IN 1995
US
5,010
21,919
14,613
10,959
CANADA
8,768
7,306
459
2,008
1,339
1,004
803
669
TOTAL
5,469
23,927
15,951
11,963
9,571
7,976
US INTEGRATED DEINKED PULP CAPACITY IN 8/93 (4)
321
1,402
935
701
561
467
US INTEGRATED DEINKED PULP CAPACITY IN 1995 (5)
1,057
4,623
3,082
2,312
1,849
1,541
TOTAL DEINKED MARKET PULP CAPACITY IN 8/93
US
1,871
8,184
5,456
4,092
NORTH AMERICA
3,273
2,728
1,976
8,643
5,762
4,322
3,457
2,881
TOTAL DEINKED MARKET PULP CAPACITY IN 1995
US
6,067
26,542
17,695
13,271
NORTH AMERICA
10,617
8,847
6,526
28,550
19,033
14,275
11,420
9,517
Sources: Pulp and Paper Week; 1992 North American Pulp and Paper Factbook; 1993 Lockwood-Post's Directory;
Paper Recycler, March 1993; Resource Recycling, April 1993; Interviews.
Notes:
(1) All deinked fiber is post-consumer
(2) Paper volumes assume that 80% of the weight of the paper is fiber
(3) Paper volumes are based on a 350 day year
(4) Integrated deinked pulp is produced for internal consumption
(5) Additional potential capacity is capacity that can be switched to produce post-consumer
deinked pulp should demand warrant it.
TABLE 3
PRINTING AND WRITING PAPER CAPACITY WITH POST-CONSUMER FIBER
Present and expected additional capacity by 1995
Deinked
DEINKED MARKET PULP
Initial
pulp
Capacity for paper with post-consumer content at (2)
start-up
capacity (1)
10%
15%
20%
25%
30%
Company
Location
date
Tons per day
Thousands of tons per year (3)
UNITED STATES 8/93
Ponderosa
Santa Ana, CA
1966
150
656
438
328
263
219
787
525
394
315
263
Ponderosa
Augusta, GA
1970
180
Ponderosa
Oshkosh, WI
1972
250
1,094
729
547
438
365
Ponderosa
Memphis, TN
1974
240
1,050
7.00
525
420
350
Mississippi River
Natchez, MS
1990
250
1,094
729
547
438
365
109
88
73
Prime Fiber
Appleton, WI
1991
50
219
146
Kieffer Paper Mills
Brownstown, IN
1992
110
481
321
241
193
160
Ecofibre/Riverside Paper
DePere, WI
1992
100
437
292
219
175
146
Fox River
DePere, WI
1992
220
962
642
481
385
321
2,260
TOTAL UNITED STATES
1,550
6,781
4,521
3,391
2,713
CANADA 8/93
Desencrage Cascades
Breakeyville, Que.
1986
105
459
306
230
184
153
TOTAL FROM NORTH AMERICAN MILLS 8/93
1,655
7,241
4,827
3,620
2,896
2,414
UNITED STATES 1995
Dynamis
1993
150
656
438
328
263
219
Sanger, CA
365
Superior Recycled Fiber
Duluth, MN
Sept. 1993
250
1,094
729
547
438
Burrows Paper
Little Falls, NY
Nov. 1993
50
219
146
109
88
73
Hagerstown, MD
Q3 1994
400
1,750
1,167
875
700
583
Pencor
Morrisville, PA
Q4 1994
340
1,487
992
744
595
496
Solar International Trading
Minnesota Pacific
Port of Duluth, MN
Q4 1994
200
875
583
437
350
292
Fort Edward, NY
late 1994
300
1,312
875
656
525
438
N. American Recycling Systems
Great Lakes Pulp & Fibre
Menominee, MI
1994
500
2,187
1,458
1,094
875
729
400
1,750
1,167
875
700
583
Green Bear
Vancouver, WA
Jan. 1995
Ponderosa
Northampton, PA
Q1 1995
400
1,750
1,167
875
700
583
American Power
Barrackville, WV
Spring 1995
470
2,056
1,371
1,028
823
685
TOTAL UNITED STATES 1995
5,010
21,919
14,613
10,959
8,768
7,306
CANADIAN 1995
1,444
963
722
578
481
Cascades
Cap-de-la-Madelein
1992/1993
330
DeNovo/Consumers Paper
Redcliff, Alta.
Spring 1994
24
105
70
53
42
35
TOTAL CANADA 1995
459
2,008
1,339
1,004
803
669
TOTAL FROM NORTH AMERICAN MILLS IN 1995
5;469
23,927
15,951
11,963
9,571
7,976
TABLE 4
PRINTING AND WRITING PAPER CAPACITY WITH POST-CONSUMER FIBER (CONT'D)
Present and expected additional capacity by 1995
INTEGRATED DEINKED PULP CAPACITY (US ONLY)
Initial
Deinked
Capacity for paper with post-consumer content at
start-up
pulp
10%
15%
20%
25%
30%
Company
Location
date
capacity
Thousands of tons per year
CAPACITY AS OF 8/93
Appleton Papers
West Carrollton, OH
30
131
88
66
53
44
Boise Cascades
Vancouver, WA
100
437
292
219
175
146
James River
Halsey, OR
137
598
399
299
239
199
Cross Pointe
West Carrollton, OH
54
235
157
118
94
78
TOTAL INTEGRATED CAPACITY AS OF 8/93 (4)
321
1,402
935
701
561
467
INTEGRATED CAPACITY AS OF 1995
Cross Pointe
Park Falls, WI
in 1993
50
219
146
109
88
73
Burrows Paper
Little Falls, NY
Nov. 1993
50
219
146
109
88
73
Union Camp
Franklin, VA
late 1994
300
1,312
875
656
525
438
International Paper
Corinth, NY
1994
50
219
146
109
88
73
ADDITIONAL POTENTIAL CAPACITY AVAILABLE (5)
Appleton Papers
West Carrollton, OH
195
853
569
427
341
284
James River
Halsey, OR
91
399
266
199
160
133
TOTAL INTEGRATED CAPACITY AS OF 1995
1,057
4,623
3,082
2,312
1,849
1,541
TOTAL CAPACITY 8/93
United States
1,871
8,184
5,456
4,092
3,273
2,728
North America
1,976
8,643
5,762
4,322
3,457
2,881
TOTAL CAPACITY 1995
United States
6,067
26,542
17,695
13,271
10,617
8,847
North America
6,526
28,550
19,033
14,275
11,420
9,517
Sources: Pulp and Paper Week, 1992 North American Pulp and Paper Factbook; 1993 Lockwood-Post's Directory;
Paper Recycler, March 1993; Resource Recycling, April 1993; interviews.
Notes:
(1) All deinked fiber is post consumer
(2) Paper volumes assume that 80% of the weight of the paper is fiber
(3) Paper volumes are based on a 350 day year
(4) Integrated deinked pulp is produced for internal consumption.
(5) Additional potential capacity is capacity that can be switched to produce post-consumer
deinked pulp should demand warrant it.
TABLE 4
EDF
ENVIRONMENTAL
DEFENSE FUND
Capital Office
1875 Connecticut Ave. N.W
Washington. DC 20009
(202) 387-3500
Fax: 202-234-6049
THE EXECUTIVE ORDER AND
THE PRIVATE MARKET FOR RECYCLED-CONTENT PAPER
John F. Ruston
Richard A. Denison, Ph.D.
Economic Analyst
Senior Scientist
September 15, 1993
OVERVIEW
The federal adoption of a postconsumer definition and standard for recycled printing and
writing paper signals to paper producers that in order to gain credit in the consumer
marketplace for selling "recycled" paper. the recovered fiber used to make the paper must
have a direct impact on the waste material that is now going to landfills and incinerators --
postconsumer paper. Use of the postconsumer definition in the proposed Executive Order
also reaffirms the definition currently used in federal law (RCRA sec. 6002), 27 state
procurement programs, the vast majority of private sector recycled paper purchasing
initiatives and the current U.S. EPA recycled paper guidelines (which specify postconsumer
content for all grades of paper other that printing and writing paper).
The current bottleneck to adding more postconsumer content to recycled paper is deinking
capacity. There is currently ample supply in fact a glut of waste paper that with
available technology can be used to make printing and writing paper with postconsumer
recycled content. There is also substantial demand in the private market for printing and
writing paper with recycled content. Deinking capacity can either be added at a paper mill or
at a stand-alone facility that produces deinked market pulp. From the standpoint of a paper
manufacturer. the marginal cost of producing pulp through deinking is significantly lower
than producing virgin bleached kraft pulp.
Paper manufacturers produce products that meet the demands of their customers. In terms of
technical feasibility. there is little difference in manufacturing paper with 10% or 20%
postconsumer content. At any level of demand for recycled-content paper among private and
government purchasers. a 20% standard will thus pull more postconsumer fiber into paper
manufactured to meet market demand than a 10% standard. For example. filling an U.S.
annual market demand for 3 million tons of recycled-content paper at a 20% standard would
require 600,000 tons of postconsumer fiber: the same demand met at a 10% standard would
only require 300.000 tons of postconsumer fiber. A higher standard will therefore increase
the number of deinking plants that are installed to produce postconsumer fiber.
The importance of the federal standard for recycled content is that it sets the stage for the
private marketplace. as producers of paper with recycled content seek to gain a competitive
advantage in filling demand for their product by increasing the level of postconsumer content
above the federal minimum. When the current U.S. EPA standard for printing and writing
paper with 50% total recycled content was established in the late 1980's for example. the
private market rapidly surpassed this with a defacto standard of 50% total recycled content.
10% postconsumer content.
There is ample evidence that paper producers are prepared to make recycled-content paper
with postconsumer content levels much higher than 10%. For example, by November 1993.
International Paper Co. will be producing 90,000 tons of 100% recycled photocopy paper per
year at Lock Haven, PA, which will have a minimum 50% postconsumer content: The Union
Camp Corp. is currently testing uncoated free sheet paper with 25% postconsumer content in
anticipation of starting its 400 ton per day (input) deinking line at Franklin. VA in February
1995. International Paper Co. has announced that it in 1995 it will complete installation of
another 400 ton per day deinking line at its Selma, AL mill, which will produce recycled pulp
equivalent to 18% of the mill's total paper production. Bank of America and Pacific Gas
And Electric Co. have organized a group of almost 70 businesses that are committed to
buying paper with a minimum of 15% postconsumer recycled content, and Bank of America
itself is reportedly now buying paper with 20% postconsumer content.
In the long term. once the definition of recycled content is established. the role of the federal
standard in the private market will diminish. Through the pricing mechanism. the private
market will adjust and balance consumer demand for recycled paper, the available supply of
recovered paper, and the increasing technical ability of paper manufacturers to user higher
levels of postconsumer content. The Executive Order will not independently lead to long-
term shortages of recovered paper, since the federal government is such a small part of the
total U.S. market.
In the near term. the critical role for federal purchasing is to add certainty to the market for
recycled-content paper, establish a uniform national definition of recycled content. address the
immediate glut of recovered office paper. and stimulate investment in deinking facilities.
Greater use of postconsumer fiber in printing and writing paper will create jobs in the-
collection and processing of recovered fiber and in the construction and operation of deinking
plants. increase jobs and sales among the companies that manufacture paper recycling
equipment. and turn a waste material that is costly to dispose of into a high value-added
commodity. By specifying 20% postconsumer content for federal purchases of recycled
printing and writing paper. the Executive Order can have a positive impact on both the
economy and the environment.
2
WHY A 10% STANDARD IS INSUFFICIENT
A.
A 10% standard will result in less, not more, use of postconsumer paper than a
15% (or higher) standard, contrary to AFPA's claim.
1.
AFPA's claim that a 10% standard will pull in more postconsumer paper than a 15%
standard is predicated on its expanded "processed recovered fiber" definition. Note
that AFPA's bar chart (attached to its 9/3/93 letter to President Clinton) does not
indicate "pull" of postconsumer paper, only processed recovered fiber. AFPA's claim
of increased participation under a lower standard is a function of how easy it is to use
preconsumer materials, and does not reflect what is really needed: increased
investment in deinking facilities required to use more postconsumer paper.
2.
AFPA's estimated pull of processed recovered fiber by 1995 is only 1.7 milllion tons;
see AFPA's bar chart. This amount is less than the amounts of printed, printing-and-
writing-paper-derived converting scrap and over-issue materials projected to be
recovered in 1995: 1.84 million tons; see Chart 1 attached. In other words, AFPA's
own 1995 projection for use of processed recovered fiber could be met without using
any postconsumer paper at all.
3.
Similarly, consider what 50% industry conformance with a 10% processed recovered
fiber standard would mean for use of recovered fiber: Of the 28 million tons of P&W
paper projected to be produced in 1995, 28 X 0.5 X 0.1 = 1.4 million tons of processed
recovered fiber would be used under this standard -- again, less than a very
conservative estimate of the amount of preconsumer paper suitable for use in P&W
paper projected to be recovered by 1995.
4.
In terms of increasing industry participation, it is critical to recognize that the
Executive Order's proposed standard eliminates the 50% total recovered material
requirement. That requirement has been the real barrier impeding greater industry
participation, and its removal is a major concession to industry. Relative to a 50%
recovered material or a; 50/10 standard (50% recovered material including 10%
postconsumer paper), a single-tier postconsumer standard of 20% will make entry into
the recycled P&W paper market easier.
5.
AFPA claims that "only five to ten commodity machines are likely to produce on a
regular basis paper meeting the 15 percent level" (9/9/93 letter to President Clinton).
There are several major flaws in this argument. First, at 15% postconsumer recycled
content, ten commodity machines (which each typically produce about 250,000 tons of
paper per year) would produce about 2.5 million tons per year of recycled-content
paper -- more than eight times federal government purchases.
3
Second, the reference to commodity machines producing "on a regular basis" omits
any paper producers that would choose to use deinked market pulp, which is produced
offsite and can be used intermittently. Currently, AFPA's own data¹ indicate that
600,000 tons of deinked market pulp are available annually in the United States today
-- enough to produce 4 million tons annually of P&W paper at a 15% postconsumer
level, or 13 times federal government demand. By 1995 or shortly thereafter, annual
production of more than 2 million tons of deinked market pulp is projected, tripling
current capacity.
B.
A 10% standard is a step backward from the defacto standard in the current
market that reflects state and local government and private sector procurement
standards and initiatives.
1.
The defacto marketplace standard today is at least 50/10.
>
State procurement standards adopted over the last 5 years generally specify at
least this standard:
27 states specify postconsumer paper as part of their standards;
25 states require at least 10% postconsumer content along with at least
50% total recovered material;
2 states (RI, OR) require at least 25% postconsumer content along with
at least 50% total recovered material.
>
The Great Lakes Purchasing Cooperative purchased 14,000 tons of recycled
copy paper last year on behalf of 7 midwest state governments. About half of
that amount was 50/20 (from Badger Paper), the other half was 50/10 (from
Hammermill/International Paper). A price premium of about 7% was paid.
The success of the purchase has led to a decision to place a larger order
involving more states this year. A Western States Contracting Alliance bid
specifying 30,000 tons of paper in the range of 50/10 to 50/30 is currently in
process.
Bank of America and Pacific Gas & Electric Company have organized a group
of almost 70 businesses committed to buying paper with at least 15%
postconsumer content, and Bank of America itself is buying paper with 20%
postconsumer content from James River Corporation.
1
AFPA, Recovered Paper Deinking Facilities, March 1993, AFPA Economics,
Washington, DC. AFPA notes that its estimates are conservative.
4
About 400 brands of P&W paper meet a 50/10 standard today (Jaako-Poyry
"Grade-Finder" listing).
>
More than 100 brands made by at least 40 companies meet a 50/15 standard
(CERMA and National Paper Trade Association Management News listings).
2.
A federal 10% standard might have been seen as progressive several years ago; today
it can only be described as lagging.
3.
Removing the 50 from the defacto marketplace standard of 50/10 to leave only a 10%
postconsumer standard will undercut these state programs -- unless the 10 is raised to
at least 20%. Nor will it result in use of more postconsumer paper.
C.
A 10% standard will not drive any expanded investment in deinking facilities,
and therefore, the supply of postconsumer deinked pulp. The limiting factor to
greater use of postconsumer paper in P&W paper is deinking capacity -- not raw
material supply or paper machine limitations.
1.
Work by Franklin Associates (cited by AFPA in its 9/3/93 letter to President Clinton
to support its contention that supply is the limiting factor) in fact states clearly that the
limiting factor is deinking capacity: "The office paper collection infrastructure and
actual collection are currently expanding faster than the paper mill capacity to utilize
recovered office papers."²
The report goes on to state: "The printing and writing paper industry is just beginning
to make the necessary investments for usage of recovered office papers. There are
new, and potentially strong, market forces driving the procurement of recycled
printing-writing paper products. These market forces need to continue to grow to
provide the economic incentives for recovered office waste paper usage in this
industry."
2.
The Franklin Associates report's estimate for recovery of P&W paper from offices in
1995 is 3.4 million tons -- double the "pull" of waste paper projected in the AFPA bar
chart under its proposed 10% processed recovered fiber standard. This hardly
represents a shortage in supply of recovered office printing and writing paper.
2
Franklin Associates, Supply of and Recycling Demand for Office Waste Paper, 1990 to
1995, prepared for the National Office Paper Recycling Project, Final Report, July 1991, p.
ES-4.
5
As shown in Charts 1 and 2. very conservative estimates indicate that at least half of all the
P&W paper produced in the U.S. could be made to readily qualify as "recycled" under the
AFPA definition (i.e., could contain 10% "processed recovered fiber" ("PRF")) using only
preconsumer materials. that is. without using ANY post-consumer materials.
CHART 1
RECOVERY OF PRE-CONSUMER PAPER SUITABLE FOR USE IN P&W PAPER
1990 AND 1995
2500
2000
1500
thousands of tons
1000
500
0
1990 Recovery
1995 Recovery
1995 Maximum
Printed Converting Scrap
Printed Overissue Material
NOTES:
"1995 Maximum" quantities represent 100% recovery of the printed converting scrap and
over-issue P&W-derived materials that are generated.
The recovery estimates are very conservative. as they do not include other potential sources
of converting scrap and overissue that could qualify as "processed recovered fiber" as defined
by the AFPA.
SOURCES: Franklin Associates. Evaluation of Proposed New Recycled Paper Standards and
Definitions. January 27. 1992. prepared for the Recycling Advisory Council.
If the quantities of recovered preconsumer material indicated in Chart 1 are used to make
deinked pulp and then used to make paper at a 10% PRF content level. the amount of such
paper is approximately 10 times the total quantity recovered. Chart 2 shows that these
amounts of "10% PRF" paper represent half (in 1990) to two-thirds (in 1995) of the total U.S.
capacity for producing P&W paper.
CHART 2
POTENTIAL FOR PRODUCTION OF PAPER CONTAINING 10% PRF WITHOUT PCW
VS. TOTAL P&W PAPER PRODUCTION CAPACITY
30
25
74%
20
65%
millions of tons
15
48%
10
5
0
1990 Recovery
1995 Maximum
1990 P&W Capacity
1995 Recovery
1995 P&W Capacity
SOURCES: Franklin Associates. Evaluation of Proposed New Recycled Paper Standards and
Definitions. January 27. 1992, prepared for the Recycling Advisory Council: EDF
calculations.
ENVIRONMENTAL
DEFENSE FUND
Capital Office
1875 Connecticut Ave.. N.W.
Washington. DC 20009
(202) 387-3500
Fax: 202-234-6049
THE EFFECT OF INCORPORATING POST-CONSUMER RECYCLED CONTENT
ON THE PRICE OF PRINTING AND WRITING PAPER
Lauren Blum
Environmental Defense Fund
(212) 505-2100
August 19, 1993
For the following reasons, the federal government should not have to pay more for
printing and writing paper with post-consumer fiber content.
Three economic factors should make paper with post-consumer fiber competitive with
paper made from virgin pulp. First, the market no longer supports price premiums for
recycled paper; second, signals of sustained demand for recycled paper will encourage
low-cost producers to make it; and third, deinked pulp using mixed office waste paper. the
new raw material of choice, is less expensive to make than virgin pulp. In fact. the
Government initiative will actually help to make recycled printing and writing papers more
affordable and available to everyone.
1.
Market forces are reducing the price premiums for recycled fiber papers.
According to the August 1993 issue of Paper Recycler. "[m]ost mills still seek a
premium for recycled content papers, but for many grades those premiums have been
dropping from a high of 10% to under 5%. and some are even being sold at comparable
prices to virgin-fiber papers. These premiums exist because the small mills that make paper
with post-consumer content have been able to find customers willing to buy their paper at
high prices.
While deinked pulp has also been selling at a significant premium to virgin kraft pulp,
there are several reasons why this is expected to change. Virgin pulp prices are currently
depressed because of an over-supply. Almost 1 million tons of bleached kraft pulp capacity
came on-line in both 1990 and 1991 in the U.S., just as market pulp prices declined
precipitously and the economy entered a recession. With the worldwide glut of pulp and a
National Headquarters
257 Park Avenue South
5655 College Ave.
405 Arapanoe Ave.
128 East Hargett St.
1800 Guadalupe
New York. NY 10010
Oakland. CA 94618
Boulder. CO 80302
Raleigh. NC 27601
Austin. TX 78701.
(212) 505-2100
(510) 658-8008
(303) 440-4901
(919) 821-7793
(512) 478-5161
100% Post-Consumer Recycled Paper
weak global economy, virgin pulp prices have remained unusually low. For example. U.S.
southern bleached kraft softwood pulp sells for $375-395 per metric ton, down from $555 per
metric ton a year ago. The price of deinked market pulp, on the other hand. has held steady
at around $565 per metric ton for the last nine months (Pulp and Paper Week, July 19. 1993).
This price gap is expected to disappear soon. Virgin pulp prices will rebound as the
economy recovers and marginally competitive mills cease production: some of the virgin
capacity shutdowns may be permanent. Additional deinked pulp capacity expected to come
on-line in the next two years will decrease its current high price. Thus. the cost of
incorporating post-consumer fiber into paper made at those mills that currently purchase
deinked market pulp will decrease.
2.
By demonstrating a sustained demand for paper with post-consumer fiber the
Government will encourage the low-cost manufacturers to produce these papers
on their state of the art machines.
Mills that operate state-of-the art paper machines produce high quality paper at the
lowest cost. Economies of scale drive paper manufacturing costs because the same number of
people are needed to run a paper machine regardless of the size; thus. mills with the largest.
fastest machines spread the labor costs over greater quantities of paper. This increased
productivity results in significantly lower costs.
Because Union Camp and International Paper both plan to produce paper with post-
consumer content on their fastest machines in 1995, the price should be competitive with
paper made with virgin fiber.
3.
Incorporating post-consumer fiber actually lowers paper manufacturing costs.
Two important components of the cost of paper capital costs and fiber costs -- are
lower for deinked post-consumer fiber than they are for virgin bleached kraft pulp. Purchased
energy and chemical costs are roughly the same.
Capital costs to build additional bleached kraft pulp capacity are roughly twice those
to build a deinking plant that uses mixed office waste paper. Several estimates for capital
costs needed to produce bleached kraft pulp are available and fairly consistent:
American Papermaker (March, 1992) reports costs of $630,000 to $650,000 per daily ton of
capacity of bleached kraft pulp.
Estimates made by the investment firm Morgan Stanley put replacement costs at $1.152
billion for the pulp mills that Weyerhaueser purchased from Procter & Gamble in November
1992; these figures translate into a capital cost of $600,000 per daily ton for bleached kraft
pulp capacity.¹ ("Summary of 37 Major Paper Acquisitions," Morgan Stanley Equity
Research Report, 1992).
Morgan Stanley has also estimated the cost of additional capacity for virgin bleached
market pulp to be $550,000 per daily ton, based on major paper acquisitions that have taken
place since September. 1988; its estimate for the period prior to September. 1988 was
$500.000 per daily ton (same source as previous bullet).
This range of capital costs -- $550,000 to $650,000 per daily ton of capacity for
bleached pulp -- is more than twice as high as the $275,000 per daily ton estimate for the
capital cost of a deinking plant that uses mixed office waste (Pulp and Paper Week,
November 2, 1992).
Fiber costs are the largest variable cost component in pulp production. Wood accounts
for 30-35 percent of the total cost of making a ton of virgin bleached kraft pulp. For
example, wood costs $115 per ton for U.S. southern bleached pulp (Pulp and Paper, March
1992), the lowest cost pulp in North America. Fiber from mixed office waste, on the other
hand, costs $70 per ton of pulp.²
These favorable economics of using mixed office waste as a raw material have spurred
the development of new deinking technologies that produce clean, bright pulp suitable for use
in printing and writing papers.
ENDNOTES
1. Based on a production level of 1920 tons of pulp per day. 350 days per year.
2. Fiber cost is based on the cost of mixed office waste f.o.b. ($30 per ton). transportation costs (S20 per ton)
and a pulping process yield of 70%.
EDF
ENVIRONMENTAL
DEFENSE FUND
Capital Office
1875 Connecticut Ave., N.W.
Washington. DC 20009
(202) 387-3500
Fax: 202-234-6049
COMPARISON OF EDF AND AFPA ESTIMATES FOR
POST-CONSUMER DEINKED PULP CAPACITY IN THE U.S.
August 6, 1993
Subsequent to preparing our July 29, 1993 analysis of the AFPA proposed definition and
standard for government propcurement of recycled printing and writing paper, we obtained a copy
of a new (March 1993) report from AFPA listing existing and expected 1995 capacity for
producing deinked pulp in the U.S. A copy of this report is attached.
We have compared the deinked pulp capacity estimate provided in our July 29 analysis
to that in the AFPA report. The comparison indicates that, for total post-consumer deinked pulp
capacity used or suitable for use in printing and writing papers, the AFPA estimates for both
present capacity and capacity expected in 1995 are actually substantially greater than the
conservative estimates we provided. A table is attached showing the comparison. More
specifically we found the following:
1. EDF and AFPA estimates of existing deinked market pulp capacities are very similar. AFPA
has included 3 extra mills for a total of 12 existing mills that produce deinked market pulp. Our
capacity numbers differ by about 10%.
2. Relative to the EDF estimate for new market deinked pulp capacity, AFPA projects two
additional deinking mills to come on-line by 1995 and that Ponderosa will increase capacity in
its three existing deinked pulp mills. The AFPA estimate for deinked market pulp capacity in
1995 is thus almost 25% larger than ours.
3. The AFPA and EDF estimates differ significantly for existing deinked pulp capacity at
integrated mills, with the AFPA estimate being much higher. The AFPA estimate includes all,
not just post-consumer. deinked pulp capacity, however. In addition, some of these mills listed
by AFPA are presently closed, and two of the operating mills produce groundwood deinked pulp,
which we did not include in our estimate. EDF's estimates for deinked post-consumer pulp in
this category were confirmed through telephone interviews with mill personnel, while AFPA's
are based on published sources.
In sum, because AFPA's estimates for deinked pulp capacity are actually higher than
EDF's, the industry's own figures support our contention that more than sufficient capacity
currently exists in the U.S. to produce printing and writing paper meeting a 15% post-consumer
recycled content standard.
National Headquarters
257 Park Avenue South
5655 College Ave.
1405 Arapahoe Ave.
New York. NY 10010
128 East Hargett St.
1800 Guadalupe
Oakland. CA 94618
Boulder. CO 80302
(212) 505-2100
Raleigh. NC 27601
Austin. TX 78701
(510) 658-8008
(303) 440-4901
(919) 821-7793
(512) 478-5161
100% Post-Consumer Recycled Paper
DEINKED PULP CAPACITY FOR PRINTING AND WRITING PAPERS IN THE U.S.
A COMPARISON OF EDF AND AFPA ESTIMATES
Present and expected additional capacity by 1995
EDF estimate
AFPA estimate
Annual deinked
Annual deinked
DEINKED MARKET PULP
pulp
pulp
capacity (1,2)
capacity
Company
Location
Thousands of tons
Thousands of tons
UNITED STATES 8/93
Ponderosa
Santa Ana; CA
53
50
Ponderosa
Augusta. GA
63
60
Ponderosa
Oshkosh, WI
88
80
Ponderosa
Memphis. TN
84
75
Mississippi River
Natchez. MS
88
64
Prime Fiber
Appleton. WI
18
20
Kieffer Paper Mills
Brownstown. IN
39
40
Ecofibre/Riverside Paper
DePere. WI
35
35
Fox River
DePere. WI
77
70
FSC Paper Co.
Alsip. IL
10
Ohio Paper Mills Inc.
Cincinnati, On
13
Reprocell
Sun Valley: CA
85
TOTAL 1993
543
602
UNITED STATES 1995
Dynamis
Sanger. CA
53
53
Superior Recvcled Fiber
Duluth. MN
88
90
Burrows Paper
Little Falls, NY
18
18
Pencor
Hagerstown, MD
140
100
Solar International Trading
Morrisville, PA
119
100
Minnesota Pacific
Pon of Duluth. MN
70
N. American Recycling Systems
Fort Edward. NY
105
105
Great Likes Pulp & Fibre
Menominee, MI
175
175
Green Hear
Vancouver. WA.
140
155
Ponderosa
Northampton. PA
140
135
American Power
Barrackville, WV
165
140
Caithness King Co.
Midland. MI
100
Fox River Fibre Co.
DePere. WI
70
International Resource Recycling
Camden, NJ
135
Mississippi River Corp.
Natchez. MS
100
Ponderosa
Oshkosh. WI
30
Ponderosa
Memphis. TN
8
Ponderosa
Augusta. GA
7
Stone & Webster
Aubum, ME
70
TOTAL UNITED STATES 1995
1,754
2.123
INTEGRATED DEINKED PULP CAPACITY (US ONLY)
EDF estimate
AFPA estimate
Annual deinked
Annual deinked
Company
Location
pulp
pulp
capacity (1)
capacity
CAPACITY AS OF 8/93 (3)
Thousands of tons
Thousands of tons
Appleton Papers (4)
West Carrollton, OH
11
68
Boise Cascades (4)
Vancouver, WA
35
53
James River (4)
Halsev. OR
48
105
Cross Pointe (4)
West Carrollion, OH
19
54
Cross Point Paper Co. (4)
Park Falls. WI
9
Daishowa America Co., Ltd.
Port Angeles, WA
65
Georgia Pacific Corp. (5)
Kalamazoo, MI
70
International Paper (6)
Merrill. WI
20
Mead Corp.
Chillicothe, OH
18
Patriot Paper Co. (6)
Hvde Park. MA
80
P.H. Gladfelter Co. (7)
Neenah. WI
90
Simpson Paper Co. (6)
Pomona, CA
25
TOTAL INTEGRATED CAPACITY AS OF 8/93
112
657
INTEGRATED CAPACITY AS OF 1995
Cross Pointe
Park Falls. WI
18
35
Burrows Paper
Little Falls, NY
18
18
Union Camp
Franklin. VA
105
105
International Paper
Corinth. NY
18
International Paper (5)
Lock Haven. PA
90
ADDITIONAL POTENTIAL CAPACITY AVAILABLE (8)
Appleton Papers
West Carrollton, OH
68
James River
Halsey, OR
32
TOTAL INTEGRATED CAPACITY AS OF 1995
370
905
TOTAL CAPACITY 8/93
655
1,259
TOTAL CAPACITY 1995
2,123
3,027
Sources: Recovered Paper Deinking Facilities March 1993. AFPA Economics: Pulp and Paper Week. 1992 North American Pulp and
1993 Lockwood-Post's Directory: Paper Recycler, March 1993: Resource Recycling. April 1993: interviews.
Notes:
(1) All deinked fiber is post-consumer
(2) Annual capacity is based on a 350 day year
(3) Integrated deinked pulp is produced for internal consumption.
(4) AFPA estimate includes pre-consumer or industrial waste paper
(5) Deinked pulp is mostly groundwood
(6) Mill is currently shut down
(7) Mill produces no post-consumer deinked fiber
(8) Additional potential capacity is capacity that can be switched to produce post-consumer
deinked puip should demand warrant it.
RECOVERED PAPER DEINKING FACILITIES
MARCH, 1993
AMERICAN FOREST & PAPER ASSOCIATION
ECONOMICS & MATERIALS DEPARTMENT
PAPER
Information Center
1-800-878-8878
AFPA
Fni
RECOVERED PAPER DEINKING FACILITIES: A SPECIAL REPORT
The first section of this report contains a listing by company, location, product
grade and estimated annual capacity of 74 existing recovered paper deinking facilities.
To preserve the confidentiality of statistical and capacity data supplied to
AFPA by its members, the AFPA Economics & Materials Department has been careful to
obtain all the information in this report from public sources. Consequently, the entries may
not comprise a complete record of all deinking plants in the U.S. pulp and paper industry,
and thus the report probably understates existing deinking capacity.
The second section of the report lists 51 publicly announced expansions or new
recovered paper deinking facilities reported to be planned between 1993-1995. The list
includes entries ranging from firm commitments to preliminary engineering and feasibility
studies. No attempt has been made to judge the likelihood that any of these projects will be
completed as described.
The table below summarizes the number of existing and planned projects by
end product.
End Product
Existing
Planned
Newsprint
13
12
Paperboard
3
-
Printing/Writing
12
6
Tissue
32
8
Deinked Market Pulp
12
24
Deinked Pulp
2
1
Total
74
51
CAP001:016DE151.WP
AFPA
Economics
SECTION I
Existing Recovered Paper Deinking Facilities
AFPA
Economics
Information in this report is obtained
from trade periodicals, company
releases and other public sources.
ECONOMICS DEPARTMENT
Entries may not comprise a complete
FEBRUARY 1993
record of all deinking plants in the pulp
RECOVERED PAPER DEINKING FACILITIES
& paper industry.
Existing Facilities 1992
ESTIMATED
ANNUAL DEINKING CAPACITY
MILL OR COMPANY NAME
LOCATION
STATE
PRODUCT GRADE
(thousands short tons)
Augusta Newsprint Co.
Augusta
GA
Newsprint
90
Bowater Inc.
Calhoun
TN
Newsprint
110
FSC Corp.
Alsip
IL
Newsprint
135
Garden State Paper Co.
Garfield
NJ
Newsprint
250
I
Empire Co.
Millwood
WA
Newaprint
40
Jefferson Smurfit Corp.
Oregon City
OR
Newsprint
120
Jefferson Smurfit Corp.
Newberg
OR
Newsprint
220
Jefferson Smurfit Corp.
Pomona
CA
Newsprint
150
Kimberly-Clark Corp.
Cooss Pines
AL
Newaprint
40
Manistique Papers Inc.
Manistique
MI
Newsprint/Directory
150
Papers
North Pacific Paper Co.
Longview
WA
Newsprint
165
Southeast Paper Co.
Dublin
GA
Newsprint
450
S
Container Corp.
Snowflake
AZ
Newsprint
230
Celotex Corp.
Quincy
IL
Paperboard
17
Green Bay Packaging Inc.
Morrilton
AR
Paperboard
105
Newark Boxboard Corp.
Stockton
CA
Paperboard
6
Appleton Papers Inc.
West Carroliton
OH
Printing/Writing Papers
68
Boise Cascade Corp.
Vancouver
WA
Printing/Writing Papers
53
Cross Pointe Paper Co. (sub. Pentair)
Park Fails
WI
Printing/Writing Papers
9
Daishowa America Co., Ltd.
Port Angeles
WA
Printing/Writing Papers
65
Georgia-Pacific Corp.
Kalamazoo
MI
Printing/Writing Papers
70
International Paper Co.
Merrill
WI
Printing/Writing Papers
20
Mead Corp.
Chillicothe
OH
Printing/Writing Papers
18
Miami Paper Corp. (sub. Pentair)
West Carrollton
OH
Printing/Writing Papers
54
Patriot Paper Co.
Hyde Park
MA
Printing/Writing Papers
80
P.H. Glatfelter Co.
Neenah
WI
Printing/Writing Papers
90
Simpson Paper Co.
Pomona
CA
Printing/Writing Papers
25
Simpson Paper Co.
West Linn
OR
Printing/Writing Papers
n.a.
Ashuelot Paper Co.
Hinadale
NH
Tissue
20
Adas Paper Co.
Hialeah
FL
Tissue
18
American Tissue Corp.
Baldwinville
MA
Tissue
50
Bay West Paper Corp.
Middletown
OH
Tissue
90
Cascades Industries Inc.
Rockingham
NC
Tissue
20
Chesapeake Corp.(Wisconsin Tissue)
Menasha
WI
Tissue
200
Crystal Tissue Co.
Middletown
OH
Tissue
25
Encore Paper Co.
South Glens Falls
NY
Tissue
46
Erving Paper Mills
Erving
MA
Tissue
40
Flower City Tissue Mills
Rochester
NY
Tissue
10
Fort Howard Corp.
Muskogee
OK
Tissue
245
Fort Howard Corp.
Rincon
GA
Tissue
290
Fort Howard Corp.
Green Bay
WI
Tissue
420
FSC Corp.
Alsip
IL
Tissue
70
Georgia-Pacific Corp.
Gary
IN
Tissue
27
James River Corp.
Ashland
WI
Tissue
23
James River Corp.
Green Bay
WI
Tissue
70
James River Corp.
Carthage
NY
Tissue
14
Kimberly-Clark Corp.
Loudon
TN
Tissue
75
Laurel Hill Co.
Cordova
NC
Tissue
18
Marcal Paper Mills Inc.
Elmwood Park
NJ
Tissue
97
Orchids Paper Products
Flagstaff
AZ
Tissue
30
n.a. not available
1/ - Conforms to product grades for paper and paperboard as published in AFPA annual Capacity Surveys.
2/ - Estimated capacity to produce deinked pulp, not gross recovered paper consumption.
CAP001:009DELS1.WP
Page
RECOVERED PAPER DEINKING FACILITIES
Existing Facilities 1992
ESTIMATED
ANNUAL DEINKING CAPACITY
MILL OR COMPANY NAME
LOCATION
STATE
PRODUCT GRADE
(thousands short toma)
Orchids Paper Products
Pryor
OK
Tissue
35
Paper Service Mills Inc.
Hinsdale
NH
Tissue
15
Pope & Talbot Inc.
Ransom
PA
Tissue
58
Pope & Talbot Inc.
Eau Claire
WI
Tissue
100
Pope & Talbot Inc.
Ladysmith
WI
Tissue
32
Putney Paper Co.
Putney
VT
Tissue
18
Scott Paper Co.
Winslow
ME
Tissue
50
Statier Tissue Corp.
Augusta
ME
Tissue
70
Stevens & Thompson Paper Co.
Greenwich
NY
Tissue
28
Tagsons Paper Co.
Mechanicville
NY
Tissue
71
EcoFibre Inc.
De Pere
WI
Deinked Market Pulp
35
FSC Paper Co.
Alsip
IL
Deinked Market Pulp
10
Fox River Fibre Co.
De Pere
WI
Deinked Market Pulp
70
Kieffer Paper Mills
Brownstown
IN
Deinked Market Pulp
40
Mississippi River Corp.
Natchez
MS
Deinked Market Pulp
64
Ohio Paper Mills Inc.
Cincinnati
OH
Deinked Market Pulp
13
Ponderosa Fibres of America Inc.
Oshkosh
WI
Deinked Market Pulp
80
Ponderosa Fibres of America Inc.
Memphis
TN
Deinked Market Pulp
75
Ponderosa Fibres of America Inc.
Augusts
GA
Deinked Market Pulp
60
Ponderosa Fibres of America Inc.
Santa Ana
CA
Deinked Market Pulp
50
Prime Fibre Corp.
Appleton
WI
Deinked Market Pulp
20
Reproceil
Sun Valley
CA
Deinked Market Pulp
85
James River Corp.
Halsey
OR
Deinked Pulp
105
Scon Paper Co.
Oconto Falls
WI
Deinked Pulp
n.a.
n.a. not available
1/ - Conforms to product grades for paper and paperboard as published in AFPA annual Capacity Surveys.
2/ - Estimated capacity to produce deinked pulp, not gross recovered paper consumption.
Page 2
CAP001:1
.WP
SECTION II
Publicly Announced Recovered Paper
Deinking Facility Expansions and
New Projects
1993 - 1995
AFPA
Economics
Information in this report is obtained
from trade periodicals, company press
releases and other public sources.
Entries include projects ranging from
ECONOMICS DEPARTMENT
firm commitments to engineering and
RECOVERED PAPER DEINKING FACILITIES
feasibility studies.
FEBRUARY 1993
Publicly Announced Expansions and New Projects 1993 - 1995
ESTIMATED
ANNUAL
DEINKING
CAPACITY
ANNOUNCED
PRODUCT
(thousands
START-UP
MILL OR COMPANY NAME
LOCATION
STATE
GRADE
short tons)
DATE
COMMENTS
Alabama River Newsprint Co.
Claiborne
AL
Newsprint
55
1993
Flotation deinking plant. 20-40% recycled content sheet.
Augusta Newsprint Co.
Augusta
GA
Newsprint
45
1993
Expansion.
Bear Island Paper Co.
Ashland
VA
Newsprint
45
1993
New flotation deinking plant. 20% recycled content sheet.
Boise Cascade Corp.
West Tacoma
WA
Newsprint
75
1993
Flotation deinking plant. 40% recycled content sheet.
Bowater Inc.
East Millinocket
ME
Newsprint
100
1993
New flotation deinking plant. 40% recycled content sheet.
Chi
ion International Corp.
Sheldon
TX
Newsprint
140
1993/1995
Flotation deinking plant. 40% recycled content sheet.
Daishowa America Ltd.
Stockton
CA
Newsprint
250
n.a.
Proposal for 100% recycled mill.
(Sub. San Joaquin Paper Co.)
Evergreen Pulp & Paper Co.
Redrock
AR
Newsprint
250
1995/1996
Plan for new mill and flotation deinking plant. 100% recycled sheet.
Tentative.
MacMillan Bloedel/Haindl Paper
W. Sacramento
CA
Newsprint
310
n.a.
New mill and flotation deinking plant. 100% recycled sheet. Originally
planned for 1994.
Ponderosa Fibres of America Inc.
Albany
NY
Newsprint
105
n.a.
New mill and flotation deinking plant. 100% recycled sheet. Originally
planned for 1993.
Ponderosa Fibres of America Inc.
South Bronx
NY
Newsprint
105
n.a.
New mill and flotation deinking plant. 100% recycled sheet. Originally
planned for 1993.
Stone-Consolidated Inc.
Shawinigan
Canada
Newsprint
80
1993
Flotation deinking plant. Fiber source mostly N.E. USA.
Cross Pointe Paper Co. (Sub. Pentair)
Park Falls
WI
Printing/Writing
35
1993
Deinking plant expansion.
Fox River Paper Co.
Urbana
OH
Printing/Writing
n.a.
n.a.
Studying deinking plant. Possible joint venture.
Intel
onal Paper Co.
Corinth
NY
Printing/Writing
D.S.
1993
New deinking plant. Up to 50% post-consumer sheet.
International Paper Co.
Lock Haven
PA
Printing/Writing
n.a.
1993
New modified flotation deinking plant. May ship excess production.
Store Papyrus Newton Falls Inc.
Newton Falls
NY
Printing/Writing
n.a.
n.a.
Studying deinking plant reactivation.
Union Camp Corp.
Franklin
VA
Printing/Writing
105
1994
Studying deinking plant. Up to 50% post-consumer sheet.
Ashuelot Paper Co.
Hinadale
NH
Tissue
n.a.
1993
Upgrade deinking plant.
Encore Paper Co.
South Glens Falls
NY
Tissue
20
1993
Expansion.
Fort Howard Corp.
Western U.S.
Tissue
n.a.
n.a.
Considering new recycling mill and deinking plant.
Fort Howard Corp.
Muskogee
OK
Tissue
65
1994
Install fifth p.m.
Fort Howard Corp.
Rincon
GA
Tissue
65
1995
Install fifth p.m.
James River Corp.
Green Bay
WI
Tissue
18
1993
Considering deinking plant expansion and pulp mill shutdown.
Ii
1 River Corp.
Old Town
ME
Tissue
n.a.
n.a.
Considering new p.m. and deinking plant. Originally planned for 1992.
Scott Paper Co.
Owensboro
KY
Tissue
a.a.
1995
Considering new mill and deinking plant.
n.a. - not available
1' - Conforms to product grades for paper and paperboard ⑉ published in AFPA annual Capacity Surveys.
2/ - Learning curve and other factors may delay full utiliz
until following year.
CAP I:010DE151.WP
Page 1
Information in this report is obtained
I
trade periodicals, c pany press
releases and other public sources.
Entries include projects ranging from
firm commitments to engineering and
ECONOMICS DEPARTMENT
RECOVERED PAPER DEINKING FACILITIES
feasibility studies.
FEBRUARY 1993
Publicly Announced Expansions and New Projects 1993 - 1995
ESTIMATED
ANNUAL
DEINKING
CAPACITY
ANNOUNCED
PRODUCT
(thousands
START-UP
L OR COMPANY NAME
LOCATION
STATE
GRADE
short tons)
DATE
2
COMMENTS
American Power Corp.
Barrackville
WV
Deinked Market Pulp
140
1994/1995
New mill and deinking plant.
Burrows Paper Corp.
Little Falls
NY
Deinked Market Pulp
35
1993
New deinking plant. 100% mixed office waste.
For own use and sale to tissue and p/w mills.
Gaithness King Co.
Midland
MI
Deinked Market Pulp
100
1994/1995
Considering new mill and flotation deinking plant. Delayed from 1992.
DeNovo/Southern Electric
Fredericksburg
VA
Deinked Market Pulp
50
1994
Feasibility study. Will supply pulp for tissue mills.
DeNovo/Southern Electric
Seattle/Tacoma
WA
Deinked Market Pulp
53
n.a.
Proposal for new recycling/cogenerationplant.
Dy
Inc.
Sanger
CA
Deinked Market Pulp
53
1993
Plan for new Recoupe steam explosion plant in existing power plant.
FSC Paper Co.
Alaip
IL
Deinked Market Pulp
20
n.a.
Considering expansion.
Fox River Fibre Co.
De Pere
WI
Deinked Market Pulp
70
1993/1994
Considering doubling capacity in new mill.
Great Lakes Pulp & Fibre Inc.
Menominee
MI
Deinked Market Pulp
175
1994/1995
Plan for new mill. 100% office waste.
Green Bear Inc.
Vancouver
WA
Deinked Market Pulp
155
1995
Proposal for 100% post-consumer wet lap mill.
International Resource Recycling
Camden
NJ
Deinked Market Pulp
135
1993/1994
Plan for new mill.
Mississippi River Corp.
Natchez
MS
Deinked Market Pulp.
100
1993/1995
Three-year expansion program.
North American Recycling Systems
Fort Edward
NY
Deinked Market Pulp
105
1994
Plan for new mill to supply tiesue producers.
F
Inc.
Hagerstown
MD
Deinked Market Pulp
100
1994
New mill. Stake/Recoupe process using mixed office waste.
P
cross Fibres of America Inc.
Oshkosh
WI
Deinked Market Pulp
30
1992/1993
Mill expansion.
Pondeross Fibres of America Inc.
Memphis
TN
Deinked Market Pulp
8
1992/1993
Mill expansion.
Pondeross Fibres of America Inc.
Augusta
GA
Deinked Market Pulp
7
1993
Mill expansion.
Pondeross Fibres/U.S. Generating Co.
Northhampton
PA
Deiaked Market Pulp
135
1994/1995
New mill and cogeneration plant.
Prime Fibre Corp.
Appleton
WI
Deinked Market Pulp
20
1993/1995
Three-year expansion program.
Resource Conversion Systems Inc.
Maywood
IL
Deinked Market Pulp
n.a.
n.s.
Possible mini-mill in town industrial park.
Solar International Trading Corp.
Morrieville
PA
Deinked Market Pulp
100
1994
Plan for new mill. 80% for sale to tissue mills, 20% export.
S : & Webster Inc.
Auburn
ME
Deinked Market Pulp
70
1994
New mill. Pulp for sale to printing/writing mills.
Superior Recycling Co. (Minnesota
Duluth
MN
Deinked Market Pulp
90
1993
New mill will produce high quality pulp from office waste.
Power/Pentair)
Chesapeake Corp./
West Point
VA
Deinked Pulp
53
1993
Considering new Stake/Recoupe process deinking plant. Possible market
De Novo Corp.
sale.
n.a. not available
Conforms to product grades for paper and paperboard as published in AFPA annual Capacity Surveys.
Learning curve and other factors may delay full utilization until following year.
Page 2
001:010DE151.WP
SEP 14 '93 11:53AM SD WARREN/HUMAN RES (617-423-5493
P.5/5
NR
Natural Resources
DC
Defense Council
DEINKED MARKET PULP PRODUCERS,
EXISTING a 100% P.C.
DEINKED
PULP
INITIAL
CAPACITY
STARTUP
COMPANY/LOCATION
(SHORT TPD)
DATE
Ponderosa,
150
1966
Santa Ana, Calif.
Ponderosa, Augusta, Ga.
180
1970
Ponderosa, Oshkosh, Wis.
250
1972
Ponderosa, Memphis, Tenn.
240
1974
Desencrage Cascades,
110
1986
Breakeyville, Que.
Mississippi River,
160
1993
Natchez, Miss.
Kieffer Paper Mills,
110
1992
Brownstown, Ind.
EcoFibre/Riverside Paper,
75
1993
De Pere, Wis.
Fox River,-De Pere, Wis.
220
1992
Total 1,495/day
Equals 523,250 TUNS TUNS/YeaR a 100% P.C.
available NOW: at 50%.
SEP 14 '93 11:53AM SD WARREN/HUMAN RES 617-423-5493
P.4/5
NR
Natural Resources
DC
Defense Council
POTENTIAL VENTURES IN NORTHEASTERN U.S.
(Project tinascel depeds ON DemanD)
Tons/Day
IRC - Fitchburg, Massachusetts
Project financed
400
Pejepscot - Topsham, Maine
Project financed
400
Stone and Webster - Auburn, Maine
Project financed
200
Wheelabrator - Concord, New Hampshire
Project financed
200
Ponderosa - Allentown, Pennsylvania
Corporate/Project
400
financed
North American Recycling -
Project financed
300
Troy, New York
Solar - Morrisville, Pennsylvania
Project financed
350
Delaware River Pulp - Camden, New Jersey
Project financed
300
Statler - Expansion in Augusta, Maine
150
Minnesota Pacific - N.E. U.S.
Project financed
400
Confidential Project - New York
Corporate/Project
400
financed
TOTAL
3500
Total wastepaper economically available in the Northeast will support 800 tonsiday - 1000
tons/day new capacity (S.D. Warren estimate).
Dara mareria 260-4711
DRAFT
August 3, 1993
What is the
EXECUTIVE ORDER
1:00 p.m.
States G- Executive OWaste Reduction
FEDERAL ACQUISITION, RECYCLING, AND WASTE PREVENTION
and Recycling
2
Recycled Projets
WHEREAS, the Nation's interest is served when the Federal
RCRA
Government can make more efficient use of natural resources to
enhance the quality of renewable resources and approach the coordinators 3 Recycling
maximum attainable recycling of depletable resources;
4 Council or
WHEREAS, this Administration is determined to strengthen the
Federal
role of the Federal Government as an enlightened, environmentally
conscious and concerned consumer;
and
Recycling
WHEREAS, the Federal Government should -- through cost- Procerent
effective waste prevention and recycling activities -- work to Boliey
conserve disposal capacity, and serve as a model in this regard
for other private and public institutions; and
WHEREAS, the use of recycled and environmentally preferable
products and services by the Federal Government can spur private
sector development of new technologies, use of such products and,
thus, create business and employment opportunities, enhancing
regional and local economies and the national economy;
NOW, THEREFORE, I, WILLIAM J. CLINTON, by the authority
vested in me as President by the Constitution and the laws of the
United States of America, including the Solid Waste Disposal Act,
Pub. L. No. 89-272, 79 Stat. 997, as amended by the Resource
Conservation and Recovery Act (RCRA), Pub. L No. 94-580, 90
Stat. 2795 (1976) as amended (42 U.S.C. 6901-6907), and section
301 of title 3, United States Code, hereby order as follows:
PART 1 - PREAMBLE
Section 101. Consistent with the demands of efficiency and
cost effectiveness, the Head of each Executive agency shall
incorporate waste prevention and recycling in the agency's daily
operations and work to increase and expand markets for recovered
Brue weddell
materials through greater Federal Government preference and
demand for such products.
Sec. 102. Consistent with policies established by Office of
Federal Procurement Policy (OFPP) Policy Letter 92-4, agencies
shall comply with Executive Branch policies for the acquisition
and use of environmentally preferable products and services and
implement cost-effective procurement preference programs favoring
the purchase of these products and services.
Sec. 103. The objectives of this order are to create an
what
ongoing Council on Environmental Progress and to establish high-
does this
level Environmental Executive positions within each agency to be
mean
responsible for expediting the implementation of existing
level
statutes and this order.
PART 2 - DEFINITIONS
English high the
Apprently,
For purposes of this order:
Pathou
2)
Sec. 201. "Environmentally preferable" means products or
services that reduce effects to human health and the environment
Marine
in comparison with competing products or services which serve the
here
same purpose. This comparison may consider production packaging,
distribution, reuse, operation, maintenance, or disposal of the
Sonewher, products BL 06 other dutts less why
product or service.
Sec. 202. "Executive agency" or "agency" means an Executive
Brand
agency as defined in 5 U.S.C. section 105. For the purpose of
this order, military departments, as defined in 5 U.S.C. 102, are
covered under the auspices of the Department of Defense.
Sec. 203. "Postconsumer Materials" mean materials or
finished products that have served their intended use and have
Anderil well 61 as
been discarded for disposal or recovery, having completed their
life as a consumer item. Postconsumer materials are a part of
the broader category of "recovered materials".
by
Sec. 204. "Acquisition" means the acquiring by contract
with appropriated funds for supplies or services (including
construction) by and for the use of the Federal Government
through purchase or lease, whether the supplies or services are
Extended Page 6.1
already in existence or must be created, developed, demonstrated
and evaluated. Acquisition begins at the point when agency needs
are established and includes the description of requirements to
satisfy agency needs, solicitation and selection of sources,
award of contracts, contract financing, contract performance,
- 2 -
contract administration and those technical and management
functions directly related to the process of fulfilling agency
needs by contract.
Sec. 205. "Recovered materials" means waste materials and
by-products which have been recovered or diverted from solid
waste, but such term does not include those materials and by-
products generated from, and commonly reused within, an original
manufacturing process (42 U.S.C. 6903 (19)).
Sec. 206. "Recyclability" means the ability of a product
or material to be recovered from, or otherwise diverted from, the
solid waste stream for the purpose of recycling.
Sec. 207. "Recycling" means the diversion of materials
from the solid waste stream and the conversion of those materials
into beneficial use. Recycling is further defined as the result
of a series of activities by which materials that would become or
otherwise remain waste, are diverted from the solid waste stream
by collection, separation or processing and are used in the
manufacture of products sold or distributed in commerce.
Sec. 208. "Waste prevention," also known as source
reduction, means any change in the design, manufacturing,
purchase or use of materials or products (including packaging) to
reduce their amount or toxicity before they become municipal
solid waste. Waste prevention also refers to the reuse of
products or materials.
Sec. 209. "Waste reduction" refers to preventing and/or
decreasing the amount of waste being generated either through
waste prevention, and recycling, or purchasing recycled and
environmentally preferable products.
Sec. 210. "Life Cycle Cost" means comparing the total cost
(capitol costs, including installation, plus maintenance costs)
over one product's expected lifetime to the total costs of a
competing product over its expected lifetime.
Sec. 211. "Life Cycle Analysis" means the comprehensive
examination of environmental effects throughout a products life
- 3 -
GENERAL COUNSEL
ID:202-395-7294
AUG 03'93 13:37 No.001 P.08
including new material extraction, transportation, manufacturing,
use, and disposal.
[Sec. 212. "Total chlorine-free" refers to products
What is
produced without the introduction of any chlorine-containing
the
compounds in the pulping and bleaching process.]
Status of
PART 3 - THE ROLE OF THE COUNCIL ON ENVIRONMENTAL PROGRESS
technology such
AND THE DESIGNATION OF ENVIRONMENTAL EXECUTIVES
how
Sec. 301. The Council on Environmental Progress. A Council
it
on Environmental Progress (Council) is hereby established.
It
does
to
shall be comprised of the Federal Environmental Executive, a
relate
representative from the White House Office on Environmental
recycling.
Policy, the Administrator for Federal Procurement Policy, and the
Environmental Executive from each of the following agencies: the
Environmental Protection Agency, the Department of Defense, the
General Services Administration, the National Aeronautics and
Space Administration, the Department of Energy, the Department of
Commerce, the Department of the Interior and the Department of
Agriculture.
(a) Authority. The Federal Environmental Executive shall
TaskForce
serve in a full time capacity as the Chair of the Council and
after consultation with the Council, may add additional agency
Task Force
environmental executives as representatives to the Gouncil.
(b) Administration. Agencies are requested to make their
services, personnel and facilities available to the JaskForce Council to
the maximum extent practicable for the performance of functions
under this order.
(c) Committees and Work Groups. As committees and work
Task Force
groups are established by the Council to fulfill its goals and
responsibilities, agencies are requested to designate appropriate
personnel in the areas of procurement and acquisition, standards
Extended Page 8.1
and specification, electronic commerce, facilities management,
waste prevention and recycling, and others as needed to staff and
TaskForce
work on the initiatives of the Council. The committee and work
groups shall identify, assess, and recommend actions to be taken
Task Force
to fulfill the goals, responsibilities and initiatives of the Council
- 4 -
Task Force
(d) Duties. The Council on Environmental Progress shall:
(1) identify and recommend initiatives for Government-wide
implementation that will promote the purposes of this order,
including:
(A) the development of a Federal plan for agency
implementation of this order and appropriate incentives
to encourage the acquisition of recycled and
environmentally preferable products by the Federal
Government;
(B) the development of a Federal implementation plan
and guidance for instituting economically efficient
Federal waste prevention, energy and water efficiency
programs, and recycling programs within each agency;
(C) the development of a plan for making maximum use of
available funding assistance programs;
(2) collect and disseminate information electronically
concerning methods to reduce waste, materials that can be
recycled, costs and savings associated with waste prevention and
recycling, and current market sources of products that are
environmentally preferable or produced with recovered materials;
(3) provide guidance and assistance to the agencies in
setting up and reporting on standardized agency programs and
monitoring their effectiveness; and
(4) coordinate appropriate Government-ide education and
training programs for agencies.
(e) Federal Environmental Executive. The Federal
shallbe
Environmental Executive designated by the President shall be
generate an annual
located within the EPA, and shall and report annually to
OMB, at the time of agency budget submissions, on the actions
taken by the Council and by the agencies to comply with the
Extended Page
9.1
requirements of this order.
This
(f) Staffing. A minimum of four (4) full time staff are to
TaskForce Task
be provided by members of the Council to assist the Federal
seens
Environmental Executive, one of whom shall have experience in
to
be
specification review and program requirements, one of whom shall
a
large
- 5 -
Committed resource
have experience in procurement practices, and one of whom shall
have experience in solid waste prevention and recycling. [These
four staff shall be appointed and replaced as follows:
(1) a representative from the Department of Defense shall be
detailed for not less than one year and no more than two years;
(2) a representative from the General Services
Administration shall be detailed for not less than one year and
no more than two years;
(3) a representative from the Environmental Protection
Agency shall be detailed for not less than one year and no more
than two years;
(4) a representative from one of the other agencies serving
on the Council shall be detailed on a rotational basis for not
more than one year.)
Sec. 302. Agency Environmental Executives. Within 90 days
after the effective date of this order, the Head of each
Department and major procuring agency shall designate an Agency
Environmental Executive from among its staff, who shall be placed
no lower than at the Deputy Assistant Secretary level or
equivalent. The Environmental Executive will. be responsible for:
(a) coordinating all environmental programs in the areas of
procurement and acquisition, standards and specification review,
facilities management, waste prevention and recycling, and
logistics;
(b) participating in the interagency development of a
Federal plan to
(1) create an awareness and outreach program for the private
sector to facilitate markets for environmentally preferable and
recycled products and services, promote new technologies, improve
awareness about Federal efforts in this area, and expedite
agencies efforts to procure new products identified under this
Extended Page 10. 1
order;
(2) establish incentives, provide guidance and coordinate
appropriate educational programs for agency employees; and
- 6 -
(3) coordinate the development of standard agency reports
required by this order.
(c) reviewing agency programs and acquisitions to ensure
compliance with this order.
Sec. 303. Agency Recycling Coordinators. Agency Recycling
Coordinators designated by the Agency Environmental Executive
shall be responsible for coordinating the development of an
what
effective agency waste prevention and recycling program and
prepatly
emphasizing agencies' purchase and use of recycled and
exits.
environmentally preferable products and services.
PART 4 - ACQUISITION PLANNING AND AFFIRMATIVE PROCUREMENT
PROGRAMS
Sec. 401. Acquisition Planning. Agencies developing plans,
drawings, work statements, specifications, or other product
descriptions shall consider the following factors: elimination
of virgin material requirements; use of recovered materials;
reuse of product; life cycle cost; recyclability; use of
environmentally preferable products; waste prevention (including
toxicity reduction or elimination); and ultimate disposal as
appropriate. These factors should be considered in acquisition
planning for all procurements and in the evaluation and award of
contracts, as appropriate. [Program and acquisition managers
should take an active role in these activities.)
Sec. 402. Affirmative Procurement Programs. The Head of
each Executive agency shall develop and implement affirmative
procurement programs in accordance with RCRA section 6002 (42
U.S.C. 6962) and this order. Agencies shall ensure that
responsibilities for preparation and implementation of
affirmative procurement programs are shared between the program
and requiring activity personnel and procurement personnel. A
process shall be developed by the agencies to ensure
implementation and monitoring of the affirmative procurement
programs by the program, requiring activity and procurement
personnel.
- 7 -
(a) Agencies shall establish affirmative procurement
programs for all designated EPA guideline items purchased by
their agency. For newly designated items, agencies shall revise
their internal programs within one year from the date EPA
designated the new items.
(b) For each of the currently designated EPA guideline
items, [concrete and cement containing fly ash; recycled paper
products; re-refined lubricating oil; retread tires; and
insulation containing recovered materials;] and for all future
guidelines, agencies shall ensure that their affirmative
procurement programs require that [100 percent of] their
purchases of products meet or exceed the EPA guideline standards
to the contracting officer unless written justification is
provided that a product is not available competitively within a
reasonable timeframe, does not meet appropriate performance
standards, or is not available at a reasonable price.
they is
track
[ (c) The Council on Environmental Progress will review and
EPA
monitor agencies annual purchases of designated EPA guideline
fication
items, and provide written notice to the Agency Environmental
in Lengure
Executives when their agencies fail to purchase or to justify
their reasons for not purchasing these items. Agency
Environmental Executives wil then be required to report justify to the
Task Force
or submit
Council on why the item (s) have not been purchased along with a
plan for how the agency intends to increase its purchases of
designated item (s)
[ (d) Agency affirmative procurement programs shall encourage
that documents be transferred electronically to the maximum
appropriate
extent practicable and when necessary.
(1) to the maximum extent practicable, that all government
documents printed internally be printed double-sided, and
(2) to the maximum extent practicable, that contracts,
grants, and cooperative agreements issued after the effective
date of this order, include provisions that require documents to
be printed double-sided on recycled paper meeting or exceeding
- 8 -
7672-969-707:41
COUNSEL
the standards established in this order or in future EPA
guidelines.)
Sec. 403. Procurement of Existing Guideline Items. Within
90 days after the effective date of this order, the head of each
Executive agency, that has not implemented an affirmative
procurement program, shall ensure that the affirmative
procurement program has been issued in final and is being
implemented to the maximum extent practicable.
Sec. 404. Electronic Acquisition System. To reduce waste
by eliminating unnecessary paper transactions in the acquisition
process, and to foster accurate data collection and reporting of
agencies' purchases of recycled and environmentally preferred
products, the Administrator for Federal Procurement Policy shall
provide policy guidance for the development and implementation of
a Government-wide electronic acquisition system. The system
shall facilitate the electronic interchange of standard
acquisition information between government and industry.
(a) Within 180 days after the effective date of this order,
the OFPP Administrator, in consultation with major procuring
agencies, shall provide specific guidance on the development and
implementation of the system to Executive agencies.
(b) To support this system, the EPA and GSA Administrator s in
coordination with the Secretary of Defense and other appropriate
agency heads, shall establish and maintain a publicly-accessible
electronic database highlighting recycled and environmentally
preferable products, that includes applicable commercial item
descriptions > (c) Classified'procurement (CIDs), standards and exemption specifications. should be maintained ITEMS
V
PART 5 - STANDARDS, SPECIFICATIONS AND DESIGNATION OF
see below
Sec. 501. Specifications, Product Descriptions and
Standards. [Where applicable,) OK executive agencies shall tab
soon as practicable,] review and revise Federal and military
specifications, product descriptions and standards to enhance
Federal procurement of products made from recovered materials or
that are environmentally preferable. When converting to a CID,
agencies shall ensure that environmental factors have been
(C) This electronic - acquisition 9 - - system shall not be
used for classified procurements.
considered and that the CID meets or exceeds the environmentally
preferable criteria of the government specification or product
description. Agencies shall report annually on their compliance
with this section in the report specified in section 604.
(a) If an inconsistency with RCRA Section 6002 or this
order is identified in a specification, standard, or product
shall
Environmental Executive of that
description, the Council may request that the agency responsible
on
for the specification advise the Council why the specification
hould can not be revised DR submit a plan for revising it within 60 days.
(b) If an agency should be able to revise an inconsistent
specification but cannot do SO within 60 days, it is the
responsibility of that agency's Environmental Executive to
the
for revising it.
monitor and enforce plan to achieve consis.ency.
[Sec. 502. Designation of Items that contain Recovered
Materials or are Environmentally Preferable. In order to
expedite the process of designating items that are or can be made
with recovered materials, EPA shall institute a new process for
designating items under RCRA section 6002. In accordance with
this order, EPA shall also identify and develop guidance for
items that are environmentally preferable.
(a) In accordance with RCRA section 6002 (e), EPA shall
issue 2 Comprehensive Procurement Guideline designating items
that are cr can be made with recovered materials.
(1) The proposed guideline shall be published for comment in
the Federal Register within 180 days after the effective date of
this order and shall be updated annually thereafter to include
additional items.
(2) Concurrently, EPA shall publish in the Federal Register
Procurement Advisory Notice (s) that recommend recovered material
content levels within which the designated recycled items are
currently available. These recommended levels shall be updated
periodically to reflect changes in market conditions.
(3) Once items containing recovered materials have been
designated by EPA through the new guideline process, agencies
shall procure these items to the maximum extent practicable and
- 10 -
modify their affirmative procurement programs to include these
items in compliance with RCRA section 6002 and this order.
(b) In accordance with this order, EPA shall issue guidance
identifying items that are environmentally preferable.
(1) The proposed guidance shall be published for comment in
Federal Register within 180 days after the effective date of this
order and shall be updated annually thereafter to include
additional items.
(2) Once items that are environmentally preferable have been
identified by EPA, agencies shall procure these items to the
maximum extent practicable and modify their procurement programs
to include these items.)
[Sec. 503. Minimum Content Standard for Printing and
Writing Papers. Executive agency heads shall ensure that by
January, 1995, agencies shall meet or exceed the following
minimum recovered materials content standards when purchasing or
causing the purchase of printing and writing papers:
(a) For high speed copier paper, offset paper, forms bond,
computer printout paper, carbonless paper, file folders, and
white woven envelopes, the minimum content standard shall be no
less than 15 percent postconsumer recovered materials. This
minimum content standard shall be increased to 25 percent
beginning in January 1999.
(b) For other uncoated printing and writing papers, such as
writing and office papers, book paper, cotton fiber paper, and
cover stock, the minimum content standard shall be 50 percent
recovered materials, including 15 percent postconsumer materials.
The postconsumer recovered materials content shall be increased
to 25 percent beginning in January 1999.
recycled
(1) The decision not to procureAprinting and writing paper
meeting the standards specified in this séction shall be
solely
based/on a determination by the contracting officer that a
satisfactory level of competition does not exist, that the
items are not available within a reasonable amount of time,
- 11 -
or that the available items fail to meet reasonable
performance standards established by the agency.
(2) If cost increases result from purchasing recycled
printing and writing paper, Each each agency should implement
as specified in section 402 (d)
waste prevention techniques (e.g. double-sides copying
electronic communications) SO that total annual expenditures
for recycled printing and writing papers do not exceed typical current annual
Paper products,
budgets for
these
products
as measured by average
based on
annual expenditures adjusted for inflation as measured by
the Consumer Price Index or other suitable index). In
determining a target budget for printing and writing papers,
agencies may take into account such factors as employee
increases or decreases, new agency or statutory initiatives,
and episodic or unique requirements (e.g., census) ]
[Sec. 504. Procurement of Re-refined Lubricating oil and
Retread Tires. Within 180 days after the effective date of this
order, agencies shall implement the EPA procurement guidelines
for re-refined lubricating oil and retread tires.
(a) Commodity managers shall finalize revisions to
specifications for re-refined oil and retreat tires, and develop
and issue specifications for tire retreading services, as
commodity managers shall take affirmative steps to procure these
items in accordance with RCRA section 6002.
(b) Once these items become available, fleet managers shall
take affirmative steps to procure these items in accordance with
RCRA section 6002.]
[Sec. 505. Product Testing. The Secretary of Commerce, through
shall maintain the capability within the National Institute of
shall establish a
Standards and Technology (NIST), for a laboratory accreditation
program for testing the performance of products containing
recovered materials or deemed to be environmentally preferable.
NIST shall review and update technical information and data on
product tests and standards in conjunction with EPA's issuance of
GSA
guidelines NIST shall work with EPA and other public and
private sector organizations that conduct appropriate life cycle
- 12 -
analyses to gather information that will assist agencies in
making selections of product and services that are
environmentally preferable.
(a)
NIST shall coordinate with other Executive and state
reverse
agencies to avoid duplication with other laboratory existing accreditation
testing programs.
b
NIST shall publish appropriate reports describing
the
testing tation program S
their
its
results, and recommendations
for test methods and related specifications for use by Executive
agencies and other interested parties.]
PART 6 - AGENCY GOALS AND REPORTING REQUIREMENTS
Sec. 601. Goals for Waste Reduction. Each agency shall
establish a goal for solid waste prevention and a goal for
recycling to be achieved by the year 1995. These goals shall be
submitted to the Council on Environmental Progress within 180
days after the effective date of this order. Progress on
attaining these goals shall be reported by the agencies to the
Council in the annual report specified in Sec. 50.1.
Sec. 602. Goal for Increasing the Procurement of Recycled
and Other Environmentally Preferable Products. Agencies shall
strive to increase the procurement of products that are
environmentally preferable or that are made with recovered
materials, and set annual goals to maximize the percentage of
these products purchased from their total budgets.
[Sec. 503. Goals for Procuring Totally Chlorine-Free Paper
Products. Each agency shall establish goals for procurement of
totally chlorine-free paper products to be achieved by 1995.
Separate goals shall be established for the different categories
of paper products, including; printing and writing, tissue and
towel, newsprint, paperboard, and packaging. Separate goals may
Extended Page 17. 1
be established for subcategories within these broad categories if
the Agency 50 chooses. These goals shall be submitted to the
Council on Environmental Progress within one year after the
effective date of this order. Progress on attaining these goals
- 13 -
shall be reported by the agencies to their annual report
specified in Sec. 604.]
Sec. 604. Annual Reporting Requirements. In accordance
with RCRA section 6002 and this order, each Federal agency shall
review the effectiveness of its affirmative procurement program
and efforts to implement this order, and provide a report
regarding its findings to the Office of Federal Procurement
Policy, Office of Management and Budget. Such report, beginning
with a report covering fiscal year 1993, shall be submitted
annually for the next four years and transmitted to OFPP and to
EPA by January 31 for the preceding fiscal year. Reports
required by this section shall be made available to the public.
Sec. 605. Review of Implementation. The President's
Council on Integrity and Efficiency (PCIE) will request that the
Inspectors General periodically review agencies' affirmative
procurement programs and reporting procedures to ensure their
compliance with this Executive order.
OK.
PART 7 - APPLICABILITY AND OTHER REQUIRIMENTS
Insert old Sec. 601 / asattached below
Sec. 701 A Real Property Acquisition and Management. Within
90 days from the date of this order, and to the extent permitted
by law and where economically feasible, Executive agencies shall
ensure compliance with the provisions of this order in the
acquisition and management of Federally owned and leased space.
GSA and other Executive agencies shall also include environmental
and recycling provisions in the acquisition of all leased space
and in the construction of new Federal buildings.
Sec. 703. Retention of Funds. Within 90 days after the
effective date of this Executive order, the Administrator of the
General Services Administration (GSA) in consultation with the
Council on Environmental Progress shall develop a legislative
Extended Page 18. 1
proposal, that if enacted, will provide authority for executive
agencies to retain proceeds from the sale of materials, recovered
through recycling or waste prevention programs and will specify
the eligibility requirements for the materials being recycled.
- 14 -
Inaddition,
Sec. 701. Contractor Operated Facilities. Contracts that
provide for contractor operation of a Government-owned or leased
facility, awarded after the effective date of this Executive
order, shall include provisions that obligate the contractor to
comply with the requirements of this orderATo the extent permitted by law.
and where economically feasible, existing contracts should be modifed.
Sec. 70st. Model Facility Programs. Each Department and
major procuring agency shall establish model facility
demonstration programs that include comprehensive waste
prevention and recycling programs and emphasize the procurement
of recycled and environmentally preferable products and services
using an EDI system.
Sec.
700. Recycling Programs. Each Executive agency that
has not already done so shall initiate a program to promote cost
effective waste prevention and recycling of reusable materials in
all of its facilities. The recycling programs implemented
pursuant to this section must be compatible with applicable state
and local recycling requirements. Federal agencies shall also
consider cooperative ventures with state and local governments to
promote recycling and waste reduction in the community.
PART 8 - AWARENESS
Sec. 801. Agency Awards Program. A Government-wide award
will be presented annually by the White House to the best, most
innovative program implementing the objectives of this order to
give greater visibility to these efforts so that they can be
incorporated Government-wide.
Sec. 802. Internal Agency Awards Programs. Each agency
shall develop an internal agency-wide awards program, as
appropriate, to reward its most innovative environmental
programs. Winners of agency-wide awards would be eligible for
the White House award program.
PART 9 - REVOCATION, LIMITATION AND IMPLEMENTATION
Sec. 901. Executive Order No. 12780, dated October 31, 1991,
is hereby revoked.
Sec. 902. This order is intended only to improve the
internal management of the executive branch and is not intended
to create any right or benefit, substantive or procedural,
enforceable at law by a party against the United States, its
agencies, its officers, or any other person.
Sec. 903. The policies expressed in this order, including
the requirements and elements for effective agency affirmative
- 15 -
procurement programs, shall be implemented and incorporated in
the Federal Acquisition Regulation (FAR) within 180 days from the
effective date of this order. The implementation language shall
consist of providing specific direction and guidance on agency
programs for preference, promotion, estimation, certification,
reviewing and monitoring.
Sec. 904. This order shall be effective immediately.
THE WHITE HOUSE,
- 16 -
GENERAL COUNSEL
NI BY:Xerox relecopier 1421 ID:202-395-7294 0- 6-00
AUG 03'93 13:32 No. 001 P.02
STREAMLINED PROCESS
Section 502 of the order
Background
Over the past few years, EPA has implemented the
requirements of Section 6002 of RCRA through its procurement
guideline development process. The guidelines have included the
designation of procurement items and recommandations on how to
procure the designated items, including minimum content
standards. Currently, both the item designation and the
procurement recommendations are proposed and finalized as one
document in the Federal Register (EB) and subsequently codified
in Title 40 of the Code of Federal Regulations (CER). It is this
codification that subjects quidelines to a lengthy formal review
process. (Historically, it has taken two years to develop and
issue guidelines through this process.) This has greatly limited
our ability to issue guidelines in a timely and efficient manner.
EPA has two often-opposing objectives in developing
procurement guidelines: to maximize the amount: of recovered
materials used to manufacture recycled products and to maximize
the quantity of recycled products purchased by Federal agencies
through affirmative procurement. Creating an "qual balance
between these two objectives is the only way WIL can impact the
markets for recoverable materials. We must establish recycled
content levels that would allow a reasonable number of sources to
provide recycled products at a cost the government can afford.
Proposal
Dus to the inordinate amount of time it currently takes to
draft Executive Order divides the designation and the
issue guidelines for items containing recovered materials, the
The first step would utilize the formal rulemaking process. EPA
recommendation portions of the guideline into two separate steps.
would establish a Comprehensive Procurement Guideline (CPG)
consisting of a list of items that are or can be made with
an interagency workgroup process, would be codified in the CFR.
recovered materials. The CPG, which would be developed through
Public comment would be taken on the proposal and considered in
but preparing the final rule. EPA would update the CPG periodically,
no less often than annually.
The second step would involve the issuance of a Procurement
Advisory Notice (PAN) by EPA. This notice would recommend
recovered materials content lavels for items that were designated
in the CPG. EPA would issue the PANS at least annually and would
announce their availability in the FB.
it would not be codified through the formal rulemaking process.
As with the CPG, the PAN would undergo public comment, but
Because PANs are only recommendations, using the formal
rulemaking procese would be unnecessarily burdansome. When
GENERAL COUNSEL
ID:202-395-7294
SENI
AUG 03'93
13:33 No 001 P.03
procuring products using a recommended content level, Federal
agencies would dotermine the suitability of the content level in
meeting their performance requirements. As with all
procurements, the Competition in Contracting Act, which is
implemented through the Federal Acquisition Regulations, would
protect the rights of individual companies unable to meet the
recycled content levels established by EPA.
PAN Development Process
EPA would form an interagency workgroup, which would include
representatives from EPA, Federal agencies, and other interested
or affected agencies, including OMB. The workgroup would meet to
discuss various alternatives for developing the PAN. Upon
reaching consensus, EPA would finalize the draft PAN and publish
it for public comment in the Notice section of the FR. Following
the public comment period, EPA would reconvene the interagency
workgroup to consolidate comments received and to resolve
outstanding issues. EPA would then prepare the final PAN for
workgroup review. The final PAN would be published in the Notice
section of the FB after addressing comments on the draft PAN.
Advantages
There are several advantages to streamlining the current
guideline development process. The first advantage is the
ability to designate more items. By creating a more efficient
guideline development process, we will be able to designate
dozens of different items simultaneously rather than specifically
focusing on one or two items. The more items that we designate,
the greater impact Federal procurement will have on developing
markets for recyclable materials.
The second advantage 15 timeliness. since minimum content
standards or levels are recommendations, they do not necessitate
the use of the lengthy formal rulemaking process, thereby saving
time and money in research and development. x180, by issuing the
draft and final recycled content recommendations in the Notice
section of the FB, we will avoid the time-consuming process of
amending the CFB. This will allow us to quickly adjust the PANs
to reflect content levels actually procured by Federal agencies.
Finally, expediting the process will enable us to stay in
the forefront of technological changes in recycling as recovered
materials content increases in products.
GENERAL COUNSEL
ID:202-395-7294
AUG 03'93
13:34 No. 001 P. 04
Section 503 or the order
COSTS OF THE RECYCLED PAPER PROVISIONS or THE EXECUTIVE ORDER
Based on discussions with industry representatives, materials
provided by individual paper companies, and our own analyses, we
believe that, over the short term, it will be more expensive for
the large, virgin integrated mills to make paper that contains 15
& postconsumer recovered materials than if they continue to use
only virgin raw materials. Thus, 11 the paper companies pass these
increased costs on to their customers, the gcvernment's cost of
recycled commodity grade papers will be higher in the near term
than comparable virgin papers.
We do not know for sure what the increased production costs
w111 be over the short term and have not received definitive cost
estimates from industry. We know that the incremental cost will
increase as the amount of recycled content increases because it
costs these mills more to buy deinked pulp from another
manufacturer than to make virgin pulp at their own facility. Based
on data received from industry, over the short term, we estimate
that the likely production cost increase for large commodity grade
mills to shift from total virgin production to a 15 t postoonsumer
recycled content will range from 9 to 12 t.
Over the long term, as companies make the decision to build
their own deinking plants, their production costs will decrease
because they can make deinked pulp at lower costs than they can pay
to have someone make it for them. Thus, we expect that over the
long term the cost of recycled commodity papers will approach the
cost of virgin commodity papers. We do not have the data or
information that would enable us to predict when that might occur,
but it is reasonable to assume that it would take on the order of
5 years for industry to add significant recycling capacity at the
large commodity mills.
We are very concerned about any action that would increase
the government's costs of doing business. Thus, the Executive
Order contains a provision that directs agencies to off-set any
recycled paper cost increases by reducing their paper usage. This
provides an incentive for agencies to implement waste prevention
techniques such as double-sided copying and use of electronic
communications methods. Thus, agencies will bir able to purchase
recycled paper without increasing their current budgets and are
likely to save money over the long term.