CMRA Submits Comments For EPA Strategic Plan

The Construction Materials Recycling Association (CMRA) has submitted comments to the U.S. EPA regarding its draft strategic plan for the next five years. The comments focused on promoting C&D recycling while providing guidance on how to measure the waste stream. The following is the text of those comments:

The Construction Materials Recycling association is considered the leading U.S. expert on construction and demolition materials and their recycling. We appreciate the opportunity to comment on the EPA’s proposed strategic plan.

We focus on section 3.1.1. The third bullet point is where the agency wants to develop a C&D goal. We are delighted EPA wants to do this, but have the following cautions and recommendations:

• The agency has no real solid baseline estimate on how much C&D is generated. Currently the agency has an outside vendor trying to develop this estimate. But even then, all agree that C&D is divided into two parts, building related and road and bridge related. That is how the agency is currently trying to estimate C&D waste generation. We recommend that any goals to improve C&D recycling rates separate these two. From there we should develop goals based on the CMRA estimates of how much is recycled.

• We also recommend that the agency include in its plan a provision for market development assistance to reach any goals that are developed. Some suggestions include working with state DOTs to promote the use of recycled concrete and shingles in roadways, C&D fines as a fill material and mulch for erosion control. The EPA could also support added value products for wood such as infeed for medium density fiberboard and similar plants. The agency could also make sure that C&D wood, which makes an excellent fuel for power generation, is included in the Bush administration’s push for alternative energy.