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U.S. Department of the Interior
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DOI's National Business Center EPP Paper Pilot Test Report


Consistent with its resource trust responsibilities, the Department of the Interior has become a leader within the federal government promoting public/private partnerships to develop and purchase environmentally preferable products, particularly by facilitating joint ventures between private manufacturers and non-profit agencies that employ persons who are blind or disabled. It is through such an effort that Interior has endeavoured to purchase of paper made with 100% postconsumer recycled fiber ("tree-free") and made without the use of chlorine.

The Blind Work Association, Incorporated of Binghamton, New York has developed this product and has made it available to Interior at the cost of $3.22 per ream. Paper made with 30% postconsumer waste (pcw) recycled content procured currently through the Government Printing Office (GPO) costs, on average, $2.17 per ream. With this cost difference, the additional expense projected over 12 months, based on the current paper use, would be approximately $65,520.

Based on the amount of paper purchased annually, 62,400 reams, Interior would capture certain environmental benefits by switching to 100% pcw paper from 30% pcw paper. Summarized below are these estimated benefits, along with the cost to DOI to capture that unit of benefit based on the additional cost to purchase the more preferable paper:

  • 1,938 pulp trees saved
    ($34.13 per tree)

  • 561,378 kilowatt hours saved
    ($0.12 per kilowatt)

  • 239,078 lbs. greenhouse gas (ghg) emissions avoided
    ($0.28 per lb.ghg)

  • 7,895.5 lbs. of waterborne waste effluents avoided
    ($8.38 per lb waste )

Estimated monetary value of benefits - $266,614

Because the product is converted at a workcenter employing persons with disabilities, over 468 hours of blind persons' labor are used in the manufacture of a year's worth of paper for DOI, resulting in, among other important benefits, fewer federal dollars disbursed as social security insurance.

Due to the additional cost of this paper, the National Business Center will incur or otherwise have to charge an additional $0.00212 per sheet in providing copying services to Main Interior Building customers, which is 2% of the cost for a double-side print job. On a large printing project, such as the FY02 budget book for the National Park Service which orders 250 books - each 700 pages printed single to double-sided, using this environmentally preferable paper would cost an additional $185 on a total project cost of approximately $12,250.

Considering the environmental benefits, the social benefits, and the interest of the government in supporting the development of markets for businesses that manufacture environmentally preferable products, it is recommended that the National Business Center procure the 100% postconsumer recycled paper now available from Blind Work Association


History: Previously, Interior had tested higher recycled content paper. In the mid-1990's, the Main Interior Building briefly used Unity DP which had 100% recycled content, including 50% postconsumer paper (mostly groundwood fibre). The use of Unity was discontinued for a number of reasons. It had a grey/brown color which was difficult to use in copy machines. It caused excessive linting. It also confused the recycling program participants because it could not be recycled as white paper, and it potentially exceeded the ground wood parameters for mixed paper recycling.

The Department of the Interior conducted pilot testing of two brands of environmentally preferable paper in 2000. The results are relayed below. In 2001, the General Printing Office and the Environmental Protection Agency (EPA) conducted a pilot testing of environmentally preferable paper. Twelve federal agencies participated in the test by purchasing 1 - 3 skids for use in their offices. The paper for the pilot was procured competitively using a specification developed by EPA. The results of this testing are still being compiled.

Commitment: The Department of the Interior has identified as a goal to purchase and use environmentally preferable, high recycled-content, process-chlorine free copy paper. This goal is related in the Strategic Plan for Greening the Department of the Interior Through Waste Prevention, Recycling and Federal Acquisition, May 2000, and in the Department's FY 2002 Annual Performance Plan. Fulfilling this goal would mean that every DOI facility would use the environmentally preferred paper in their offices and identify it as a requirement in all printing requests and contracts for services. Federal agencies are currently mandated to purchase paper made with a minimum of 30% postconsumer waste content, under Section 6002 of the Resource Conservation and Recover Act (RCRA), which directs federal agencies to purchase products that have the highest percentage of recovered materials practicable, considering price, availability, and performance.

Availability: As part of its commitment to buying environmentally preferable products from preferred and mandatory acquisition sources, the Department of the Interior sought to identify whether such products could be purchased from a National Industries for the Blind affiliated non- profit agency. Interior's commitment to mesh its' interest in environmentally preferable products with its obligations under the Javits-Wagner-O'Day Act (JWOD) was documented in a Memorandum of Agreement signed by the Assistant Secretary - Policy, Management and Budget on behalf of Interior and representatives of the Committee for Purchase from People Who are Blind or Severely Disabled, the National Industries for the Blind, NISH, and the U.S. Environmental Protection Agency.

Opportunity: Recently, a number of high quality, "bright white" high recycled content paper brands have become available at prices comparable to the 30% postconsumer content paper. Approximately $200,000 worth of paper (over 150 skids) is used each year by the National Business Center's Creative Communication Services (CCS) in the print shop and in the self- serve copy centers within the Main Interior Building and South Interior Building.

Paper Attributes:

Market analysis led to the identification of two brands of environmentally preferable copy paper. Encore 100 paper distributed by New Leaf is made of 100% postconsumer recycled material and is made without the use of chlorine or chlorine derivatives for deinking and bleaching. This paper is produced by Badger Paper Mills, with mills in Peshtigo and Octonto Falls, Wisconsin. Badger has undertaken an audit and testing through Integrated Paper Services, Inc. to substantiate their environmental claims. The audit cover sheet, dated November 29, 2000, indicates that a single process line was tested for the presence of chlorine and it was found to be negative.

Rolland's New Life paper is made of 60% postconsumer recycled waste, 80% recycled content, with the remaining 20% including totally chlorine-free virgin fiber. This paper has been audited and endorsed by the Chlorine Free Products Association, certified as "process chlorine free" (PCF). The PCF certification verifies the following attributes of paper:

  • No chlorine or chlorine compounds were used in the papermaking process

  • How the mill determined post-consumer content

  • The mill has no current or pending violations

  • The mill does not use old growth forest for any of the virgin pulp

  • The product contains at least 30% post-consumer content.

Both papers are recyclable as Grade 1, white office paper. Paper must not contain more than 10% groundwood by weight. Ream wrap is recyclable as mixed paper (Grade 2).

Testing Results:

Interior's National Business Center- Creative Communication Services initiated a pilot test of environmentally preferable paper in May, 2000. Both brands of paper were purchased. In pilot tests performed in copy machines used in the Main Interior Building, the two papers performed adequately. Neither papers created copy machine jams that exceeded normal operations. The New Life paper appeared to be a little thicker and brighter than the Encore 100, but this did not seem to result in a functional difference. Improper storage of the paper acquired in July 2000 may have contributed to a slight curling tendency noted. The paper was stored for nearly three months without humidity control before it was used. Attached is a more complete summary of the testing performed.

Analysis of Benefits of Environmentally Preferable Paper:

There have been two comprehensive studies of the paper and pulp industry that are often cited to describe the environmental aspects of paper manufacture. In 1995, an extensive study was published by the Environmental Defense Fund (EDF). Working with its' "Paper Task Force," EDF involved Duke University and representatives of Johnson and Johnson, McDonald's, Prudential Insurance of America and Time, Inc. Also in 1995, the Environmental Protection Agency's Office of Enforcement and Compliance Assurance published a "Profile of the Pulp and Paper Industry," as part of its' Sector Notebook Project. This profile was updated in 1998. These two lifecycle assessments of the paper manufacturing process appear to be the most often cited studies available at this time Other recent reviews of the industry, including papers by the Worldwatch Institute (1999) and the Institute of Scrap Recycling Industries (undated), reference these two sources.

For the purpose of this analysis, the EDF study offers resource utilization data that is tied to units of production, which allows for the break down of benefits per unit incremental cost difference which is outlined below.

Comparison of Resource Inputs/Outputs Related to the Manufacture of 30% Postconsumer Recycled Paper and 100% Postconsumer Recycled Paper
Resource Input/Output
30% PCC Paper
100% PCC Paper
% Difference
Energy Usage (000 BTUs)
33,421 21,657 35%
Net Greenhouse Gases (CO2 Equivalents
5,050 3,582 29%
Nitrogen Oxides
17.3 14.4 17%
Particulates 10.9 7.3 33%
Sulfer Oxides
26.2 25.6 2%
Hazardous Air Pollutants (HAPs)
1.53 0.2 87%
Volatile Organic Chemicals (VOCs)
4.4 1.8 59%
Total Reduced Sulfur (TRS)
0.21 0 100%
Solid Wastes (lbs)
1,911 1,154 40%
Adsorbable Organic Halogens (AOX)
1.2 0 100%
Biochemical Oxygen Demand (BOD)
6.23 6.1 2%
Chemical Oxygen Demand (COD)
72.5 27.6 45%
Suspended Solids
9.13 6.9 24%
Effluent Flow (gals)
12,461 10,325 40%
Wood (lbs)
4,854 0 100%


At the request of the Department of the Interior, the National Industries for the Blind worked with one of its affiliated non-profit agencies to develop the capabilities to convert and sell the higher recycled paper to Interior purchasers. The Blind Works Association of Binghamton, New York approached both Rolland and New Leaf to arrange to purchase paper rolls to convert (cut to size and package in cartons). Blind Works Association found that it would be most economic to work with New Leaf. Packaging to be provided by Blind Works Association is an innovative 5 ream carton with out individual ream wraps. Blind Works Association holds the patent on this packaging, which is safer and convenient for office users (weighing 25 lbs. instead of 50 lbs. per box). Also, there is less solid waste from ream wrap waste which is typically not recyclable.


There is a $1.06 additional cost per ream. This would amount to an additional $62,400 annually to CCS, given a average purchase rate of 13 skids of paper per month. Some of this cost could be added to the service rate charged to customers who use CCS's self-serve copy centers and printing services.

Per sheet, this increment is 0.002 cents. Currently, copying services in the self-serve copy centers cost $0.07 per impression (for both single and double-sided non-rush print jobs).

CCS currently sells cartons for $31.00 each to bureau and offices in the building, realizing a $9.30 profit on each carton. If CCS were to market the 100% pcw paper at $18 for a 5 ream box (equivalent to $36 per 10 ream carton), it would realize roughly half of what it had previously. The National Business Center sells XXX cartons of paper per month. This represents only a portion of all the paper purchased in the building. If CCS were to market the unique packaging and environmental attributes of the paper it could increase sales, especially because it is otherwise very difficult to get this paper in small quantities. To make up the loss of $5 on each carton, CCS would need to sell almost twice as much to realize the same net revenue.

It is Interior's goal to pay approximately the same as the 30% postconsumer recycled content paper. However, very often, when new environmentally preferable products are new on the market, the pricing is not initially as competitive as the traditional alternative. Implicit in the drafting of RCRA Section 6002 and Executive Order 13101, "affirmative procurement" by federal agencies is intended to create and sustain markets for these emerging products so that they may become more commercially viable. For this reason, the Office of Federal Procurement Policy letter 92-4indicates it is permissible to consider life cycle cost analysis to assist in making product and service selections.

Costs of Environmental Benefits:

By simple calculation, the additional cost of purchasing the 100% pcw paper over the 30% pcw paper can be compared with the unit resources saved or emissions avoided, as documented in the EDF study previously cited. Assuming a ream weighs 5 lbs. 3.5 oz., an additional $406.13 can be allocated to a ton of paper purchased. Apportioning this cost to the EDF study benefits yields the following cost of benefits:

  • $0.12 for each kilowatt hour of energy consumption avoided in manufacturing

  • $34.13 for each pulp tree not felled

  • 8.4 lbs. of green house gas emissions avoided per dollar additionally spent

Again, by simple arithmetic, it can be projected at the rate of annual paper purchasing the following environmental benefits may accrue:

Calculations are detailed below:

No. of Reams in a Ton of Paper
Each Ream Weighs 5 lbs 3.5 oz.
(as weighed at the MIB P.O.)
2,000lbs/5.22 lbs = 383.14 ream/tons
No. of tons of paper consumed annually in MIB copy centers
13 skids/mo. x 12 mo./yr. x 40 cartons/skid x 10 reams/carton = 62,400 reams/yr.
62,400 reams/yr. / 383.14 reams/ton = 162.86 tons paper/yr.
Cost differential per ton between 100% pcw paper and 30% pcw paper
Cost differential per sheet
$3.225 /ream - $2.17/ream = $1.06 dif./ream
383.14 reams/ton x $1.06 / ream = $406.13 /ton
500 sheets/ream
Cost difference of $1.06/ream
$1.06 / 500 = $0.00212 per sheet

Trees saved per year by changing to 100% pcw paper from 30% pcw paper
Additional cost of 100% pcw over 30% pcw allocated per tree saved (cost per tree)

~17 trees required to manufacture
1 ton of virgin paper3
By changing to 100% pcw paper, Interior would save an additional 70% of those 17 trees (~11.9 trees/ton)
11.9 trees saved/ton x 162.86 tons/yr = 1,938 trees saved/yr
$406.13 / ton / 11.9 trees/ton = $34.13 per tree saved
Energy saved (kwh) in the manufacture of 1 ton of 100% pcw as compared with 1 ton of 30% pcw paper
Energy saved per year by changing to 100% pcw paper from 30% pcw paper
Cost per kwh saved by purchasing 1 ton of 100% pcw paper instead 30% paper
33,421,000 - 21,657,000 = 11,764,000 btus
11,794,000 btus x 0.29305 = 3,447 kwhs1/ton paper
3,447 kwhs/ton x 162.86 tons/year = 561,378 kwhs/year
(Approx. equivalent to 12 months of energy use in 60 homes) 2
$406.13 / 3,447 kwh/ton = $ 0.12 /kilowatt
Greenhouse gas (lbs. ghg - CO2 equiv.) emissions avoided in the manufacture of 1 ton of 100% pcw as compared with 1 ton of 30% pcw paper, and per year of purchasing by DOI
Cost per lb. Ghg emissions avoided by purchasing 1 ton of 100% pcw paper instead 30% paper
5,050 lbs. - 3,582 lbs. = 1,468 lbs. ghg/ton
1,468 lbs. ghg/ton x 162.86 tons/yr. = 239,078 lbs. ghg/year
$406.13 / 1,468 lbs. ghg/ton = $0.28 /lb. Ghg
Waterborne waste effluents avoided (lbs. AOX + BOD + COD + SS) in the manufacture of 1 ton of 100% pcw as compared with 1 ton of 30% pcw paper, and per year of purchasing by DOI
Cost per lb. waterborne waste emissions avoided by purchasing 1 ton of 100% pcw paper instead 30% paper
1.19 lbs. - 0 = 1.19 lbs. AOX
6.23 lbs. - 6.1 = 0.13 lbs. BOD
72.53 lbs. - 27.6= 44.93 lbs. COD
9.13 lbs. - 6.9 = 2.23 lbs. SSs
Total waterborne waste effluents avoided per ton = 48.48 lbs.
48.48 lbs/ton x 162.86 tons/yr. = 7,895.5 lbs./yr.
$406.13 / ton / 48.48 lbs. = $8.38 /lbs
Employment of blind persons (hours/ton of paper)
3 employees required to cut and ream wrap paper:
1 emp. operates machine at 240 reams/hour
(383 reams/ton / 240 reams/hr = 1.6 hrs/ton)
2 emps. wrap 600 reams/hour
(383 reams/ton / 600 reams/hr x 2 emps. = 1.28 hrs/ton)
Total for 3 employees = 2.88 hours / ton of paper purchased
2.88 hrs/ton paper x 162.86 tons/year = 468.5 hours/yr.

  1. 1 btu = 0.29305 kwhs The Engineer's Companion: A Concise Handbook of Engineering Fundamentals

  2. Average home energy use is 780 kwhs, provided by Pacific Gas and Electric Company

  3. Recycling Paper, Institute of Scrap Recycling Industries

Attachment A - Environmentally Preferable Paper Pilot Testing

Efforts described in this report were undertaken to evaluate and, as appropriate, support the procurement of environmentally preferable paper for use in the Main Interior Complex, and throughout the Department. A pilot test, conducted in two phases, was undertaken toward this end to determine if the performance of environmentally preferable paper is suitable for use in the Main Interior Complex as a standard copy paper. In addition, the environmental benefits of the paper will be summarized along with the costs of its procurement.

Paper Tested:

The Department of the Interior initiated a pilot test of environmentally preferable paper at the Main Interior Building in May, 2000. Two brands of paper were purchased: New Leaf Encore 100 and Rolland New Life. At the time the test was initiated, these were the only two brands that could be identified as having a chlorine-free manufacturing process and that was made with a high percentage of postconsumer waste content. The papers tested also had the attribute of being made without the use of chlorine or chlorine derivatives in the deinking or bleaching processes. Both papers appear "white" to users, not grey or brown, with a minimum of 85% brightness. Both papers were tested at the 20# weight. In addition, a 24# weight 11" by 14" product by Rolland was also used for printing the Strategic Plan for Greening the Department of the Interior.

For the initial testing, 40 cartons of Encore 100 and 20 cartons of New Life paper were purchased and delivered to the Main Interior Building in May 2000. Paper was stored in the loading dock area until testing commenced in July, 2000.

The paper was used in both the print shop and in the 6th floor self-serve copy center. The machines were serviced by a technician prior to the beginning of the pilot project and after the testing was complete. The paper was used in the following types of machines: Xerox 5680, Xerox 5690, Xerox 265, Xerox Docutech. Xerox.

The primary focus of the pilot testing was to determine copy machine compatibility. The following characteristics were assessed as follows:

  • Jamming: User logs were placed in public copy centers and CCS copiers. Direct sales clients received a questionnaire. Visual observations were made by CCS personnel to see if jamming occurred.

  • Linting: Preventive maintenance on the machines was preformed prior to initiating the pilot. At the end of the pilot period, the machines were evaluated for the presence of lint and compared with a machine serviced at the same time using the non-pilot paper.

  • Spotting: The photoreceptors on the testing copy machines were cleaned just prior to the beginning of the test and once again at the end to determine the amount of spotting as a result of the new paper product.

  • Curl: It was noted if excessive curling was observed.

In order to document and keep track of machine jammings as a result of the paper, a log sheet was created and used for by all of the involved Creative Communication Services' staff.

These following observations were made by National Business Center Creative Communication Services staff based on the pilot use testing performed in July 2000. Network Print Specialist, Abu M. Abdullateef, coordinated the pilot testing.

  • In the Xerox Docutech NP35, no excessive jamming was observed and both paper performed equally well. (V. Girarei)

  • A curling tendency was noted in the Encore 100 as compared with the New Life paper and with other papers used. (M. Whitiker)

  • In the "old" Xerox 5690, the New Life paper seemed to jam less than the Encore 100 paper. (M. Whitiker)

  • The Encore 100 paper seemed to bend more easily than the New Life. (M. Whitiker)

  • In the Digithpath 6155, no substantial difference was noted between the performance of the New Life and the Encore 100 papers. (R. Dunn)

  • He did observe that the Rolland paper was visually superior than the New Leaf paper, but noted no functional differences between the papers with reference to his machine.

  • The New Life paper appeared to be slightly thicker than the Encore 100 paper. (Whitiker, Dunn, Hunter)

  • The New Life paper appeared to be slightly brighter than the Encore 100 paper. (Whitiker, Dunn)

  • In the self-serve copy room where there are two Xerox 5680s and a DC-265st, neither paper appeared to create additional jams over the paper that has been previously used. (Abdullateef)