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A. Hydraulic Mulch
1. Background
In the CPG, EPA proposed designating hydraulic mulch products used for landscaping
and erosion control in hydroseeding applications and as an over-spray for straw mulch (see
59 FR 18877, April 20, 1994). Hydraulic mulch is made of small pieces of cellulose fibers,
which can be either wood or paper. It is applied to a soil surface by mechanical spraying,
usually in a process known as hydroseeding, which involves spraying a mixture of water,
seeds, and the hydraulic mulch over soil. The mulch provides stability for the soil,
preventing erosion, and provides protection and warmth for the seeds, facilitating
2. Summary of Comments and Agency's Response
No commenters opposed the proposed designation of hydraulic mulch.
3. Rationale for Designation
EPA believes that hydraulic mulch products satisfy the statutory criteria for selecting
items for designation.
a. Use of materials in solid waste. As discussed above in section II.A, paper is a
significant component of the solid waste stream. Construction and demolition debris contains
. a significant percentage of wood. Although recovered paper is used by the pulp and paper
industry, there continues to be a need for additional markets for this material.
b. Technically proven uses. EPA is aware of at least 37 manufacturers of paper-
based hydraulic mulch located throughout the U.S. There also are several manufacturers of
wood-based hydraulic mulch using recovered wood.
The hydra&c mulch. industry is divided on the benefits and drawbacks of paper-based
and wood-based hydraulic mulch. Manufacturers of each item claim superior performance of
their products. It is EPA's understanding that the International Erosion Control Association
is developing performance standards for hydraulic mulch to resolve the dispute over
c. Impact of government procurement. Government agencies purchase, or use
appropriated Federal funds to purchase, hydraulic mulch products. EPA estimated the 1990
expenditures for these products to be $10-15 million, or approximately 50 percent of the
hydraulic mulch industry's total revenues. The Federal government represents a large share
of this market, because hydraulic mulch products are used extensively in highway


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