The authors of this article review evidence showing that Americans produce as much as 140 million tons of litter each year and that the annual cost of cleaning it up may be as much as one billion dollars. A significant portion of this litter is in the form of nonreturnable cans and bottles. This has portion of this litter is in the form of nonreturnable cans and bottles. This has prompted many approaches to the littering problem, including those suing monetary rewards for picking up litter and for recycling. As the authors note, monetary rewards for picking up litter and for recycling. As the authors mote, monetary rewards end to be easily obtainable and continuously available to be effective. On September 12, 1983, the state of New York enacted a “Bottle bill” which required a “5-cent deposit on every bottle and can of been and soda” sold in Now York. The goal was to provide a positive incentive for people to return these containers rather than discard them, as to encourage people to pick up those that had been discarded.