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Listed below are comments received from stakeholders relating to the
issue area of
recovery and recycling payments
. Comments are received through
stakeholder meetings and correspondence. Due to transcription and/or space
limitations, the following may be paraphrased from the original comment
received.
Comments/Questions (received as of March 17, 2004)
- We (local govt.) hold collection events currently. We have an appointment system, extra staffing at event--more costs than just processing the equipment. Each event costs about $15,000. If we apply for reimbursement, what is
eligible?
- What are you going to include in determining your fee to come up with your fee
schedule?
- Break fee into 3 parts i.e., transportation, collection and recycling. Transportation involves different parties and
distances.
- How are the invoices going to be checked against actual materials
collected?
- Does SB 20 apply to those that are exporting if they decide not to receive
payments?
- Any thought to potential unscrupulous operators bringing CRTs into the state and trying to collect fees? How can this be
prevented?
- Is there a cap on the fee? Who would get payments first?
- Please give special consideration to rural counties implementing bill. We have higher costs due to lack of
infrastructure
- If we (local govt.) collect 1,000 CRTs in 2/04, can we get reimbursed or do we need to wait until
July?
- We (recyclers) would like to be charged on a per pound basis as we are with the bottle
bill.
- Plastics in these goods are very difficult to recycle. How do plastics in general
fit?
- We (recyclers) need a formal dialogue between manufacturers and recyclers. Manufacturers say they can’t release information because it’s proprietary. This lack of info impedes progress. Manufacturers hide behind this veil and impede progress toward
recycling
- Think it would be bad for recyclers to have to wait 90 days for payment. Would like to see 30
days.
- Payment system can’t be specific to everybody – differences in services and locality. Don’t prohibit access to system because they have to charge a little bit beyond what they receive from SB 20. Don’t make eligibility case by case.
- Can local governments charge a recycling fee for CRTs?
- We (local govt.) are going to collect CRTs through our bulky waste program. When can we get reimbursed for
that?
- Six million computer monitors in CA. Who will be reimbursed for the processing/handling of
these?
-
Higher unit costs in rural jurisdictions.
The unit costs associated with the collection/receipt of materials from individual users, on-site material processing, equipment sorting, packaging, storage, and eventual transport to a designated recycling center - a
location that will quite likely be distant from the rural county wherein the waste was
generated - are disproportionately higher in rural counties. Low population densities invariably lead to higher collection costs; the limited economy of scale means higher processing, handling, and transportation costs; and, long distances and limited access to recyclers means higher transportation costs.
(RCRC)
- At the Electronic Waste Stakeholder Workshop, a per-pound funding program was suggested. If a “per” unit/pound payment mechanism is developed, due to the higher per unit costs, it will be necessary to establish higher rates in rural areas to cover actual cost. Or, if a per capita payment program is adopted, a minimum amount for rural jurisdictions is suggested, as has been done in other state funded programs.
(RCRC)
-
Timing of authorized collector payments
. As previously stated, some of our member counties currently charge fees for e-waste disposal. There is no implementation date specified in the Act as to when payments to “authorized collectors” will begin. It is also unclear when local agencies will no longer be able to charge fees. In order to avoid suspension of any ongoing programs or financially compromising these agencies, we would like to suggest the regulations make these two activities/dates coterminous; local agencies should be able to continue charging their fees until such time the payments actually begin and are sufficient to cover all associated local government costs.
(RCRC)
-
Funding for stockpile reduction
and illegal e-waste disposal programs. Many of our counties host one day “events” to encourage the disposal of stockpiled electronic waste. These events have proven to be a successful tool to encourage the disposal of stockpiled e-waste, but also incur additional costs for operation. Furthermore, many of our counties have vast amounts of public land that are subjected to illegal waste disposal. The ESJPA would like to ensure that the regulations provide funding to local jurisdictions to properly handle stockpiled materials and to maintain e-waste disposal clean up programs.
(RCRC)
- CIWMB and DTSC has the ability to request detailed recycling information through its invoice authority given in SB 20 in 42479 (a)
Require recyclers to provide detailed (non-proprietary) information on the processing methods (crt to crt, lead smelting, or
hazardous waste disposal) used in their recycling of the devices that they are
invoicing for payment. And please make this info available on
the Boards website such that the public may use the info to select
services that match the recycling preferences desired.
- Reimburse on a per pound basis instead of trying to do it per unit. It will
be very burdensome to count the number of monitors. It would be much easier
to weigh the loads and submit weight tickets.
- The collectors would contract with a Certified Recycler based on their
performance and cost to process the collected materials. Recyclers would
charge the authorized collectors for their services and give the collectors
a receipt that they receive a certain number of pounds of listed materials.
The authorized collector would submit weight receipt to the Waste Board for
reimbursement based on the number of pounds processed. Having this system of certification of the parties involved would lower the
chance of fraud and misuse of the fees. Attached is a flowchart
of this system.
- Comments submitted by Sonoma County
Waste Management Agency on developing a flexible payment schedule
include 10 Goals, a description of how money should flow (from the
state, to approved recyclers to collectors) and a discussion of how the
approach furthers the 10 goals presented.
- We currently charge $16 per CRT item and $16 up to 400 pounds for non-CRT equipment and small kitchen appliances. As a hypothetical situation, if the CIWMB and DTSC were to define covered electronic device to only include entire units containing CRTs and CRT devices, would we eligible to receive recycling payments only for those items defined as covered electronic devices? If so, then we assume that we would have to segregate the revenue that we received for the collection of non-CRT devices and small kitchen appliances from the CRTs and CRT devices. Is that assumption correct?
- All collectors should receive payments for collecting. Reject
proposals to limit collections to "systems" as was mentioned
at the meeting.
- Concerns that implementation will negatively affect rural
communities by not providing full compensation for the cost of
maintaining the legislated electronic waste collection and recycling
facilities.
- Without a payment system favorable to rural communities, or the
ability to charge additional fees for electronics recycling, local
government will be left with a mandated service that has not been
adequately funded.
- Give local governments the ability to charge additional fees to meet
any financial shortfalls, as well as an advance payment to cover initial
costs.
- We (local government) are looking toward using Household Hazardous
Waste (HHW) funding to assist in funding e-waste programs, and suggest
that HHW be the per capita base for SB 20 [payments]; giving each
jurisdiction a baseline for their e-waste collections.
- All units that are dismantled and recycled should be reimbursable at the established rate.
- I agree that those who collect the CRTs (or CEDs) will hold the responsibility
for appropriate dismantling and recycling of the units. Providing the funding to collectors will assure efficient, market driven services
throughout the process. Collectors are responsible for these local programs
now; help them keep these programs low-cost and convenient.
- Actual dismantling of the unit for recycling, not reuse, should be the
requirement to qualify for reimbursement.
- Dismantling can occur anywhere, but needs to be verified in some consistent and responsible manner. State standards that local jurisdictions
can point to in dealing with processors would be helpful.
- My concern is that the large recyclers can potentially squeeze out the traditional collectors and
refurbishers. They take only that which has value and charge us for the rest, or require the collector to hold on to equipment or delay taking equipment. Since the small collector does not have large warehouse facilities, the commodity must be sold at a discounted rate or, [the recycler] charges the collector a fee to accept the equipment. This can be a serious problem in areas where there are few recyclers or where recyclers do not want to split the payments. To prevent this potential problem [I suggest] adding wording such as: "A Authorized Recycler is required to accept any and all product from a Authorized Collector in a timely manner."
- Is an approved CRT glass crusher in the state of California automatically authorized as a recycler under the new SB20 bill?
- The recycler should be prepared to take all monitors and T.V. sets at a pre-established rate from the collector as there can only be an upside in value to the dismantling and CRT crushing, therefore the collector gets paid by the recycler even if the recycler chooses not to process.
- Last year we handled about 3,500 CRTs. At 60 pounds each, that would be 210,000 pounds. If you pay out $0.30 per pound to recycle, $0.15 per pound to collect and $0.05 per pound to transport, that results in a cost of $105,000. San Luis Obispo County has about 250,000 residents out of about 35 million residents in California or about 0.71 % of the state total. Based on our cost of $105,000, a statewide cost to implement SB 20 would be about $15 million per year. This is significantly less than the $60 to $80 million estimate provided by the CIWMB. This supports my recommendation to fully fund the recycling, collection and transport costs.
- As an authorized collector, the City has real concerns about the $0.20 per pound fee paid to collectors. We want the total cost paid. We do not want to have to charge residents an additional fee after they have already paid a fee at purchase. The City feels the 20 - 28 is too low.
- Our principal concern is the higher unit cost in rural jurisdictions for the collection, handling, and transportation of the electronic waste to the recycler. An across-the-board per pound or per unit payment schedule does not address this issue. However, we understand that it may be necessary to begin this type of implementation initially in order to obtain the necessary data required to realize a more fair and accurate method in the future.
- There also needs to be recognition that, rural areas will need to continue to collect “supplemental” fees to cover the true cost of implementation until such time that total reimbursement is reached.
Every effort has been made to accurately reflect
stakeholder input. Please direct any corrections or additional comments in
alignment with guidance on the Stakeholder Input page.
Stakeholder Input Page |
SB 20 Home Page
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