Vermont: Our exports in 2010 and 2009 were 22% (both years). Last year was 15%... the second half of the year saw reuse rates fall through the floor... as predicted in our testimony for S.77 to Vermont's legislature two years ago.
Part of the cause is the apparent declining demand (price) of reuse product, which I've described recently. It's actually a steady demand, but a supply imbalance from rapidly emerging markets who are now switching from CRTs to LCDs themselves (seeing used Chinese CRT TVs in South America, omg)...
As the price of reuse commodities fall, resources to defend or maintain our markets are limited. Competition from Steward-Shredders in the USA, and competition from Chinese used supply, makes this seem like a losing battle.
Vermont's legislature defined "local reuse" to be restricted (to keep OEMs from having to pay for the same TV, over and over again). But then ANR defined "local" as "USA" (Honolulu is local to Middlebury, by Vermont statute). Ok, we then removed any reuse from the program to make sure it wasn't charged and was outside the program. As of now, ANR has said even that is NOT ok, and material that we didn't charge to the program is sitting in a legal limbo, collecting in boxes in the plant... or more often we just recycle it and tear it down. We buy product for the reuse markets out of state - the 16% includes material brokered from other states into export-for-reuse markets.
Economically, it's rather short-witted for Americans to take a billion dollars of assets and ban them from reuse. It makes recycling more expensive, makes for a criminal's "sellers market" for the remaining reuse, forces export markets to buy loads which are of lesser quality, or to source their loads from Shanghai, Seoul, and Kuala Lumpur.
There. It's not my first attempt to make the case without mentioning you know who, but no one could describe this as an ad hominem attack. I hope one of the experts in favor of "no intact unit" will post a comment explaining why my analysis is wrong, and why even 15% export for reuse is too high.
As a former regulator, I know the risk-averse standards in the state and federal bureaucracy. As a regulator, you don't make or lose more money commission on your legal interpretations. Your currency becomes praise and criticism.
You don't like to be criticized. You avoid blame. So if the Watchdogs are the most visible dishers of blame, setting a standard which eliminates reuse just seems "prudent". That was the lesson from CA SB20, where not a single regulator could explain why CRT glass could be exported when it was BROKEN but not exported when it was INTACT (effectively mandating "cancellation"). Here it plays out again, in Vermont... and the stakes to defend the market are declining as competition from other nations supplying their own e-waste grows.
The game is planned obsolescence, gray markets, raw material resource subsidy, patent wars, regulatory standards, hard drive destruction laws, software obsolescence, shifting burdens of proof, non-tariff barriers, warranty law... I know of underhanded games played by the reuse markets in response. To a legitimate, open minded researcher, I'll share the black-hat methods used by the reuse and export markets to stay alive. But in the big picture, it's really like any other prohibition - when you try to enforce a law that is at odds with the marketplace, you are taking a big risk, and putting that risk into the hands of society's most risk-averse managers.
And toxics has nothing to do with it. It's just a cognitive risk played on the battlefield for earth's good enough markets.
Part of the cause is the apparent declining demand (price) of reuse product, which I've described recently. It's actually a steady demand, but a supply imbalance from rapidly emerging markets who are now switching from CRTs to LCDs themselves (seeing used Chinese CRT TVs in South America, omg)...
As the price of reuse commodities fall, resources to defend or maintain our markets are limited. Competition from Steward-Shredders in the USA, and competition from Chinese used supply, makes this seem like a losing battle.
Vermont's legislature defined "local reuse" to be restricted (to keep OEMs from having to pay for the same TV, over and over again). But then ANR defined "local" as "USA" (Honolulu is local to Middlebury, by Vermont statute). Ok, we then removed any reuse from the program to make sure it wasn't charged and was outside the program. As of now, ANR has said even that is NOT ok, and material that we didn't charge to the program is sitting in a legal limbo, collecting in boxes in the plant... or more often we just recycle it and tear it down. We buy product for the reuse markets out of state - the 16% includes material brokered from other states into export-for-reuse markets.
Economically, it's rather short-witted for Americans to take a billion dollars of assets and ban them from reuse. It makes recycling more expensive, makes for a criminal's "sellers market" for the remaining reuse, forces export markets to buy loads which are of lesser quality, or to source their loads from Shanghai, Seoul, and Kuala Lumpur.
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| 15 year old e-waste, GENERATED in Lima, picked up by an urban collector |
As a former regulator, I know the risk-averse standards in the state and federal bureaucracy. As a regulator, you don't make or lose more money commission on your legal interpretations. Your currency becomes praise and criticism.
You don't like to be criticized. You avoid blame. So if the Watchdogs are the most visible dishers of blame, setting a standard which eliminates reuse just seems "prudent". That was the lesson from CA SB20, where not a single regulator could explain why CRT glass could be exported when it was BROKEN but not exported when it was INTACT (effectively mandating "cancellation"). Here it plays out again, in Vermont... and the stakes to defend the market are declining as competition from other nations supplying their own e-waste grows.
The game is planned obsolescence, gray markets, raw material resource subsidy, patent wars, regulatory standards, hard drive destruction laws, software obsolescence, shifting burdens of proof, non-tariff barriers, warranty law... I know of underhanded games played by the reuse markets in response. To a legitimate, open minded researcher, I'll share the black-hat methods used by the reuse and export markets to stay alive. But in the big picture, it's really like any other prohibition - when you try to enforce a law that is at odds with the marketplace, you are taking a big risk, and putting that risk into the hands of society's most risk-averse managers.
And toxics has nothing to do with it. It's just a cognitive risk played on the battlefield for earth's good enough markets.
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