Comments to Federal Register: Request for Information To Inform Interagency Working Group on Mining Regulations, Laws, and Permitting

 

Request for Information To Inform Interagency Working Group on Mining Regulations, Laws, and Permitting

https://www.federalregister.gov/documents/2022/07/15/2022-15114/request-for-information-to-inform-interagency-working-group-on-mining-regulations-laws-and

Secretary of the Interior Deb Haaland

It is critical to environmental public works, waste management, and recycling sectors in the Northeast, Midwest and West Coasts that federal lands in the interior west be managed in a way that levels the playing field. For too long our Congresspeople have failed to recognize that subsidies and lack of management of mining, fracking, and timber management on federal lands have direct consequences on recycling programs for metal, glass, plastic and paperstock.

After 150 years, the critical need to reform the Mining Law of 1872 is well documented. As professional recyclers from states without federal mining, fracking, and extraction, it is essential that we convey the importance of mining reform to the investment, job creation, economic realization, and sustainable economy.

When recyclers in cities like Boston, Albany, Baltimore, Burlington, etc. pay people to collect secondary raw materials from urban, suburban and rural waste:

1. We must pay for the value of the material, unlike “royalties” unpaid by virgin material harvests
2. We must pay for the cleanup of sites when we are finished with our recycling work
3. We are responsible for waste effluent and byproducts

Unfortunately, even as we recyclers provide 40% of all of the metals, paper fiber, and plastic used by USA industry, we must compete - unfairly - against wanton waste, crude processing, toxic tailings, and environmental injustice for the “backyards” of indigenous Americans, whose “NIMBY” interests are never paid as much attention to as the urban neighborhoods of our recycling enterprises. Our recycling programs provide raw materials at a fraction of the energy and carbon costs of virgin material extraction. Our children's children will appreciate every ton we conserve by leaving in the federal lands to be used, sparingly, to meet future needs.

Every time serious reforms of the mining laws in North America (by Udall and Bumpers in the 1980s, or Canada in the 1990s) are even discussed or threatened with a committee vote, the free market invests in recycling. Since this committee started its consideration, two of the largest investments in electronics recycling were made by the raw material smelting industry.

As the front-line regulators, investors, workers, and consumers of “Urban Ore” recycling programs, we urge you to recognize and defend our interests in a level playing field and circular economy.

Robin Ingenthron

Founder, Fair Trade Recycling (tradename of WR3a.org)