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)

Vermont E-Waste Recycler Accused of Burying Hunter Biden Hard Drive in CEO's Front Yard

 [April 1, Middlebury, Vermont]

Early on April first, Drones from the Vermont Agency of Natural Resources - in constant surveillance of Good Point Recycling - provided shocking photos of the largest e-waste dump in the United States.

Focus material - data - was being landfilled, and on the CEO's own personal property.

"Honest, we just thought we were digging up collapsed orangeburg sewer pipe," said the Bristol Vermont excavating company owner, Steve.

But when the pipe was replaced, in a ten foot deep excavation, the excavator saw Ingenthron place a hard drive, floppy disk, zip drive, and a letter and post it note in the deepest part of the sewage-rinsed  yard hole.  They were placed carefully, with double zip-locked bags for protection.

"Dumping e-waste," said ANR staffer Karen Krabapple, who pilots the drones from her home during pandemic lockdown, "is a crime in Vermont."

Help Us Define "Waste Colonialism": Talking Secondhand

Looking for University Research to Help Us Define "Waste Colonialism"...

Robin I

@WR3A

·

2m

Actively seeking university researchers interested in "waste colonialism", or the use of apparently environmentally minded rules to serve planned obsolescence and protectionism. #wastecolonialism #freejoebenson #fairtraderecycling

"Waste Colonialism" comes up in the final chapters of Adam Minter's new bestseller "Secondhand: Travels in the New Global Garage Sale".  Adam kicked off his book tour at the University of Vermont, in part to thank my company and our global partners for "dropping our drawers" and giving him access to secrets of the trade.

In fact, the next to last chapter is titled "A Rich Person's Broken Thing". That is drawn directly from conversations I had with my Ozarks grandparents, both on the farm as a child, and in long talks with them after I returned from the Peace Corps in Cameroon, Africa (June 1984-December 1986). Adam captured my grandpa Clarence Fisher's anecdotes about when automobiles first came to the Ozarks (his own father had a horse and wagon, and signed his name with an "X"). As many family members were leaving the Ozarks during the Great Depression (along the "Hillbilly Highway"), his older brother, he said, got into the used automobile business. He explained that no one they knew could afford a new car (and the unpaved roads would be heck on them anyway). Used cars were affordable... but his brother's method was to go to St. Louis, Memphis, or Chicago and listen for sounds a car was making when it had broken down or was about to. If you knew what went wrong with a car, what the sound that problem makes, and how to fix it, you could buy the "rich man's broken thing" for a lot less. They'd bring it down to Cedar Valley, fix the car, and flip it for the price of a working used car.

I explained to my grandparents how I'd seen Africans doing that exact same thing. And Adam not only put it in the book, but recounts the tale of Joseph "Hurricane" Benson of BJ Electronics in England, who was sentenced to prison for buying used hotel CRT TVs and selling them to Africa.

Adam shows the wisdom of the African traders, and accepted my challenge, which was to ask why do rich countries (and in particular white people, because Japan and South Korea don't do this) create "rules" by which Africans can buy secondhand equipment?  And when the UK House of Commons reported that the African exports needed to stop - not to "save" the Africans from pollution, but to retain "strategic minerals and metals" for European industry - why did no one from that House of Commons think it worthy to write the UK Barrister who was recommending Joe Benson be prosecuted?

Adam's answer is "waste colonialism". He doesn't use "racism" the way I have in the blog, but he certainly calls out the bigotry involved in confusing (sometimes deliberately) the secondhand (and "thirdhand") Tech Sector with the unschooled wire burners of the scrap sector.

As I said when apologized to 7 years ago, the apology from Basel Action Network should not be made to me, but to the Africans, Asians and LatinX whom the NGO has been racially profiling as "primitives".

Ethical Gravity 4: Moral Moving Targets, Beautiful Gray Markets

Is an "illegal" market, or a "black market", unethical?

It is illegal to sell the Holy Bible in many nations, but who would consider it unethical?  It is important to distinguish ethics from laws passed by authorities to grant - well, more and more authority.

Beautiful, beautiful gray.

Vermont Press Release - Firsthand accounts of SECONDHAND, By Adam Minter

MEET AUTHOR ADAM MINTER IN BURLINGTON, VERMONT

November 14, 2:30PM, UVM Davis Center

On November 14 (America Recycles Day Eve), the University of Vermont Recycling staff will greet best-selling author Adam Minter at the Davis Center (590 Main Street) as he speaks about his new book SECONDHAND, Travels in the Global Garage Sale.

Minter chose Vermont as a launching point (to the surprise of his publisher, Bloomsbury Press) to thank Vermont for hosting him at the Fair Trade Recycling Summit (2013), where he met several of the fascinating people he profiles in Secondhand.

According to UVM Recycling Director Corey Berman, and Middlebury recycler Robin Ingenthron, Vermont's emphasis on reuse is something that Adam saw, firsthand, put to good use in Secondhand.

"Downsizing. Decluttering. A parent's death. Sooner or later, all of us are faced with things we no longer need or want. But when we drop our old clothes and other items off at a local donation center, where do they go? Sometimes across the country—or even halfway across the world—to people and places who find value in what we leave behind."

Secondhand takes readers on a globetrotting journey to see how items saved or discarded, donated or sold by Americans make their way into reuse, repair or remanufacturing processes. In Vermont's example, he followed a load of computers from Middlebury to Ghana, and interviewed the "tech sector" importers who provided Ghana's information grid with affordable electronics. Minter also treks to Japan, India, Mexico, and other "reuse trade routes", and winds up with important questions about how important our stuff really is, and who should write the rules about it.

Date: Thursday, November 14, 2019
Location: Sugar Maple Ballroom – Davis Center (Address is 590 Main St.)
Time: 2:30 pm – 4:30 pm.

It Was 20 Years Ago Today: Good Point Recycling's Eco-Entrepreneurism

Just ran across this photo from 15 years ago (just before we bought the Nissan forklift), at the warehouse across from Agway on Exchange St. The monitors were selling for $7 apiece back then.  Pretty much all we did was to do pickups, pull out the PCs and CRT monitors we could reuse, and load everything mixed back onto a trailer.

5 years earlier, I had announced my resignation at Massachusetts DEP to follow my wife to Middlebury, Vermont, where I'd taken a job running a thrift store while doing consulting work for EPA, MA DEP, New Deal Software, etc.

It was 20 years ago that I took a big chance and left my corner office at One Winter Street in Boston, having successfully instituted the USA's first waste disposal ban on CRT devices in Massachusetts. The consulting work I did for MA DEP and EPA was published in September 2000, about a year after I turned it in. Titled Electronics Re-Use and Recycling Infrastructure Development in Massachusetts, it eventually became the business plan for Good Point Recycling. 

The report was based on interviews with 48 electronic recycling professionals, 176 TV repair shops, 4 white goods (fridges) appliance collectors, 10 thrift shop operations (Goodwill, Salvation Army, etc), 2 retailers, 20 computer monitor repair shops, 7 Original Equipment Manufacturer reps (not credited or cited), and 32 used electronic equipment exporters.

Blogger V. Twitter - Recycling News Happens Fast [StormX]

There are two reasons why the number of Good Point Ideas blog posts has declined in the past 24 months.

The first relates to an increase in use of Twitter. As I noted 5 years ago, Twitter is misunderstood as a "squawking box". Sure, there's lots of inane squawking on Twitter. But the most important thing on the Twitter site is in the top right hand... the Search Box.

"Following" a thousand people is pretty impossible. I trim it down with a FairTradeRecycling list of twitter posters I follow more closely. But it is the "saved search term" feature that we need to pay attention to. It allows you to get an early scoop... and if it turns out to be clickbait, it's only 160 characters or whatever.

So ten years ago, the incredible idea below would have been subject of a blog, which would take me 45 minutes to write (and if readers are lucky, another hour to re-edit).  Now I post it bam on Twitter.

Storm Water Trash Catch Nets

I saw this on a repost from an old pal Wim Roskam on Facebook, who in turn found it on Architecture and Designs rather cool Facebook page.  The problem with stormwater carried litter is obvious if you've been to an African city like Accra, Lagos, Dakar or Douala.  The litter on the beaches is depressing and ubiquitous, and no amount of white savior plastic straw abstinence is going to save the sea creatures there.

STORMX is the license holder (image above is from North American licensee StormWaterSystems.com). The net baggies allow water to run through, but catch the debris... which is the actual culprit of urban flooding - falsely blamed on scrappers of Agbogbloshie 40 months ago. 2015 was the same year that Twitter helped a youtube video of a turtle with a straw stuck in its nose go viral... which led to a LOT of journalist ink going into the plastic straw bans.

Panel Discussion - How to Address 4 Weaknesses as a Business Owner

In a couple of hours, I will be sitting on a panel at the 2018 Electronics Reuse Conference. Topic - How to Address Weaknesses as a Business Owner - was the first to tempt me for 5 years.

Good Point Recycling opened in April 2001.  I bought a used truck with a $15k bathroom improvement budget, and didn't hire the first full time employee for 3 years. The first 3 years, I was mostly doing consulting gigs between truck runs. If your weakness is "talking too much", charge by the hour.

I used to speak at conferences pretty often 20 years ago, 15, 10 years ago. But one of the weaknesses I found that we all have is this - speaking to your peers, to other businesspeople, to competitors, etc, sucks. We are all weak when our audience consists of people who know or think they know as much as we do. If they agree, then they sat in a session to hear the obvious. If they disagree, "A man convinced against his will is of the same opinion still."  Generally, don't do it. I generally try to refer invitations to WR3A to Tech Sector people from Mexico, Ghana, Malaysia, etc, who really can tell an American audience something they don't know.

This topic, however, is about weaknesses. About addressing my own weaknesses. So I accepted. It should be an opportunity to self-deprecate and tell some funny stories about near-death experiences.
I'll start by acknowledging my survival. We will have a moment of silence for some late, great, fates.  In alphabetical order, here is a list of companies which I'm pretty sure were at one point part of the 10 largest electronics recyclers in the world (or claimed to so be).

Allied - 2006
DMC - 2006
HMR - 2006
Creative - 2014
CRTR - 2015
Eco International - 2013
EWSI / 2TRG / CLRR - 2016
Intercon Solutions - 2013
MPC - 2015
WeRecycle - 2015

OP ED: GPS Tracker Controversy Resurfaces #Monitour

Just a brief update about the 2016 reports (2) by Basel Action Network which claimed that their partnership with MIT Senseable City Lab demonstrated that 36% of USA E-waste is illegally -  and shamefully - exported.  When the first report came out, one year ago, we contacted MIT to question the following methodological concerns in the study.  MIT sent a disavowal and stopped appearing with BAN in the press, but the damage has been done.  BAN unmasked unwitting and unwilling participants and named names - even companies like mine that they know for a fact did not export the device they shipped to us.  Where there's smoke, someone should get fired.

1) 50% of waste - CRT TVs - were not tracked.  Probably because they are almost never exported. If they are never exported, the exported "findings" fall back into the 10%-20% range identified in several other studies.  It's the "blue-eyed basketball player fallacy" (selective sampling).  They tracked 30% of types of devices deemed likely exports, and found 36% of those were exported.

2) BAN covered up destinations which didn't fit their "primitive and shameful" narrative of overseas recycling.  Here is video from April '15, six months before our downstream USA recycler exported a printer we handled, of Hong Kong's legal EcoPark.  We found direct evidence that BAN erased the coordinates for this facility, and shared that on the blog and with MIT.



3) BAN misidentified legal repair and reuse as shameful exporting.  Two CRTs tracked in Pakistan ended up in a multi-story reuse shop a couple of blocks from Pakistan's largest tech university, in the same building that sells CRT analog converters (changing monitors to TVs).  Another data point that "disappeared" in BAN's second report appears to show a large SKD factory in Foshan.  If it isn't this factory, then why did BAN erase the datapoints in its second report?  In Fact, one of the SEATTLE devices exported (under investigation by Washington DEP) was in fact tracked through the site above, and is found in reuse in Tin Shui Wai (a city, not a rice paddy, in the New Territories).  BAN erased the datapoint, but it was shared with us by someone in Seattle, and we profiled the cover up here.

4) Whether or not the tampering and fallacies above were intentional, BAN's participation and funding and sharing data with E-Stewards who sponsor BAN financially are prima facia violations of MIT ethics rules on both conflict of interest and tracking of "unwitting and unwilling" human subjects.  If there was any question whether BAN was just following devices or was targeting unwitting and unwilling subjects in the first report release, that was released in the second, where BAN named me personally and my clients in Somerville, despite knowing that we did NOT export the device they tracked. Oh, and the Somerville site is a commercial office, not a public drop off point... MIT undergrads had to ring a doorbell and get buzzed in to a building with no "recycling" sign.  At that point, MIT assigned its attorneys to the case and MIT Senseable City Lab issued a disclaimer and stopped commenting publicly on BAN's allegations.

And remember, #2 EcoPark is a direct competitor of E-Steward donors!

5) We had direct tracking of exactly how much of our used electronics we qualify for direct or potential export.  It's under 10%.  We provided that information to MIT Senseable City Lab, who provided it to BAN before BAN issued the 2nd report ignoring that data.   The fact we could track that item without BAN's GPS was less interesting to us than the fact that an E-Steward who pays BAN handsomely cancelled our shipments of printer scrap for several weeks while the GPS tracker was in our building.  A source at MIT has privately confirmed the same suspicion, that BAN had active access to "live" devices and that it would have been simple to warn paying sponsors to avoid shipments containing the devices.

If anyone needed a track record for BAN's targeting of me personally, here is a reminder of a paid BAN staffer's characterization of me, personally, to a Chicago Patch reporter two years earlier, and BAN's public admission of the personal attack, and apology to me.

Whether funders like The Body Shop Foundation or researchers like Carlo Ratti of MIT Senseable City lab will ever partner with Basel Action Network again is an open question.   But they would be wise to track the history and reputation of the "watchdog" that barks at companies that don't pay them "certification fees" worth millions of dollars to stay silent, and to fund vicious racist attacks on innocent Tech Sector importers and exporters like "Hurricane" Joe Benson of the UK - the Tom Robinson of UK's witch hunt into fake news about Agbogbloshie distributed by BAN... falsehoods exposed by me months before BAN's report called me out in shameful light.

It's a shame that legitimate concerns exposed by the study can't now be pursued without airing false propaganda.   The fact our Massachusetts printer, sent to Chicago, didn't go to the place in Hong Kong described and approved (#2) and the reasons - legit or not - given to our downstream USA copy machine repair shop who exported it... all legitimate avenues to explore and learn from.  But those could have been pursued without "unmasking" the unwitting and unwilling participants, and without the 5 research fallacies described above.

I'm bringing this up because last week a Vermont Agency of Natural Resources staff person made a claim about my company and the GPS tracking which did not mention the legal R2 certified facilities in Hong Kong or EcoPark (video above), in defense of new Procedures which the Agency admits are directed at one company - mine.

Common Stereotypes - Defending and Embracing Working Roots

On vacation, at the Mediterranean.

When we went out for beer at the beach with a couple of my wife's cousins (people who were at our wedding here in southern France 26 years ago), I found myself trying to simplify my thoughts so that my French vocabulary would be less of a struggle.  My French isn't too bad "for an American truck driver".  But I admit I don't try as hard as I used to.  My wife and kids speak exclusively in French, but most of my vocabulary is now about reminding teenagers to clean up a mess in the kitchen.  It's not very philosophical stuff.

Anyway, when you're my age and you come to visit inlaws in France once a year, you wind up retelling and re-asking and re-recounting a lot of the same stuff anyway.  And one of the "small talk" topics is always whether I fit a stereotype of "American" based on the French news.

Fiddling with Product Stewardship (as E-Waste Burns)

Product Takeback/ Stewardship advocates and laws have manufactured a System for recycling #ewaste which requires maintenance and stewardship.  The ship of Product Stewardship is seaworthy, but it's headed for an iceberg if the advocates are just focused on the next legal product and don't take responsibility for the takeback laws they already created.

Check the List, Below, of TV recycling company closures and failures.

The "Product Stewardship" movement needs maintenance... or at least some fiddling with.

When devices go obsolete Stewardship advocates make manufacturers "fix the problem".  But what's good for the goose, is good for the gander, right?

Something is broken in E-Waste Stewardship.

As I testified and wrote 5 years ago, electronics reuse markets are so complicated (compared to mattresses, paint, and alkalines) that "e-waste" was probably NOT the best product for wiser Product Stewardship Advocates to start off with.   Now, the list of problems in the electronics recycling infrastructure in "ewaste stewardship" states is growing bigger.   Primum non nocere - "first do no harm" - needs attention.

But that's water under the bridge.  We have these state "takeback" laws now, and a command and control system of accounting for residential TV recycling.

Take a look out the window, my friends.

Here is a brief (and incomplete) list of CRT Recycling Companies which have left the residential TV and computer recycling markets in the Northeast, some permanently. The squeeze of NOT reusing (liabilities in contracts banning exports), and subsequent glutting of CRT glass end-markets (prices better for buyers), has driven up costs, but there's no way to send a Price Revision.  Meanwhile, in NY, NJ and PA in particular, some OEMs reportedly met their "obligations" and left these recyclers, and others, to "pound sand".

My company is still around in part because of our good fortune losing our largest contract - Oyster Bay in NY Long Island, which we lost in 2012.   The OEMs had said they met their goals, and we thank our lucky stars that a competitor talked Oyster Bay into dropping us as a vendor (that competitor is now on the "casualty list" below - focusing on commercial electronics and out of the residential stewardship game).

Others were not so lucky... The Northeast Product Stewardship map has some big holes to fill...

• 2TRG - Ohio Recycler that was part of EWSI Roll up.  EWSI failed to fulfill its financing obligations to Good Point Recycling after GPR invested significant accounting.
• Creative Recycling* - Major service provider on East Coast (including NY, CT, NJ, PA), one of our biggest competitors in NY.
• CRT Recycling (CRTR)* Brockton MA - was one of our largest competitors in MA and NH.
• Eco International NY/PA* - This site was one of the oldest and most respected CRT glass processors in the Northeast.  They reportedly left the largest (12k tons) pile of CRT glass during their bankruptcy.
• Ewaste Recyclers, LLC of Jaffrey, NH closed without finishing the recycling of CRTs they had accepted.
• EWSI Geneva NY -  See 2TRG.  They affected us not only by being a competitor without a sustainable economic plan, but triggered enforcement in NY raising the costs of recycling.
• MPC PA/MN* - One of our backup companies when we ran out of manufacturer obligation in NY, discovered with 2,500 tons unprocessed CRT glass in Philadelphia area.
• North Coast and Kuusakoski did not go out of the residential TV recycling business, but gave up even trying to pay for CRT glass recycling, creating a huge controversy with dumping CRT glass on municipal landfills as "daily wind cover".
• Sims Metal Recycling NY/NJ/Canada - Closed largest e-waste plants this year after $115M annual "write offs" for e-waste.
• StoneCastle - Not a Northeast player, but contacted Good Point to ship dozens of trailers of CRT glass in 2012, 2013 (to Retroworks de Mexico).  We did not execute the PO based on our credit review, but this would have taken us down with them.
• Waste Management Inc. closed its CRT dismantling facility in Springfield, Massachusetts, three years ago.
• WeRecycle* CT/NY - The company went through a brief bankruptcy (shortly after taking over VT one-day events), was purchased by Hugo Neu Recycling, and then withdrew from residential recycling contracts.  Had been one of the largest CED recyclers in CT, NY, MA, RI.

This is probably over 50% of New England CRT capacity, down in flames (figuratively or literally), since the passage of Product Stewardship Legislation in the Northeast.

Some of this is the scrap metal and plastic market - not anyone's fault.  But the largest recyclers in the list failed while scrap prices were at an all time high...

For the past 12 months, we've lost $250,000 just on scrap prices.  The "high" is over.

True, the Product Stewardship laws did create a booming supply, and brought expansion and investment to the industry.  But now, prices for scrap have crashed, and there appears to be little way for large, single-payer contracts like Vermont's to make adjustments.

And it's not just circuit/wiring board.  Steel scrap prices have crashed.  Copper scrap prices have crashed.  Plastic scrap prices have crashed. The price of circuit boards has gone through the floor, following the lowest gold prices since the recession.  As the USA dollar gets stronger, even reuse markets are shrinking.

Good Point continues to meet all of its obligations, paying what is necessary to recycle the CRT glass, at smelters and new CRT furnaces.  But we can't love a business that doesn't love us back.  The cost of Certification (mandatory in Vermont) keeps going up, and the state keeps increasing its insurance requirements.  We need to keep paying our staff a living wage, and that wage should be changing as the unemployment rates fall.

Time for some leadership.

Evolution of RERA #eWaste Legislation: Spinning H.R. 2791 Obsolescence

Lobbying for the RERA Bill, to bring EU style enforcement to bear on secondary market electronics, keeps shifting parameters.   Here's a blow by blow on why exports of used electronics should (or shouldn't) be banned.   The justifications for both RERA and Interpol enforcement seem to go "obsolete" every 18-24 months... Moore's Law for accusations?  

Summary: H.R.2791 — 113th Congress (2013-2014)

(Note, the dialogue is equally effective in summarizing INTERPOL's Project Eden enforcement)

"The legislation is necessary because 80% of USA e-scrap is exported and dumped.  It was necessary to arrest Joe Benson and more like him.".

- No, actually USITC and MIT show conclusively that most is not exported (otherwise why would we have all those CRT glass piles?)

"We meant, The legislation is necessary because of what IS exported, 75% is simply dumped and recycled in primitive conditions.   It was necessary to arrest Joe Benson and more like him."

- No, actually 85%-93% is reused, not dumped, according to multiple peer reviewed UN studies.

"Ahem.  Thanks to the attention we brought, and arrest of Joe Benson, the situation is greatly improved.  Legislation is needed to continue this improvement."

- No, the studies were on the containers seized during his arrest.  It was literally the accused containers that were found to be 85%-93% reused.  He didn't do what you said.

"While the 80% dumping was exaggerated, 9-15% dumping is still completely unacceptable.  Legislation is needed so Africa will leapfrog into new product..."

- No.  Actually, brand new product imported to Africa was found to fail more often than the used equipment, either due to lightweighting (less durable, cheaper components susceptible to Africa's electric grid fluctuations), or shipment of "new" ESD damaged warranty returns to Africa.

CRT Glass Recycling "Breakthrough" - Innovator Award Finalist

Great News!

After 5 years of trials at our sister company "Retroworks de Mexico" (see NPR Living on Earth, and MarketPlace), approval of the glass recycling system under EPA CRT Rule last year, and a $469,000 "Fair Trade Recycling" research grant with 3 universities to study the process, Good Point Recycling's CRT Glass management is in the news again.

This month we are being flown as a FINALIST to the National Recycling Innovators Forum in New Orleans, hosted by the national Resource Recycling Conference. This is a very prestigious national competition, which includes all types of recycling innovation (paper, glass, plastic, compost, you name it).  Our "Fundente Production Partnership" (FPP) proposal is recognized as a way for electronics recyclers across the nation to cooperatively share in this new market.  Basically, it supports the use of old TV CRT glass as leaded silicate to replace as a necessary ingredient in copper, zinc and gold smelting.  A single copper smelter we are working with in Mexico uses over 200 tons per day of leaded silicate "fundente" or fluxing agent, and copper smelters (like Phelps Dodge in Arizona) would also become end markets in replacing mined Angelsite, Feldspar, and other virgin leaded silicates for their smelting processes.

News about the Innovators Forum is here, the winning proposal submitted by Good Point Recycling of Middlebury, Vermont is described here (FPP).

 (Breakthrough, or "break, threw"?)

Africa Tech Taught Techie Stuff to Vermont: Now Georgia Tech Scholar

Emmanuel Eric Prempeh Nyaletey, the head Technician at Good Point Recycling, has been offered a scholarship at Georgia Tech to earn a degree in coding and programming.  He leaves Vermont with his wife in the coming days, his last day at work tomorrow.

2013 Good Point Recycling End Markets: 6 Percent Reuse

Good Point Recycling of Middlebury Vermont is now preparing our 1st Quarter Report and Annual 2013 Report for the Vermont Agency of Natural Resources.   Having just had these numbers audited under our R2 Solutions annual surveillance in March, we have more than enough data to demonstrate what kind of a company we are.

  2013 Outgoing Recycling:  Good Point Recycling

The most obvious change over the past 4 years was our decision to bring demanufacturing jobs in house, doing the television and monitor teardown here in Addison County.  Our payroll hit $26,000 per week, much of it in time-and-a-half (OT), and we hired more experienced people to do it.  So Red "CRT whole unit outsource" went down, and blue "Bare CRT tube glass", and associated plastic, went way up.

Something that surprises people is how little we export, and the reasons it has declined.  Good Point never exported more than 30% of the material, I think the peak (28%) was in during the years (2006-8) when we were buying and selling monitors from other companies, for refurbishing in Malaysia and redistribution in Egypt.

Why the decline?  Was it stricter EPA enforcement?  
Responsible Recyclers standards?  
Pressure from Basel Action Network?   
Strict Vermont E-Cycles Program standards?

No, none of these explains the fall from 28% export to 6%.  It's the marketplace.  And there's nothing ghoulish, witches brewy, noxious, or radioactive going on.  There's no Batman villian in the "e-waste" trade.  When the reuse market finds another source, no one wants to import it any more. It's scrap.  Metal and Plastic.  Recycling.  Boring.  Laundrymat scale boring.

Vermont Apple-to-Orange Software Validates CRT Recycling

(This is part of an April Fool's blog tradition, and I hope no one took it personally)

Small Northeast State Solves E-Waste Recycling Glut Profitably, with New Validation Procedures

[Middlebury, VT  April 1 2014]  It turns out there are two ways to solve the E-Waste Recycling Crisis.    In a stunning turn of developments, Vermont has validated a brand new way to recycle CRTs.


1.  Charge manufacturers more (42 cents per pound rather than 28)
2.  Demand less (allow land application)
3.  Profit!

Suppose there are two ways to do something.  One way takes a lot of labor hours, and then costs a lot to transport and treat the material.   The other way takes fewer hours of labor, but creates a mixed mess that is even more extremely expensive to transport and treat the material.  Normally, this is called "getting what you paid for".

But with an online thesaurus tool, Vermont "recyclers" are now "solving" this "e-waste" "problem".

Inequation disproved in 6 month study

"We were as stumped as the next state with the need to change our award winning state recycling program," said Vermont ANR Commissioner David Mears.   "But we made lemonade."

John Obfusca of Cali Waste Systems described the new development.  "One of our guys, at the end of the shift, just goes 'Hey, what if we just don't recycle it, but we call it something kinda alternativey?'  It turns out, you just have to name the process right to get it approved."

Diverting waste from a landfill into another landfill?  Land cover that fits the defination (per RFP) of "no land application"?   There's an app for that.

Mother Jones on Research In Cognitive Bias: and Vermont E-Waste?

"The Science of Why We Don't Believe Science"

"[Yale Pschology Research] undercuts the standard notion that the way to persuade people is via evidence and argument. In fact, head-on attempts to persuade can sometimes trigger a backfire effect, where people not only fail to change their minds when confronted with the facts—they may hold their wrong views more tenaciously than ever."

This is an excerpt from an article in Mother Jones, by correspondent Chris Mooney, who has been reading some of the same research on cognitive bias that I've been interested in for the past 4 years.   Neurological level research can detect brain stimuli which indicate a response (to risk) that acts faster than reason (also detected).   If an idea is a threat, either to a long held belief, or to ones self interest, brain radar can see it coming in a nanosecond.

What's a "convincing argument"?

This creates a real problem if your business is already in a bind.... outnumbered, overruled, the deck stacked against you.  Research indicates that "arguing convincingly" is an oxymoron.   If you are arguing with an entrenched authority who might be embarrassed by a reversal, you are statistically more likely to fail.  "You can't fight city hall..."

This is why the western legal system has evolved legal representation.  An attorney or lobbyist can be more skilled in making arguments indirectly, more nuanced, and avoid making the authority feel "risk impulses" which spell doom for the client. If the case has to be made, the legal counsel hopes the backlash befalls them, rather than the client.  It's also why we triangulate our justice system, with prosecutors, defenders, judge and jury.

People like John Adams, Ben Franklin, and Thomas Jefferson were anti-authority, and they were smart and argumentative and completely outgunned by the British monarchy.   The British Colonial game was rigged.  When the USA's founding fathers succeeded, the freshness of their experience led to a constitutional system which has made it less likely that an authority figure can run roughshod over a little guy.  We also have the fourth estate, journalism and free speech.

Letter to Vermont Legislators: Montpelier, we have a problem

3/26/2014 UPDATE:  For whatever reason ; )   since this was originally published, the Agency decided to issue the rebid.  I'd specifically asked the previous week.    The original post here has been re-edited to reflect the Agency's decision to rebid, though we noted the agency has inserted language to protect it from appeals.

There continues to be a lack of independent review of the Agency's bid process.  Hopefully they will have representation this time from the cities and towns and schools who actually receive the services.  When I was at Massachusetts DEP, the DPGS (procurement office) reviewed our bidding procedures, and appeals were considered part of the "checks and balances".  It remains to be seen how Vermont deals with the prospect of scandal.

After restating our request as a "FOIA", we got the state costs paid under the new contract for the first quarter.

Wait what?  Let's zoom in..

Cost per pound under the new state contract:  $0.42 (if you leave in the 10 days of the injunction, when Good Point charged 28 cents per pound).   Recall that ANR staff testified, under oath, in court, that the difference in cost was negligible, less than a penny per pound.

Attached is an open letter to the Vermont Legislators who are considering the 22 pages of red tape aimed a the Independent Plan, which would become statute (law) rather than a negotiated settlement once ratified.

Heavy Hey Yah Vermont (Teach Me Lies) #Ewaste

)

This is our song.  (Outcast)

Obadiah Parker (acoustic cover)

posted by Michael Schulte.  

Sounds truthful.  

but what about... teach me lies?  Nigeria's top video below.  Nigeria has Internet.

Motherload Blog Alert: Foreshadowing Karma

My next posting is nearly finished, and it's another college-thesis styled attempt to tie together several themes of this Good Point Recycling blog.

- Accidental Racism, Environmental Malpractice, Environmental Injustice
- Cognitive bias, psychological basis for the mis-prescriptions of justice and intolerance
- Facts, statistics, and environmental best practices
- Geographical and social development forces, from urbanization to 'state-hate'

I'm a little bit afraid to hit the "publish" button, I want to reread it again over the next two days.  But as a preview, here are two links, one to a CNN interview of Harvard bio-psychologist Steven Pinker, and the other to an amazing Singapore-based undergraduate's philosophical blog (pen name Laicite).

In the treatise, I confess to waging war on too many battlefronts, and the psychological toll it takes on our loyal clients, staff and supporters of Good Point Recycling.   I read an essay by Alexis de Tocqueville on the weekend, and will use the specifics of the Vermont "state-hate" phenomena to shed light on broader truths for the environmental movement.

The blog begins in Singapore, takes a random wander through Vermont "e-waste", touches Lord Chris Smith (UK Env Minister) and Interpol, and ends in Africa.  Environmentalists and bible belters, regulators and entrepreneurs, can all be excellent people, and still wind up wringing collateral damage out of distrust and shame.   The way out is an exercise in leadership, requiring both humility and certain direction.  We evolve to accept differences, to defuse state-hate, and wind up with fusions and Gangstagrass.  

If you don't want to read Steve Pinker, de Tocqueville, or Laicite, I'll assign the pilot episode of My Name Is Earl., something of a transition from the recent "cultural gulf" theme, a very humorous USA television program I just discovered a couple of months ago.

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