Showing posts with label regulation. Show all posts
Showing posts with label regulation. Show all posts

Einstein's Amygdala Part 3: The Predatory Business of Labelling Competitors as Predators

To reiterate the below-the-fold conclusion of Part 2:

Today, in most of the world, the highest risks to our health are affluence-related.

Over-eating. Driving cars too fast. Ingesting newly developed drugs. New inventions like handguns. But as compared to the highest risk of death a mere fractional 200 years ago, the biggest risk today is having lived twice as long as the average human 1% of evolution ago. The entire list of these affluence-related risks and outside risks today is a lower risk than faced by 30 year olds, centuries (seconds in evolution relativity) ago.

Einstein's theory of relativity places the fully formed amygdala in a perspective setting, similar to the relative speeds of sounds from trains, speed of light, all the great Einstein thought experiments explaining relativity. 

The press and social media constantly portray business and trade as if it takes place between predatory cats and baby rabbits. And it is natural for humans to give equal weight to every new fear.



Photo by me 2021. Lots of people photograph this cat in San Juan. Some of my
own photos over the years have been flagged by Google as unattributed, fodder for
another blog someday



WasteDive Asks: Are Solar Panels the Next CRT Recycling Problem?

 Our small Vermont company gets 2 big stories in July.

First, Recycling International is publishing a 2 page interview with Yours Truly, whose small Vermont Recycling Company has catapulted to #36 on the Magazine's list of Notable Recyclers worldwide (and that's not just "e-waste").

Do we belong on a list that includes Robin Weiner of ISRI at #15, or author Adam Minter at #6?

My only explanation is ironic - compared to similar lists a decade ago, Recycling International now realizes there are hundreds of well-managed recycling companies in places like Ghana, India, China, Pakistan, Indonesia, Singapore.  After reading their interview of me, I realized the irony that a) thanks to us (and this blog), the list is much harder for a white American to get onto, and b) we are deliciously placed several rows above Basel Action Network (screenshot below), which tried to get me labelled as a pariah after being called out for profiling Joe "Hurricane" Benson as a "primitive recycler" (rather than a 25 year expert at reuse export) based on his nationality.


But before I "bury" the lead about solar panel recycling ---  it's been my honor to put together an esteemed panel on how Solar Panel Reuse in Emerging Markets may offer the same solutions as it offered SVGA computer monitors 20 years ago... Register at NERC.org for a front row on Zoom, as I participate with Emmanual Nyalete of Ghana, Lennart Banaszak of Germany, and Good Point Recycling's very own Solar Nerd Trevor de Young (who's trailer home is almost completely "off grid" with salvaged solar panels - including some deliberately smashed by the solar de-installers in an botched "end of life" crime).

(see hammer marks, which rendered this panel 50% efficient. If it is relocated to Ghana, the 50% efficient panel will produce more KWH - due to abundant sunlight - than it produced in Vermont before it was "sabotaged" to prevent reuse).

Katie Pyzyk's interview in WasteDive explores our pilot program for solar panel reuse... and finds parallels to the CRT Reuse concerns that resulted in California SB20 and piles of shredded leaded CRT cullet across the West.

CRT Glass Resolution: An "Own Goal" In Slow-Mo

The path of least resistance is to trust our environmental regulators, trust the watchdogs, and assume that profit-driven industry is the villain, the fox in the henhouse.

The path of least resistance is to assume that people questioning environmental enforcement are "apologists" who care less about environmental pollution than the enforcement proponents.

Sometimes those assumptions are 100% right.  I'm not a carbon climate causality denier, and I'm proud of my 9 years of service as a Massachusetts recycling regulator.


But as a former regulator, I can attest regulators are not always right.  Regulatory agency lawyers tend to be more risk-averse than private sector attorneys, for example.  Regulators understandably want to hold themselves to "the highest environmental standard".  But when there is doubt and uncertainty - an engineering problem for example - the regulator can become obfuscated and defend his own reputation.  That is to say, when in doubt, the regulator has to act - in doubt.  And saying "yes" or "no" sometimes boils down to the regulator's own insecurities.

And these lead to unintended consequences.  #OwnGoal

Let me again state that what the agencies do, for the most part, is great.  I'm suggesting an environmental police chief should look at community concerns the way any police chief looks at protest.  You can stonewall and deny mistakes, claim 100% effectiveness in your policy.  Or you can learn from a mistake and adjust your policy.

Where are We on the Ethics Spectrum? 6 Degrees of Environmentalism

What's the purpose of this blog?  I often meet people who share the interest in ethical exports and electronics recycling, and we exchange information, each developing deeper knowledge through the relationships.

But the blog is also a journal.  It can capture my own thinking about a "big story".

And "e-waste" is really not a big story at all.  It's a fairly small part of recycling,  Recycling is really important because it avoids mining and preserves added value.  It's really rude to future generations to burn up limited fossil fuels, warm the planet, and then throw away the metal and plastics and do it over again.  It's really rude to tell a generation of Africans starving for Mass Communications / teledensity that they should buy brand new stuff most cannot afford because our sense of liability - an ethical luxury - comes first.

Throughout the blog there are facts that I share with academics and researchers and policy makers, and then there are places where I get angry and vent - as I'd do in a journal.  What is most important are the big perspectives which I can only comprehend a bite at a time.

Recycling policy becomes a lens to view ethics in a way that observes cross-cultural and economic interest's "spin" on those ethics.

Ethics really have to be understood as coming from a source of good, a right and wrong, poles.  It's possible that the most cynical view of ethics - that it's all evolved psychology and genetic nurture and greed - is true.  We have to be willing to consider it.  But I think an evolved, polished, enlightened Ethics which takes into account evolution and psychology and enlightened self interest is a thing of beauty, a work of art, and a gift to future generations.

Another long intro leads us here: My outline of self interest in international ethics.

[thanks to virtual pal Rafa Font of Belgium for sharing the article by Courtney Martin, The Reductive Seduction of Other Peoples Problems]

1.  The Ethics Illiterate

We tend to call people "evil" in literature, but most of the evil I see in the world is more of an ethical blindness.  People who really just care about something else, about themselves, about money, about pleasure.

There are people who would eat 1,000 endangered species tongues on toast and throw the rest away just for the sense of privilege, power and luxury (and even if cheese tasted better).  But in my experience, assholes aren't really thinking about ethical questions.  They would as soon burn a phone book as a Bible.

The worst problems in the world aren't created by Marvel Comics evil people, but by those who are mostly illiterate in ethics, and don't know how to feel good about sustainability.  The action is evil, the murder is evil.  What's in the evil mind is a waste.

2.  The Ethics Superficial

There are many people who have a general awareness of ethics and are on the right side, they think.  But while they may be literate in right and wrong, they don't really read novels, if you get my drift.

The morality is often a currency which they see has a social value.

They want to be friends with people who are ethical (which is really smart), and they follow the opinions of the tribes they find themselves in.

The Ethical Superficials may evolve into more professional ethics agents, or they may be satisfied to see themselves as ethically superior to Ethical Illiterates, earning an internal "moral currency" for having expressed "politically correct" or "religiously correct" views.







E-Waste Tragedy 7: Logical Fallacy ("Something Must Be Done")


Staying on subject.  What lessons can the Environmental Activist Community learn from the "E-Waste Tragedy?"  Does Joseph "Hurricane" Benson belong in prison?  If not, how the heck did he get there, and how do we keep from making the same kind of mistake again?

Turns out, the ancient Greeks had this nailed many centuries ago.

In Orlando, at the E-Scrap 2014 Conference, I actually had a chance to speak to several people on all sides of the "Guidelines" issue.   Most, including Jim Puckett, said of course Joe Benson does not belong in prison.

The person from StEP (Jaco) mostly defended the prison sentence for Benson.  Jaco acknowledged the probability that 91% of Benson's sold good were actually reused, and acknowledged that most of the stuff filmed at the dump was "Post-Reuse", and generated by Ghanaians.   Nevertheless Jaco made the case that "rules are rules".   If the Guidelines "suggest proof of full functionality", that Benson should have known the consequences of his export activity, even if those Guidelines were based on eroneous (BAN.org) claims.  Even if Benson knew they were being reused, and new he was bringing rejects back for free recycling in the UK, prison was warranted.

(Did you notice the term "Guidelines suggest proof is needed"? How about proving the suggestion is warranted?)

Throughout these conversations, we observe the "Appeal to Desperation".

SOMETHING MUST BE DONE.  
X (GUIDELINE) IS SOMETHING. 
THEREFORE, X MUST BE DONE.

This logical "appeal to desperation" has also been labeled the Politician's Fallacy, and often results in prohibitions, war on drugs, 10 foot fences to foil 9 foot ladders, and many "industry self regulation" standards.  There is a lot of money in providing "Something".

Having studied this for a couple of decades, I'm basically hardening in my position.   Even Mr. Puckett actually offered to sign the petition, and said of course Benson should be released.

Facts and Strategy in Recycling Business: Part II

In part 1, we focused on common experiences in curbside recycling of newspapers, plastic jugs, glass bottles, and metals from households.   In each case, labor or machinery is used to separate the mass of materials into commodities, graded to different quality for different end market tolerances.  The commodities are collected, transported and sold around the world.

2.  Differences between E-Scrap recycling and household curbside recycling.

2.1  Labor:   If all the printers, computers, televisions, cell phones etc. came to a Materials Recovery Facility or MRF with the pieces disassembled, you could really run it down the same recycling sorting line that manages the bottles, cans and paper from households.  This highlights the first key difference.  A television weighs about 100 pounds.   It's different than 100 pounds of cereal boxes, magazines, wine bottles, detergent bottles, and olive cans.  Those can be separated by 4 people, spread out on a Mayfran belt.  The TV has to sit in front of one person, who must remove up to 50 metal screws.  Even the raw materials are different - the circuit board is a composite of several different metals and fiberglass, much more complex than a TetraPak composite drink box.  And the glass has steel mask, phosphorous powders, and even lead (pb) vitrified (melted and mixed with) the silica in the glass itself.

The process of putting one TV in front of one person (capable of maneuvering 100 pounds) and disassembling it into 100 pounds of screws, copper, plastic, aluminum, glass, etc. is much slower and much more difficult.   This is the first difference.

2.2  Reuse Sales:   The second is that there's little possibility, effectually zero, that the 100 pounds of commingled curbside material can be reused, fixed, or resold at any value.  But in a wealthy country, people are anxious to buy the newest, flattest appliance.  Putting the old unit into a spare bedroom used to be the way we justified the replacement cost, but that's long exhausted its potential.  It's cheaper now to pay $10 to recycle a TV than to run a $25 classified add to sell the TV for $10.

2.3  Regulation:  While both curbside recycling and electronics recycling beat the pants off of raw material mining when it comes to risks, both have NIMBY forces against them.  The neighbors in the forests complain less.   Since property value drives environmental regulatory enforcement, and recycling tends to be close to people (generators), recycling of either type is more regulated.

But the recycling of electronics, or "e-waste", is far more regulated.

And it occurs to me that I've written about that so much that I'll just end this.  I have more interesting things to say about slums in Ireland.


Trouble with Stewardship III


Regulatory Progress?  Or Regulatory Digression?

...And I'm here to help.
Were "E-Waste" Stewardship laws, as passed in over 20 states, an improvement over the Massachusetts Waste Ban approach?

The diversion rates don't say so. (Disclosure - the 1999 MA DEP regulation was my contribution - the first state with a CRT recycling law, always omitted from the list of states by NCER and other Stewardship advocates).  Did anyone actually follow to see whether the Massachusetts' treatment was bad for the patient?   Keep It Simple, Stewards?

If the movement for Product Stewardship is legit, and mature, it won't take these questions as an "attack".  It's important for technocrats to distinguish themselves from watchdogs.  They are not the same thing.

The new Stewardship laws are more complex, perhaps more sophisticated.   Regulators calculate what "shares" of electronics recycling responsibility to assign to different manufacturers.  They invent "diversion targets" that the manufacturers must either meet, or pay a penalty.