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)

Three Legged Journalism: Reporter + Source + Editor > Blogger

While on summer vacation at my parents place in rural Arkansas (Buffalo National River, the only river managed by the US Department of the Interior - please don't issue mining and fracking rights here), I have a chance to reflect on journalism, and my critiques of lopsided and inaccurate reporting over the years.

Talking with Mom on the apparent loudness of politics, and tribal journalism, and bias confirmation... We settled on risk analysis, and how so many people believe in conspiracy theories.

Around here in the Ozarks, the "deep state" conspiracy is admittedly popular. I was informed yesterday (indirectly from a confidential source) that a contractor lady for Mom - sweet gal, hard worker - informed her that the Republican staff and White House lawyers who testified to Representative Thompson and Cheney's January 6 Investigation committee were "paid" to testify against Trump.  By whom? Didn't get to ask.

Now I do know on firsthand that this can happen.  Conspiracies can definitely happen. But the rumors of conspiracy travel halfway around the world while the Truth is still waking up to a hangover.

"Going Out On a Limb" however is a lot easier for a blogger than it is for an institution. It is rare that a blogger like myself should be a better source than any of the journalism institutions or international agencies that gave Anane's wildfire story on illegal e-waste dumping the oxygen to burn people like Joe "Hurricane" Benson. So today I'll reflect on how rarely anti-conspiracy experts get it right.

The Lithium Rule: Do Unto The Others Yet To Be Born...

"Do Unto The Others Yet To Be Born As You Wish Your Ancesters Would Have Done For You"

I have finally gotten my motto. This is a philosophy I landed upon as a teenager - to see the world from the vantage point of future children I'll never meet.

Let's label this the "Lithium Rule"... Since if it isn't searchable, it hasn't been labelled as of yet. It helps that I misspelled "Ancestors", of course.

"Do unto the others yet to be born as you wish your ancestors would have done unto you"

Surely I'm not the first one to come up with this?  But Google suggests I may be the first to publish it online (which I'm quite aware isn't all 8 billion of us with that privilege... and also this is in English). I searched it both ways, done for you or done unto you... first dibs. It is...

The Lithium Rule.

Do not do to future generations that which you wouldn't want previous generations to do to ours.

What Poor People Do, Rich People Define?

The "Informal Sector" is a term I have never seen among the 6 billion people in the market it refers to.

The big mining companies are all in the "formal sector".

https://www.linkedin.com/feed/update/urn:li:activity:6960944556800385024?utm_source=linkedin_share&utm_medium=member_desktop_web

vocabulary lesson - of unwitting racist environmentalists... Your antithesis of recycling is mining, forestry, fracking... all of which earn gajillions from unearned public royalties.\

14/15 Superfund sites were the opposite of Recycling.

Elective Upgrades Supply Good Enough Markets

Elective Upgrades Supply Good Enough Markets

Is imitation the sincerest form of apology?

There is a guilt dilemma in "First World" aka "Wealthy" aka OECD consumer markets.  While there are repair and delayed gratification reuse trends (my company sells about $25k per month worth of TV parts to USA repair shops), there is also a lot of guilt about "elective upgrade", which remains the driver of most new sales.

Organizations like Basel Action Network and Greenpeace made a false assumption about 2 decades ago that "e-waste" was a product of equipment failure and inability to repair. That Americans, Japanese, South Koreans, Germans, Brits and Italians patiently wait for their CRT televisions, flip phones, and Pentium 4s to become hopelessly unrepairable before buying a plasma TV, smartphone, or i-Series laptop. 

The fact that it is patently obvious to nearly everybody that it was not the case, in hindsight, has been a point of reflection of this blog since I started it in 2006. 

Unnecessary elective upgrades, if indeed they are discarded as "waste" (or sentenced to a desk drawer, attic, or file cabinet) are indeed a wasteful use of mined, refined, extracted raw materials. But if they are reused, they create access for poor people to establish a "critical mass of users" to justify investments in TV broadcast, internet cable, and the estimated 170,000 mobile phone towers today that connect the continent of Africa... all financed by secondhand flip phone sim cards, replaced by black technicians on streets like Lagos, Accra, and Kinshasa.

It's a story older than this bad head gasket... sold to a Cummins motor geek in Florida, who re-exports trucks to rapidly emerging markets. Roads were paved in Appalachia and Ozarks by hillbillies like my grandparents, who could only afford vehicles they were smart enough to buy and fix.