Vermont's Anti-Business Reputation Part 2: DEC Grinch Steals Christmas

This morning I had to announce layoffs for 5-8 staff at Good Point Recycling in Middlebury Vermont. These will only affect Vermont employees, our Brockton MA facility, which does 95% of the recycling (not reuse) for our company is unaffected.  Good Point has been threatened denial of payment and threat of environmental enforcement by Vermont's Agency of Natural Resources. The "crime" is removing T-con boards for reuse, and hard drives for recycling and data security, at a change of address (down the street) which we notified ANR of 6 months ago after our landlord declined to give us an extended lease.

We informed ANR in July that we were moving the removal of TV boards, to test for reuse and resale, to a different building.  We showed that we sell approximately $50k per month to USA repair shops - individually tested and inventoried circuit boards for $30 each.  ANR said then that we had to change the address on the recycling insurance policy - which lists no address and covers pollution anywhere it's released. ANR said we must change the address on the bank financial mechanism - at a cost of $1500 - despite the fact it lists NO ADDRESS and covers recycling tonnage anywhere we might abandon it. Despite these two crystal clear evidence of incompetence or bias by the ANR staffer, the Secretary and administration has taken no action except to send another ANR staffer to inspect us in October. He said he saw zero evidence of any environmental violation under RCRA, and said that the administration of our recycling contract might be her issue (how she withholds funds).

That contract does say we must be R2 certified. We explained the move during our R2 audit and the auditor and SERI told us that so long as all the same downstreams and management systems were in place, that the change of address would be done at the anniversary of the next audit. If R2 does disqualify the same person from reusing the same TV circuit board, removed solely for the purpose of reuse, and the Vermont state statute clearly says that a device removed solely for the purpose of reuse is NOT recycling and is NOT governed by the statute, then R2 would be messed up. 

None of our competitors in the ITAD and hard drive destruction business - or Vermont's own Surplus Property office - is required to have any of these insurance or certifications.  Karen explained that is because the "purpose" of the drive removal is for "data reasons" and when our staff do the exact same action, it is for "recycling" reasons.

Hey, Governor Phil Scott, cleanup in Aisle 9.

A job listing a removed working LED light strip for resale at TV repair shops in USA

I waited 6 months to do the layoffs because my history shows that Vermont ANR does not take admitting error lightly. When we enjoined them from cancelling our contract in 2013, they wrote letters to all of our OEM clients implying we were guilty of violating environmental laws (there was no such claim)... that was the last time I had to lay off 50% of Good Point's staff until ANR settled and returned the contract to us in 2014.

The Empty Chair: Raise Your Hand If...

Raise Your Hand if you know who STEVE JOBS is.

Now, Keep your hand raised if you know who Jim Puckett or Basel Action Network is.

Now, Keep your hand raised if you know who TERRY GOU is.

Keep your hand up if you know who Simon Lin is.

Keep your hand up if you know Dr. Graham Mytton is.

Keep your hand up if you know who Prince Nico Mbarga is.

Keep your hand up if you know who Awal Muhamed, Yaro Muhammed, or Razak of Savelugu is. 

Keep your hand up if you've ever been to Savelugu.

Now unless you are author Adam Minter... my guess is your arms are back to your side. You'll need both of them when I conclude this talk.

The technology for "touch-screen" information feedback - sending data via touching a display device - was originally developed for cathode ray tube CRTs in Germany in (I think) the 1960s (based on my interview with Allen Liu, retired CEO of Net Peripheral, in 2016).  That patent was either abandoned or purchased by the Taiwanese engineers - graduates from University of Taiwan in Taipei - decades later. These tinkerers* applied to very small handheld touchscreen devices.  The "patent claims" by Apple and Samsung over smartphone touchscreen technology went nowhere 15 years ago (if anyone remembers those court cases, keep your hand raised) because neither invented it. Taiwan was the Cyrano of electronics invention, rising from "contract manufacturing" to schematic design wizards.  Terry Gou is the Taiwanese CEO of Foxconn, which manufactures most iPhones. Simon Lin is the Taiwanese CEO of Wistron and Acer.

Author, Author!

The seat next to me is empty, because those of you who lowered your hands might think I'm an expert. But everything I'm telling you today is either public data, available from World Bank and IMF loans for electric grid and hydroelectric projects which provide electricity to more than 90% of people in the world.  And if you had not interviewed fake experts like Jim Puckett of BAN, or Sasha Rainbow (Placebo MTV documentary director), or photojournalists like Kevin McElvaney and other "poverty porn purveyors" who got their information from Mike "Fishing as a Boy" Anane - that the center of capital city Accra was a remote fishing village in the 1990s... etc.

For twenty years, what I have learned by listening to the Tech Sector, listening to importers, listening to the founders of great OEMs, was derided by a lot of idiot white people who were given the privilege to sit before conferences in that chair.  People from Greenpeace, from European institutions, people like Interpol's Cornelius... people who probably meant well, but who were completely responsible for the false arrest, denigration, defamation, discrimination, and imprisonment of Tech Sector workers like Joe "Hurricane" Benson, an African who may well have become the "next: Steve Jobs, the "next" Terry Gou, or the "Next" Simon Lin. (Keep your hand raised if you remember Steve Jobs second company, "NEXT").

“You can be for the environment, or against plastics, but not both”

Getting to know Megan Fontes, the new Executive Director of the Northeast Recycling Council this week. Lynn Rubenstein is retiring - Lynn and I worked together in several capacities over the decades (she came with me on my first visit to China in 2002).

Via LinkedIn, Megan just shared this article to ask my thoughts.   Plastic – Fact over Fiction

Chris DeArmitt - PhD, FRSC, FIMMM

Written by Chris DeArmitt.  He's a paid "expert witness" who's got industry connections, but I guess I do too, and have seen my articles dismissed based on my "recycling business".  The article makes several of the same points made in the Oregon study from a couple of years ago.

Remember: “you can be for the environment, or against plastics, but not both”.

Well, I'm not as sure about microplastics as Chris DeArmitt (his argument that the number of alarmed scientific reports is 24% but number of press reports 90%+ does point to journalistic alarmism, but if he's an expert on plastics, that's a really weak response to concerns on microplastic pollution).  But his LCA lifecycle analysis is spot on.

He also takes some cheap shots against other materials, like "ceramic takes longer to degrade than a plastic bag". It's an apples to oranges comparison. Same with carcinogens in dust industries like cement. I'm sure if a study was done on inhaling plastic particles, they'd be just as carcinogenic (abrasion is the cause with cement, not toxicity). But he's defending his team, and it is true Team Plastic is getting ganged up upon.

Vermont's Anti-Business Reputation? Yep, that's a thing. Part One Of ...?

Part 1, History 1999:  When I left my position as Division Director at the Massachusetts Department of Environmental Protection, I got a one-year special assignment to orchestrate the first CRT waste ban and recycling program in the USA. I got to promote/appoint my most talented staff... That is the thing I'm proudest of from that time.  It wasn't "recycler of the year" or the state legislature commendation, or the state employee of the year recognition, or increasing my program budget from $1M to $10M, or my own promotions.  I'm proudest of the demotion year, because that elevated people like Brooke Nash, John Fischer, and Greg Cooper (two of whom began as interns) to my empty chair.  Anecdotally, I got a pay raise (how demotions work at Mass State Employees Union) and three-day a week (to commute from Vermont), to focus on ONE big special project - cathode ray tube recycling infrastructure - which essentially became the Massachusetts "infrastructure business plan" for a TV and computer monitor waste ban.

"Don't throw the baby out with the bathwater" is an idiomatic expression for an avoidable error in which something good or of value is eliminated when trying to get rid of something unwanted.^[1][2][3]

A slightly different explanation suggests this flexible catchphrase has to do with discarding the essential while retaining the superfluous because of excessive zeal.^[4][A]

Vermont Agency of Natural Resources and its DEC initially gave me a nod and showed respect when I left Massachusetts DEP and invested my sweat equity to start a consulting business on electronics recycling.  I got to meet with Bob Tonetti and Marilyn Goode at EPA in Washington, and they codified the Massachusetts DEP CRT recycling rules into Federal. I got to meet Michael Dell in Texas, I got invited to present to the California Resource Recovery Association CRRA Conference.

My message was reuse. Repair is the hospital, and Reuse is the orphanage, for used electronics. Recycling is the Morgue. Little did I know that to Vermont ANR, reusing a computer part to fix another computer would one day be presumed to be a murder of the first computer. The burden of proof is on the doctor saving the patient.

Vermont Agency of Natural Resources, to date, has appointed a RoboCop who doesn't care about orphanages or hospitals to throttle my company. It has been all about the morgue, and only the morgue. And they sent an inspector to investigate my company's reuse of solar panels last month... The problem was that they are not a problem yet... I've been predicting that solar panels are the "next CRT", and ANR acted too swiftly. And so I listed our 50,000 s.f. facility for sale, and moved half of my operations to Massachusetts in 2019. I remain with a foothold in dear old Vermont, but I see storm clouds in places far north of Puerto Rico...

But back to history - Why are we still talking about CRTs? Because all the orphan CRTs created the critical mass of users for Asia and Africa internet cables.  All of the orphan flip phones created the critical mass of users for 170,000 mobile phone towers operating today in Africa. And secondhand solar panels are about to be the babies boiled to be boiled in the bathwater. For that reason, Vermont will not be my place to invest in solar panel recycling. Two reasons - "No" and "Hell NO!" I'm not killing orphans, and will go to prison rather than build a business overseen by baby killers. Vermont can't get it right, because it has no spine to correct regulators, because stopping regulators from killing reuse orphans is "anti-regulator" and that is "bad". Orphanages and Emergency rooms saving patients are "anti-cemetery" and are presumed to be dumping the bodies on roadsides. Here in Vermont, we can't have that.

Toe tag. (2022, September 2). In Wikipedia. https://en.wikipedia.org/wiki/Toe_tag

What Plastic Recycling Really Needs: Rational Critical Thinking

Wouldn't we be frustrated if NPR did a story on low health and safety standards of vegetarian restaurants in Indonesia, and made the story about vegetarianism without comparing the standards at meat-centric Indonesian restaurants? This is an example I use of critical thinking when I give a talk on recycling markets. I'm not against improving them, and shining critical light on them may be helpful. But isn't associating poor hygiene with vegetarianism and not visiting a control group of meat restaurants a rather cringeworthy example of #gotchajournalism clickbait?

Note to all editors of all news organizations.... Always compare recycling to virgin material production, please, and not to an idealized image of recycling.

There's Always Market Demand for Rational Critical Thinking.  It's just undervalued.  The problem has plagued Journalism ever since newspapers lost the one-third of revenue from classified ads... if only News Corp or New York Times had purchased / invested in eBay 25 years ago...

The drop in revenues continues as journalism competes with online advertising, targeted to unique consumer data from Alphabet, Meta and Amazon.  And "free content" abounds - woefully edited or fact-checked - via links to fake news shared by "friends of friends" online.

That's a long way to approach the reporting on the state of plastic recycling by NPR's Laura Sullivan.  She has made her biography synonymous with a story that Plastic Recycling is a big lie... Either she can fix this herself, or we need tenure-seeking professors and graduate students to lay some math and control group facts on her "conclusions".

"Sullivan won her third duPont in 2022 for her Planet Money podcast WASTE LAND, an investigation with Frontline into Big Oil and the myth of recycling plastic. The California's attorney general opened an investigation into the oil companies citing NPR's reporting, saying the companies participated in a "half century of deception" perpetuating a myth that plastic could be recycled in an effort to manipulate the public to buy more of it."

I learned a lot by trying to show CBS 60 Minutes producer Solly Granatstein that the CRT computer monitors were nowhere in evidence in the Scott Pelley footage of Guiyu. I showed his team, before the segment ran, photos of the factories that bought the CRT monitors for re-manufacturing and reuse. Later I sent them emails showing the "toxic river" in Guiyu was immediately downstream from the largest textile factories on earth, and that the water samples were pretty much identical to Bangladesh textile factory effluent in the Lourajang River. Later still, I helped Adam Minter investigate the integrated chip reuse markets which actually drove the circuit board recycling market in Guiyu... Reuse is still being attacked as "counterfeit".