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Having had a chance to discuss the documents provided to the Reuse Committee participants from our last meeting at November 28th, 2007, Free Geek and Computers for Schools present a joint reuse submission for your review.
We remain as enthusiastic as ever to participate in the development of a reuse program for the province. We are confident that a viable, effective framework will result.
As discussed, we have created an umbrella reuse organization called “E-SAFER BC” - Electronic Stewardship Alliance for Ethical Reuse BC. It is our intention to launch a website posting information about our groups with links to our websites, enabling consumers to locate ethical reuse groups easily and match their donation to equipment specifications and/or charitable philosophies. This site can dovetail with the web resources already available, for example Return-It collection sites and services.
E-SAFER BC will not be limited to Free Geek or Computers for Schools, but should eventually include other reuse organizations exerting a high level of commitment to environmental stewardship, community reuse and ethical recycling practices – all of which will require transparency and the eschewal of illegal dumping and export, including a commitment not to violate laws in importing countries, above and beyond Canada’s export regulations. However, determining the standards by which other groups may join E-SAFER and be accountable to the BC Stewardship plan remains challenging.
As for ESABC's draft, the WEEE guidelines have provided an excellent framework. There remain a few problematic issues.
While we believe that audits may help with internal improvements or inventory controls, they will be limited in their scope to assess exporting practices, environmental impact, community benefit and, in the end, have little ability to curtail the solicitation practices of bad players within the export industry.
In order to offer input on the proposed auditing process, we need clarification as to what specific standards would be employed, as well as the actual cost of undertaking such an audit. We assume you will require auditors to fully verify compliance with both Canadian and importing countries’ export regulations, and will require auditors to review the organizations’ environmental and occupational impacts from operations. Further details would greatly assist us in our evaluation.
More information regarding previous audits conducted on other participants would also fortify our understanding. We are especially interested in the process undergone by the Salvation Army and Encorp as points of collection, and would also benefit from information on the audits of Vanguard, and the program's consolidation sites and downstream processors. Financial information may be redacted to protected business sensitive information.
In particular, we would like more information on:
· what the audits consisted of,
· who they were performed by,
· each audit's approximate cost,
· who incurred these costs
We also remain unsettled at the prohibitive cost of conducting the audit itself. We are concerned that this feature will curtail participation by worthy re-users, particularly community-oriented non-profits, and put them at a disadvantage to typically more prosperous unsavoury operators. The sincere pursuit of good practices should not be obstructed by short-term cost, particularly considering the high environmental tolls at stake. Perhaps something to level the playing field should be considered, for example in the order of a capacity grant for qualifying organisations. Such a grant could be designed to cover auditing costs for non-profits, or very small re-users, which would reveal good candidates; part of the application would also entail demonstration of financial need for the bursary, preventing abuse. By limiting the number of grants available per year, it would stimulate competition and reward rigorous self-examination and transparency. Another option is to offer audits with fees based on a sliding scale, with grant money covering auditor time and expenses for qualifying organizations, or in-kind grants.
One of our key priorities is to ensure that ethical reuse organizations such as Computers for Schools and Free Geek gain high visibility in order to solicit computers for reuse in the community. It is our firm belief that many computers earmarked for recycling can instead have extended life in new settings -- and only at their true end of life be entered into the provincially-mandated recycling stream.
One of the Province’s markers of success of the stewardship program is having collected more equipment than initially projected – thus it serves both our interests to ensure reuse continues to have an active and viable role within the ESABC stewardship plan. Prominent reuse will reduce (through delay) the volume in the recycling stream, while simultaneously meeting community and school needs; such an initiative will further educate and engage the public, motivating them to access the program, and creating healthier communities in the process. It is our hope that British Columbia will become an example of a truly comprehensive e-waste management program for the rest of the country to follow.
We look forward to meeting with you shortly to further discuss the ideas outlined in this letter, in particular to review in detail the requirements listed under the WEEE and would suggest a time during the first week of March.