Final Report on Rural Community Electronics Recycling Project

M E M O R A N D U M
REPORT WITHOUT APPENDICES SENT BY EMAIL - Original mailed

To: Susan Loney, RUS
From: Lynn Rubinstein, Executive Director
Date: October 23, 2002

RE: Final Report on Rural Community Electronics Recycling Project ~ USDA Award #01

Attached is the Final Report for the Northeast Recycling Council Inc.'s Rural CRT Recycling project. Thank you very much for this wonderful opportunity. The project went extremely well and I believe that a great deal of valuable information has resulted.

I would especially like to thank and acknowledge the state project partners, host communities, and vendor staff that played a critical role in the success of this project.

Maine State Planning Office:
-----Sam Morris
-----Tom Miragliuolo
New Hampshire Department of Environmental Services
-----Christopher Way
Vermont Agency of Natural Resources
-----Carolyn Grodinsky
Sandy River Recycling Association
-----Ron Slater, Manager
Pittsfield, Maine
-----Don Shute
Pemi-Baker District
-----Dan Woods
Springfield
-----Hallie Whitcomb, Recycling Coordinator
Central Vermont Solid Waste Management District
-----Liz Helrich, Special Programs Coordinator
ElectroniCycle
-----Robin Ingenthron, Vice President

Please let me know if you have questions or comments.

Sincerely,

Lynn Rubinstein
Executive Director

Cc: Rhonda Shippee, USDA Rural Development Vermont State Office

Northeast Recycling Council, Inc.

USDA Rural Utility Service
Rural Community Electronics Recycling Project ~ Award #01
Final Report

October 2002

The Rural Utilities Service Administration provided funding to the Northeast Recycling Council, Inc. (NERC) to conduct a Cathode Ray Tube Recycling Demonstration Project in Maine, New Hampshire and Vermont. This report summarizes NERC's accomplishments in completing its obligations under the grant.

The project goal was to develop and implement a cost effective recycling/re-use solution for cathode ray tubes (CRTs) from residences and municipal governments, thereby reducing the volume of materials disposed in landfills and incinerators, and reducing the risk of lead and other heavy metals leaching into the groundwater, surface waters and soils in the target states.

The project objectives were to:

1. Develop a cost effective computer/television-recycling/re-use program for residences and municipal governments, as well as a transportation strategy to end-markets.
2. Educate Recycling Center operators in the proper management and collection of CRTs, including collection, storage and transportation practices.
3. Maintain communication among the project participants to create a regional and inter-state solution based upon cost effective collection and transportation strategies, and less upon the limits imposed by state boundaries.
4. Promote inter-state cooperation in developing and implementing rural recycling/re-use programs.
5. Evaluate the effect of state and federal regulations on the project and offer recommendations for regulatory incentives to stimulate the safe and cost effective collection and transportation of CRTs.
6. Create a model for other multi-state and regional collaborations to establish cost-effective CRT recycling/re-use programs in rural settings.
7. Provide the recycling/re-use industry with information gathered from the project so that they can use the model when creating and supporting collection programs in rural communities and regions.

I. DELIVERABLES AND ACTIVITIES
All deliverables and activities have been fulfilled. The table below summarizes the deliverables and events.

a. Summary of Deliverables and Activities

II. PROJECT IMPLEMENTATION

------a. Community Selection
This project provided technical assistance for the development and implementation of regional electronics recycling collection programs in three states: Maine, New Hampshire and Vermont. The overall framework was to secure a minimum of two host communities in each of these states; those sites to serve at least one other community. In order to participate in the project, host communities had to meet certain criteria:

1. The host site had to be willing to organize and manage an electronics recycling program.
2. It had to be willing to allow other communities to participate in the collection (thus, making it regional).
3. The host site, and the majority of the individual participating communities, had to have populations under 10,000.
4. The host site had to express the intent to continue the electronics recycling program should it prove to be successful and resources be available.

In Fall 2001, NERC began this project by conducting a conference call with state agency contacts in Maine, New Hampshire and Vermont. Their support and participation on the project Advisory Committee was confirmed. During that conference call the goals and activities of the project were reviewed, and the process for selecting participating host sites from each state was discussed. There was discussion about distributing a general announcement and solicitation of interest to rural municipalities in each state, but the partner agencies felt that it would be more efficient to draw on their familiarity with the communities in their respective states as a starting point. At the request of the Committee, NERC drafted a solicitation letter that each state could customize and send to multiple qualifying communities. The state contacts agreed to review the letter, make changes as needed, send it to candidate communities, and to take the lead role in selecting the communities. As a result of this process, each state identified potential host communities that were contacted and invited to apply to participate.

The solicitation letter explained the purpose of the project, what NERC's role would be, what would be expected of participating communities, and suggested that communities return a letter describing their interest and capacity for taking part in the project. See Appendix A for sample invitation letter.

The letter was ultimately used only in Vermont. The Maine and New Hampshire environmental agencies decided to speak directly with town managers, solid waste directors and recycling coordinators in order to solicit their participation.

By mid-December, each state agency had helped NERC to identify two qualifying host communities (with regionally participating communities) in Maine, New Hampshire, and Vermont. Each of these communities submitted letters of intent and applications of interest to NERC. Individuals from additional communities had expressed initial interest, but could not garner adequate support from superiors or Boards of Directors to make a commitment to the project.

• In Maine, the selected host communities were the Town of Pittsfield (15 additional small towns use the Recycling Center - total population 16,099) and the Town of Farmington (Sandy River Recycling Association serves 19 communities and 16 townships - total population 26,373).
• In New Hampshire the hosts were the Pemi-Baker Solid Waste District (12 towns - total population 24,878) and the BCEP Solid Waste District (Barnstead, Chichester, Epsom & Pittsfield - total population 14,074).
• In Vermont, the selected host communities were the Central Vermont Solid Waste Management District (21 member towns - total population 64,739) and the Town of Springfield (which shares its Recycling Center with the Town of Chester - total population 12,122).

------b. Site Visits
In December 2001, NERC conducted site visits with the Vermont and Maine host communities. Due to scheduling difficulties, the New Hampshire site visits were delayed until January. During these visits Recycling Center and solid waste transfer station facilities were toured, rapport was established with the individuals who would operate the recycling programs, and likely collection strategies (given the infrastructure, motivations and circumstances) were discussed. Each host community was asked to complete a questionnaire and to sign a letter of intent to participate in the project. A sample letter and questionnaire are in the Appendix. Often, the questionnaire was completed during the visit.

------c. Collection Strategies
With two host communities/organizations in each of the three states established, NERC assisted with determining an appropriate collection strategy for each site. The decision making process took into consideration the resources of the host community, preferred strategies for introducing new recycling streams, budget and regional relationships, among others. The results were as follows:

• The Pittsfield, Maine began an ongoing collection program at its Recycling Center.
• The Sandy River Recycling Association (SRRA), Farmington, Maine held a one-day collection event in early May.
• The BCEP Solid Waste District, New Hampshire, serving the towns of Barnstead, Chichester, Epsom & Pittsfield, opted for an ongoing collection program.
• The Pemi-Baker District, comprised of 19 communities in northern New Hampshire, held one-day events in Littleton and Plymouth.
• The Central Vermont Solid Waste Management District (CVSWMD) began an ongoing collection program at its Recycling Center in Barre. The CVSWMD also held one-day collection events in Hardwick and Tunbridge, and organized a unique computer re-use event, which was held over two days in Barre, VT.
• The Town of Springfield, VT began an ongoing collection program for computers.

------d. Vendor Selection
During site visits and discussions, the host communities made it clear that a principle function NERC could perform for them through this project would be researching electronics recycling vendors and finding reliable markets. The hosts were not familiar with electronics recycling vendors, how much they were charging, and whether they were performing environmentally sound recycling practices or "exporting harm" by simply shipping materials overseas. Furthermore, the host communities wanted some assurance that once they began an electronics collection program for their residents, a recycling relationship with a vendor would exist in the long term. NERC therefore set out to answer these questions and provide some assurances.

There were extensive discussions between NERC, the host communities and the agency partners to determine the criteria that should be established for a successful vendor. Part of this discussion was research into the procurement requirements in each state and for host communities and districts. As a result of this research and discussions, NERC crafted and sent a Request for Pricing Information and Qualifications Statements (see appendix) to eleven companies in the region. The principle reasons for pursuing the strategy of a Request for Pricing were:

• One host had a competitive procurement policy requirement that would be fulfilled through this process.
• To be thorough and prevent potential liability.
• To verify the accuracy of impressions about individual companies.
• To compare "apples to apples" in terms of service and pricing in order to accurately determine the best procurement strategy.
• To attempt to secure preferential pricing - especially for transportation -through the use of a multi-state, multi-community procurement strategy.

Although this process delayed the start of collections, it was a valuable and productive process. We were, in fact, able to secure better pricing and services than individual states or communities had been offered.

The Request for Pricing Information and Qualifications Statements described the USDA grant project, the host sites, and the collection services desired from a vendor. In response, NERC received proposals from four companies.

NERC analyzed the responses, including follow-up conversations with the respondents for clarifications and additional information. An Excel spreadsheet was prepared that summarized the pricing arrangement proposed by three of these companies. One of the companies offered an incomplete proposal and as a result, its pricing information was not included in the spreadsheet. This information, including the actual responses, was distributed to the host communities and Advisory Committee, and a conference call was held to discuss the responses and to select a vendor.

Due to a combination of factors including price, minimum load requirements, re-use program, municipal collection experience, reputation and location, NERC recommended ElectroniCycle as the vendor of choice for this project.

Because NERC is not a government entity, it had the flexibility to negotiate with ElectroniCycle, to secure significantly lower prices and waived fees on behalf of the hosts. In March, NERC convened a project conference call. Members of the Advisory Committee (Maine SPO, NH DES and VT ANR), as well as several of the host communities (Pittsfield, ME, BCEP District, NH, and the CVSWMD) participated on the call. Several points were discussed, including NERC's vendor recommendation, collection site logistic considerations, re-use maximization, retailer involvement and state legal requirements. The state agency representatives agreed to provide information clarifying the legal requirements that must be met by the recycling company (e.g., universal waste permit) as well as the host community (e.g., local collection site permits). All of the host sites accepted this recommendation and proceeded to make individual contracting or other arrangements directly with ElectroniCycle. NERC's role was limited to helping to identify the vendor but had no legal contractual or other relationship with ElectroniCycle.

NERC provided sample contract language (see appendix) to assist the host communities with developing contractual relations with ElectroniCycle. Ultimately, all of the host communities opted to enter into a service relationship with ElectroniCycle under the terms as negotiated by NERC.

------e. Host Trainings
Beginning in March, NERC and ElectroniCycle conducted trainings for each of the host site staff. An outline of the material covered in the training in the appendix. The trainings took place in the host community, and when possible, at the intended collection site. The trainings were very well received and in addition to providing basic information and site specific guidance about program logistics, it was an excellent tool for ensuring that the staff understood why the community was beginning this project, to feel a full partner in it, and to have any questions and concerns addressed.

------f. Field Trip
NERC organized a field trip in April to ElectroniCycle's facility in Gardner, MA in order for the hosts to gain a comprehensive understanding of what will become of the material that is collected. This was a very successful event, and one that proved to be important to an understanding of the project and program requirements for all participants. It was informative and helpful for helping the host communities to better understand the process and to be equipped to answer questions from supervisors and the public.

------g. Program Specifics
Pittsfield, Maine began an ongoing collection program May 3, 2002 at its Recycling Center. The Recycling Center serves the surrounding ten communities as well as Pittsfield. This site was unique among the host communities because there was a dedicated recycling fund available to cover the costs associated with recycling electronics for Pittsfield residents. Thus, no end-of-life fees were charged to bring materials in for recycling. Individuals bringing in materials from other communities had the equipment weighed and their municipality charged a per pound fee by Pittsfield for the materials brought to the site by their residents. The town of Pittsfield explained that its motivation for participating in this project is its belief that electronics recycling is an essential service and thus budgeted in anticipation of the opportunity. During a four-month period 10,680 pounds of material, or .63 pounds per capita, was collected.

The program manager reports that they are being "overwhelmed" with computers and televisions, and that it is "really going well." Because of the savings in avoided solid waste disposal fees, they continue to be able to cover the cost of recycling for residents.

The Sandy River Recycling Association (SRRA), located in Farmington, Maine held a one-day electronics collection on Saturday, May 4, at the Sandy River Recycling Center in Farmington. The Maine State Planning Office provided active support for this collected and has posted photographs, program history, and other details on its website. The event also accepted fluorescent bulbs, thermometers, and mercury switches.

A total of 165 people brought electronics to the event. It required eight workers to handle the 6.61 tons of material, which filled a 53' trailer during the 7-hour (8 - 3) event. In addition, the University of Maine at Farmington brought in 1,390 pounds of electronics for recycling; bringing the total received to 7.3 tons. The per capita collection rate, without the University material, was .51 pounds. The collection was free to the 21 member communities of the Sandy River Recycling Association and its 25,890 residents.

Also collected at the event were 176 fluorescent light bulbs, six PCB ballasts, four thermostats, 27 thermometers, 65 lithium batteries, and 10 rechargeable batteries. All the material collected will be re-used or recycled.

A copy of the poster and press release is in the Appendix. As a result of the outreach efforts, there were several news articles promoting the event (also in Appendix). The SRRA officials were very pleased with the event. More material than had been expected was received. They also expressed the opinion that it was an easy event to organize and "not a budget breaker."

The overall budget for the collection was .18/pound for the electronics (total of $2,775 including transportation) and approximately $600 in staff and volunteer labor (not including the NERC time provided through this grant). This represented approximately 24 hours of program staff time to organize and implement, and 20 additional hours of volunteer time on site. SRRA considered the one-day event to be a "fabulous education tool" for residents of their region and to increase awareness of the future need to recycle electronics.

The BCEP Solid Waste District, which serves the towns of Barnstead, Chichester, Epsom and Pittsfield, NH, had intended to begin an ongoing collection program in June 2002. Despite repeated inquiries and offers of assistance, it has failed to materialize. The District still intends to begin an electronics collection program, but other program and budgetary priorities have resulted in putting the program on hold. Their intention, however, is that once the program begins to charge $10 per CRT and that all other electronics will be free of charge.

The Pemi-Baker District is comprised of 19 communities in northern New Hampshire. It held one-day events in Littleton (July 13, 2002) and Plymouth (July 20, 2002). Each event was held from 9 - 3. These were "turnkey" events, with the District being responsible for advertising and organization, but had no direct financial responsibilities for the recycling. Instead, ElectroniCycle (see Turnkey contract in Appendix) charged participants end-of-life fees for each item that was brought to the event.

The District developed and implemented a very aggressive advertising and promotion campaign, including paid advertising. The District spent $700 on display advertising, and had funding contributed to cover the cost of posters by the North Country Council, the Regional Planning Agency for the area. They ran the ad in the main Littleton area paper for three weeks, and ran it in the main papers in the Plymouth area for two weeks. The posters were distributed to the District representatives and asked to be posted in their towns. The radio stations were contacted and asked to do a promo about the collections. In addition, an announcement was placed on the local cable stations that post community events.

There was press coverage of the event in Plymouth, and an editorial written as a result of the Littleton event. Copies are in the Appendix.

The North Country Council also provided a grant to cover staff time to administer the project on behalf of the District.

The population served by the entire District is just under 25,000. A total of 15,995 pounds was collected at the two events, for an average of .64 pounds/capita. However, the Plymouth collection was very disappointing to the District. There were only 16 vehicles that participated, including two schools. It was due to the schools that the total weight of 4,854 pounds was collected at that site. The project organizer for the District speculated that the poor turn out was because "the collection wasn't held at the transfer station (where we hold our household hazardous waste collections) but because of the landfill closure process going on there that wasn't possible." "In Littleton on the other hand - the collection was held at its HHW location and was a huge success (44 cars plus the businesses)."

Springfield, VT informally began an ongoing collection of computers at its Recycling Center in late spring. It will begin a permanent collection of both computers and televisions once a storage area has had a cement floor poured. A grant was received from the state of Vermont to pay the approximate $5,000 cost of that work, but due to other work priorities, the Springfield Department of Public Works has not yet poured the floor. Once that work is accomplished (which is expected before January 1st), the electronics collection program will be promoted. There is currently a fee of $10 per computer recycling, and there is a $10 fee for televisions as well but they are not yet set aside for recycling. The volume of televisions that comes in is significant and until the storage area is completed there is no appropriate place to consolidate the televisions. The Recycling Coordinator is firmly committed to beginning this program in earnest as she firmly believes that landfilling or incinerating of electronics is fundamentally wrong.

The Central Vermont Solid Waste Management District (CVSWMD) began an ongoing collection program at its Recycling Center in Barre in April. In addition, CVSWMD held special collection events in Hardwick and Tunbridge in June and August, respectively. Further, the District organized a unique two-day re-used pilot project that was held in September 2002. A complete report, prepared by the CVSWMD, about its program is in the Appendix.

The Hardwick one-day event has the dubious distinction of having the worst participation of any event held under this project. It was a turnkey event, managed by ElectroniCycle, but the turnout was so poor that per the terms of the turnkey contract, the CVSWMD should have owed the vendor $600 for failing to meet the minimum volume of material. However, demonstrating its support of rural programs and willingness to be flexible, ElectroniCycle made a proposal that the District embraced. A second one-day event was scheduled for later in the summer in Tunbridge. This too was planned to be a turnkey event. ElectroniCycle proposed that rather than being on site the District would collect and consolidate the materials, moving them to its permanent collection facility in Barre. The materials would then be picked up as part of a regular pick-up. In exchange, ElectroniCycle waived the $600 fee.

As a result, the District rented a panel truck, secured gaylords and pallets, brought a pallet jack from the Barre location, and managed the end-of-life fees. In addition, to loading the truck on site, the truck then was taken to Barre where the materials were taken off the rental truck and moved into the electronics storage area. Fortunately, the CVSWMD staff was able to respond to these changes circumstances.

Both of these one-day events were held in conjunction with household hazardous waste (HHW) events and the turnout for the electronics was consistent with the approximate number of customers expected for the HHW program.

At its Barre Recycling Center, the District implemented a permanent collection program, using a trailer that was on site for storage. This site was chosen in conjunction with NERC after a review of all of the CVSWMD Recycling Centers. The Barre site offered the greatest storage areas, traffic flow opportunities, and accessibility for hours. By contrast to the one-day events, this program has been operating smoothly and with consistent volumes of materials.

The District also took upon itself to try a re-use model: one that had never been tried before. By taking advantage of a bi-annual clothing swap event organized by the District, a two-day computer only re-use event was created. A detailed report on this effort is in the Appendix.

In brief, computer equipment was accepted for consignment, donation or recycling on the first day. Volunteer technicians evaluated all of the computers before they were put up for sale or donated. Technicians helped sellers set a price and helped shoppers on the second day find a computer that met their needs. There were 12 volunteer technicians from local businesses and agencies. NERC worked closely with CVSWMD to identify and secure sponsors and technicians to support this event; including helping to draft solicitation letters and visiting potential sponsors.

Approximately 54% by weight of what came in was sold or donated for re-used and the balance was sent for recycling because it did not meet re-used standards; such as being in working order, of the right speed, or modem accessible.

III. COLLECTION RESULTS ~ OVERVIEW

IV. PROJECT EVALUATION

------a. Where the objectives achieved?
Each objective will be addressed separately.

1) Develop a cost effective computer/television-recycling/re-use program for residences and municipal governments, as well as a transportation strategy to end-markets.

The project did successfully accomplish this objective. Several different strategies were tested and in most cases they proved to be very cost effective and effective in collecting materials from residents and government. In addition, the project did develop a regional and multi-state program for moving the materials for recycling to end-markets. The vendor selection process allowed the host communities to play an active and critical role in determining the services and qualifications of the vendor, and in making the vendor selection. Having a non-governmental third-party (NERC) in the role of quote recipient provided the maneuvering room to negotiate with vendors and to tailor an ultimate arrangement that best met the needs of the host communities. As a result, we were able to secure pricing and terms superior to those that had previously be obtained by state contract in Maine and New Hampshire. Vermont does not have a state electronics recycling vendor contract. This was particularly significant in Maine where, due to travel distances for the vendors, the pricing was significantly higher than in other parts of New England. Through this process we were able to negotiate pricing more closely in line with the price being offered to areas more proximate to the site of recycling.

2) Educate Recycling Center operators in the proper management and collection of CRTs, including collection, storage and transportation practices.

This was very successful, and proved to be more complex than we had initially anticipated. There were five principle strategies used. These were an integral package and expanded Recycling Center operator expertise and capacity with each phase.

1. Application process to participate in this project.
2. Initial meeting at the collection site with staff and decision makers.
3. Tour of recycler's operation.
4. On-site training for program staff.
5. On-site participation and assistance during collection (for special events).

Application Process
While the state project partners were instrumental in identifying host communities that would be appropriate for this project, it was determined that an application process would be an important first step in educating communities about the project and securing a level of intent and commitment from them. As such, an extensive questionnaire was developed for each host community to complete. Copy in Appendix. In addition to engaging the communities, it provided critical information for helping to design a program suitable for those communities. The questions addressed: staffing, budget, communities served, experience, site operations, fees, equipment, public education, and specific questions about an electronics collection in terms of operations, costs and logistics. In general, we worked with the community to complete the questionnaire and in this way we became familiar with each other and began to develop an understanding of what would be necessary to operate a program, and what type of program might work best for the individual host community.

Initial meeting/Site visit
Often, the questionnaire was completed at the initial meeting between NERC and the host community. NERC staff, often accompanied by a representative from the recycler, visited each host community to meet staff, look at the potential collection site, discuss logistics, answer questions, and when necessary, meet with municipal or district decision makers to ensure full commitment and support of the project. Only in a few instances did this prove to be challenging and only one program that had applied due to staff interest failed to materialize after this effort. The site visits were also the occasion for the signing of an agreement between NERC and the host community, in which the community agreed to the terms and conditions of participating in this project. A copy of that letter of agreement is in the Appendix.

Tour of ElectroniCycle
Once the host communities had been finalized and the vendor selection completed, it became apparent that a visit to the recycler would be important for program staff to fully understand the program, to be able to answer questions from the public, and to feel fully engaged in the project. As such, a tour was arranged and representatives from every host community, and several participant communities, as well as state partners attended. The tour helped to provide a degree of confidence both in the individuals who would be dealing with the public, but also in the communities that their material was truly going to be handled in an environmentally and socially responsible manner.

On-site training for staff
NERC staff and a representative from ElectroniCycle visited each collection program and collection site and conducted a training with staff to discuss site set-up details, safety issues and personal safety equipment, answer questions, discuss storage and pick-up details (as needed), provide additional contact information, and finalize program details for that site and program. There was also discussion about how to publicize and promote the collection, and review of existing procedures and practices. In several cases, communities had begun informally collecting electronics because their citizens were bringing them in for recycling. Often, these were not being stored or handled safely and the site training provided an important opportunity for site and staff specific assistance.

On-site participation & support
Naturally, holding a collection event is the best training. In addition to host community staff and volunteers, NERC staff participated in each special event collection. We played several roles:

1. Helping to process and check-in participants.
2. Helping to answer questions.
3. Facilitating relations and arrangements with vendor.
4. Observing for purposes of this report.
5. Technical assistance and advice for that event and future opportunities.
6. Data collection.

By being on-site and providing hands-on assistance, we were able to provide guidance about how to properly manage a collection, to provide one-on-one training and assistance - as needed - to program staff. After the events, host community staff uniformly expressed the opinion that they had learned a lot, had new ideas for how to run future events, and had enjoyed it.

3) Maintain communication among the project participants to create a regional and inter-state solution based upon cost effective collection and transportation strategies, and less upon the limits imposed by state boundaries.

Through the forum of the Advisory Committee - to which the host communities' staff was added from the initial membership of state project partners - we were successful in maintaining a dialogue and information exchange among the programs. We had initially planned to use a listserv as a tool for inter-program communication. While we did establish one, it proved not to be the best tool for communicating. Instead, we relied on phone calls, general emails, faxes, and meetings. In addition, the tour of ElectroniCycle proved to be an important opportunity for all of the project players to meet each other, exchange ideas and experiences, and develop a working relationship around this effort.

The process that was used to select the vendor also relied on the teamwork of the expanded Advisory Committee. They were active participants in creating a regional and inter-state solution, and in designing that solution.

4) Promote inter-state cooperation in developing and implementing rural recycling/re-use programs.

As the project evolved, this objective and the one above relating to maintaining communication provide to be the same effort. The camaraderie that evolved among the host communities and the exchange of ideas during conference calls proved to be valuable.

5) Evaluate the effect of state and federal regulations on the project and offer recommendations for regulatory incentives to stimulate the safe and cost effective collection and transportation of CRTs.

With the assistance of the state project partners, NERC examined the relevant state and federal regulations, as well as proposed federal regulatory changes to the Universal Waste Rule that arose during the course of this project. As a result of this effort, NERC was able to publish a listing of the Universal Waste Laws in the Northeast States. This was the first time that this information had been compiled and there was a great demand for it and interest in the results. Because of the rapidly changing regulatory world, the Listing was updated in late spring. What was discovered was that Maine, New Hampshire and Vermont had liberal state laws for the collection and movement of CRTs, and that the federal government was attempting to move in the same direction. The only regulatory concerns that arose were fairly minor ones: and they were both in Vermont.

In Vermont, the collection sites (whether for a special event or permanent collection) were required to amend their solid waste plans and get permission from the state environmental agency to add electronics collection to their programs. The principle difficulty proved to be determining the correct format for making the request and what the "magic language" was that should be included. Once this was resolved, the sites readily were able to receive the regulatory permission to proceed. In addition, there was a need for some paperwork to be filed by ElectroniCycle with the state for transporting of electronics within the state. After some dialogue with the relevant state agencies, it was determined that ElectroniCycle was fully in compliance and the supplemental filing of information had not been necessary.

Our recommendations were for the deregulation or Universal Waste status of CRT material to be encouraged and supported, and that the state agencies should develop a clear packet of regulatory and permit requirements for holding electronics collection events. In this way, time would not be lost in trying to determine what is necessary, whether the entities are already in compliance, and institutionalizes the concept and need for electronics recycling events.

6) Create a model for other multi-state and regional collaborations to establish cost-effective CRT recycling/re-use programs in rural settings.

We believe that we have accomplished this significant task - which lies at the heart of this project. By working cooperatively with state agency partners, developing a strong working relationship with a vendor, and having committed regional host communities, we have been able to develop a model for rural electronics collection programs that is cost effective and efficient.

7) Provide the recycling/re-use industry with information gathered from the project so that they can use the model when creating and supporting collection programs in rural communities and regions.

The data from this project has been shared with the national database being compiled by EPA of program results as well as publicized on the NERC website. In addition, we have presented this project at a training in New Hampshire (in the form of a PowerPoint presentation).

In addition, having a third-party (NERC) as a technical and coordinating resource proved to be extremely important. We were able to provide ongoing technical assistance and support, problem solving, and guidance. Host communities were particularly interested in the experiences of the other host communities and eager to learn from them and to compare their own experiences. NERC was able to provide a context and conduit for this information and outreach.

------b. Looking Ahead
The Pemi-Baker Program has offered specific comments about its future electronics recycling program goals.

For next year I will try to encourage the District towns to implement a permanent electronics recycling program. The one-day collections are great . . . but are very inefficient - reaching only a small percentage of the population. I envision electronics developing into something mirroring our paint recycling program. Paint is collected year round in all District towns and then consolidated at 2 to 3 points for pick-up. It is easy to see that electronics could be handled in the same manner with towns collecting the material in gaylords and consolidating the gaylords at Plymouth and Littleton at the time of pickup. Businesses could/would be invited to bring their material to either one of the two sites at this time.

The CVSWMD also offered some program insights.

This is success. But of course, there are areas that will require our attention as we refine a permanent program:

• Evaluate user fees and determine what percentage of program costs, if any, CVSWMD will subsidize.
• Improve business access to electronics recycling opportunities.
• Improve training of and program buy-in by field staff.
• Improve collection site & collection methods (may require the purchase of additional materials handling equipment and the design and construction of a space more suitable for electronics collection).
• Expand service to include 100% of CVSWMD population.
• Public education on responsible electronic waste management and conservation-minded purchasing.
• Continued advocacy for shared responsibility for electronics waste management among consumers, manufacturers, government and local retailers.

------c. Lessons Learned
As with any pilot project, there were many lessons that were learned that might benefit other rural electronics collection efforts. In summary, they were:

• Having technical assistance and outside encouragement to start a program - even if only in the role of catalyst - is important. It provides credibility to the effort, support to staff for requesting the creation of a new program, and the very practical support of time and help in designing and maintaining the program.
• Ongoing technical assistance and support - responding to changing circumstances and providing guidance about what others are doing and how they can benefit from information. One of the special features of this project was the multi-state and multi-site effort. The participants benefited from the experiences of their peers, and the support from being part of a larger effort.
• Having staff to design and implement the program is essential.
• Multi-state/regional procurement was an effective strategy for cost containment and ensuring that the specific needs of the programs were met.
• In some cases, the population being served is too small to warrant having a recycler on site - or to designate it a specific collection for the purposes of the recycler. It was more financially effective to collect the materials and transport them to a consolidation point - in this case, a permanent electronics collection site.
• Using a turnkey operation, with an adequate population base, is the most cost-effective strategy for a community having a one-day or special event.
• The advance trainings were truly helpful from the perspective of both the recycler and the program hosts.
• In a rural area the material to be expected, no matter whether it is an ongoing program or a special event, is approximately ½ pound per capita. This is approximately one-half to one-quarter as much material as is seen on average nationally - which generally reflects urban collection environments.
• Working closely with state environmental agencies helps to streamline permitting and procedural requirements, and can become a source of technical assistance and physical assistance at collection events.

ElectroniCycle found this project to be a learning experience, and one that benefited their business.

In some instances the small amounts of material to be picked up at the permanent collection sites - because of storage limits at those sites -was viable when it was added onto an existing milk run but would not have worked by themselves (failed to meet minimum). Also in some cases (e.g. Agway Energy Products had pickups statewide) the host community stops became an "anchor" allowing ElectroniCycle to add other clients to the milk run, so the end result was more material collected as a result of this effort than simply due to the USDA project.

Our "rule of thumb" of one-pound per resident peters out when the population is spread across a wide area. It came close with heavy advertising in areas with no permanent collection, but having a one-day event in an area which has a permanent collection fell far below that estimate. We adapted 2 solutions: 1) In Tunbridge, the District held the "event" without our staffing, and transported the material to their permanent collection point; 2) In St. Albans (not NERC, but new turn-key) we arranged for school material to be there for pick-up if there was room left from the municipal collection, or stored if there was not room. Finally, following the Littleton event we have pushed back public hours if there is a large lot coming in from a satellite community, so that unloading the large load does not delay service to the citizenry.

I'd also say that the advanced trainings, which we so often skip when setting up a rural community, were truly helpful. Our major conclusion is that rural recycling is possible and productive, and opens new opportunities.

APPENDICES

A) Sample invitation letter
B) Letter of intent to participate in the project
C) Community questions
D) Request for Pricing Information and Qualifications Statements
E) Sample contract language
F) Turnkey contract
G) Outline of the material covered in training
H) SRRA collection publicity materials
I) Pemi-Baker District outreach materials
J) CVSWMD program report
K) CVSWMD Re-use pilot report
L) PowerPoint Presentation About Project