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[GreenYes] Take Back

June 13, 2008

Mr. Leonard Robinson
Chief Deputy Director
Department of Toxic Substances Control
1001 I St.
Sacramento, CA 95812-0806

Subject: AB 1109 Task Force Recommendations

Dear Mr. Robinson:
The San Luis Obispo Integrated Waste Management Authority (IWMA)
would like to offer its perspective on the recommendations being
developed by the AB 1109 Task Force. AB 1109 requires the Task Force
to make recommendations to the Legislature on, among other things,
the most effective, cost-efficient, and convenient method for the
consumer to provide for the proper collection and recycling of any
end-of-life general purpose lights generated in this state.
All of the options being considered by the Task Force recognize the
obvious fact that retail take back best meets these criteria. These
options essentially differ only on whether such retail take back
should be strictly voluntary or voluntary with the prospect of
mandatory if yet to be specified levels of convenience and recycling
are not achieved. Thus, the key issue is whether retail take back
should be voluntary or mandatory.

The IWMA respectfully submits that the answer to the voluntary versus
mandatory issue is equally obvious: the voluntary approach has been
tried and failed. Despite DTSC's best efforts during the last 2
years, the voluntary Take-It-Back-Partnership appears to have
resulted in less than 1% of potential retailers participating in the
program. Without universal participation, true convenience cannot be
achieved and without such convenience recycling is simply not going
to happen.

The IWMA also tried the voluntary take back approach. In our case,
we provided the collection containers and paid the post collection
costs of managing the materials. With a free program to retailers,
many of the locally owned stores participated in the program;
however, many of the big box retailers declined to participate. For
example, Wal-Mart and Home Depot, who account for 50% of the retail
sales of CFLs refused to participate. In our many attempts to get
them to participate in our fully funded voluntary program, we were
told time and again, that they would not participate until the
program was mandatory.

As a result of the major retailers' refusal to participate in a
voluntary program, the IWMA eventually adopted a mandatory take back
ordinance and now all retailers are participating in the program.
As far as we know, in California only the 2 Wal-Marts and 2 Home
Depots in San Luis Obispo County take back fluorescent tubes and
bulbs each and every day.

Recognizing the inevitable need for a mandatory take back provision
from the outset offers significant overall program efficiencies
because it:

• Eliminates the need for a potentially costly and inefficient
Third Party Organization
• Greatly simplifies the task of public education
• Expedites Implementation of a State-Wide Program

Under a mandatory take back scenario, the normal business
relationships between retailers and manufacturers can and will most
efficiently and appropriately handle the necessary cost sharing for
meeting this responsibility. There is no need to create a new third
party organization to "manage" the program. In addition, there is
no need to create a third party funding sources such as utilities.

Similarly, with all retailers participating, the task of public
education is greatly simplified because you have a very clear,
unequivocal message: "Take-It-Back!". This message could be
required on the labeling of all fluorescent tubes and bulbs and as
part of any promotional advertising by the utilities for purchasing
of CFLs.

Since February 2006, DTSC regulations have made it illegal for people
to dispose of fluorescent tubes and bulbs in their waste.
Unfortunately during the last two years, effective, cost-efficient,
and convenient programs have not been implemented throughout
California. To recommend a voluntary program, managed by a third
party organization that would need to be created and funded by the
electric utilities will further delay the implementation of an
effective program.

A simple and effective model has already been used in California, the
Rechargeable Battery Recycling Act of 2006" (A.B. 1125). This
legislation requires any retailer who sells rechargeable batteries to
take them back from the public. Similar legislation for fluorescent
tubes and bulbs would result in the expedient implementation of an
effective, cost-efficient, and convenient state-wide program.

The IWMA greatly appreciates your careful consideration of our


William Worrell
San Diego, California

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