American Retroworks Inc. PO 1010 Middlebury VT 05753
www.retroworks.comMarch 2, 2010Mr. Allen HershkowitzNatural Resources Defense Council40 West 20th StreetNew York, NY 10011
Dear Mr. Hershkowitz,As a lifelong environmentalist, former Peace Corps volunteer, Recycling Director for Massachusetts DEP (1992-98), and career recycler, let me thank Natural ResourcesDefense Council for your service protecting the environment. We stand together on thedisposal and extraction subsidies, and reform of the General Mining Act of 1872.NRDC has recently begun to take a stand on the export of “e-waste”. As founder of a fair trade electronics export organization, I welcome your reputable organization to thedebate. I trust you will take the following comments in the right way.
Basel Convention does not ban, nor should it, the export of used monitors, laptops,computers, etc. for repair and refurbishment. This is explicitly described(including Cathode Ray Tubes) under Annex IX of the Basel Convention (B1110).While some NGOs argued against this provision to the Secretariat, countries withcontract manufacturing – ie the factories which originally made units – successfullymade the case that reuse and refurbishment is not “waste”.
Some NGOs have seriously misrepresented the contract manufacturing capacityof the CRT refurbishing plants in particular. NRDC should carefully consider theclaims that “the majority of the tubes are burned, dumped, or disassembled toextract reusable material.” I have travelled across Asia and the Mideast, and cantell you that even the worst exporters are forced to ship a majority of refurbishableCRTs in order to get repeat business, because there is no economic force to burnCRT monitors etc. I would like to show you film.
The “Prohibition” on export has unintended consequences. There are 3 billionpeople earning 3 thousand dollars per year, and for the past decade their rate of access to the internet is 10x the USA’s. They will not stop getting onto the web,nor should we want them to.You should not take my word for any of this. I can provide NRDC with invitations to tour the factories which originally manufactured and assembled monitors from newly mintedCRTs, which now refurbish the CRTs under the identical factory conditions that your old