E-Cycles Advisory Committee - March 6, 2012 meeting

From: PICKERELL Loretta

Sent: Thu Mar 08 08:20:53 2012

To: 'Bailey Payne'; 'Becky Jarvis'; 'Betty Patton'; 'Craig Lorch'; 'Erik Stromquist'; 'Gail Zuro'; 'Jason Linnell '; 'Jeff Kuypers'; 'Jim Craven'; 'Lee Fortier'; 'Mary Jacques'; 'Michael Moss'; 'Mike Watson'; 'Scott Klag'; 'Tim Rocak'

Cc: ' dkumar@warren-news.com'; 'aeudis@wm.com'; 'bhenry@bentonhabitat.org'; 'bpeterson@universalrecyclers.com'; 'cmanley@sanyotv.com'; 'cspivey@ecsrefining.com'; 'ddiaz@universalrecyclers.com'; 'mrmnj@hotmail.com'; 'paulpony4@hotmail.com'; 'tirvine@TotalReclaim.com'; 'Tricia Conroy '; 'vernamr@us.panasonic.com'; 'walcorn@ce.org'; 'katt.fretwell@tek.com'; 'mrmnj@hotmail.com'; 'tirvine@TotalReclaim.com'; 'ddiaz@universalrecyclers.com'; 'gregg.chason@pnf-usa.com'; PERRY Marylou; PALMERI Jordan; PICKERELL Loretta

Subject: E-Cycles Advisory Committee - March 6, 2012 meeting

Importance: Normal

Advisory committee and interested parties -

At yesterday’s E-Cycles fee rulemaking advisory committee meeting we discussed proposed concepts for the registration fee rule with a goal of proposing rules for public comment on April 1. As discussed, we are inviting additional comment particularly on (a) the proposed fee structure to generate the target revenue for each year and (b) the process for setting, reviewing and revising target revenue to approximately match program costs. Please send comments to the group above or to Mary Lou Perry and me ASAP but no later than March 16, so we can consider them in drafting proposed rules.

The rule concepts proposed for discussion are as follows:

a) Fee model #2, Tier structure B, with a $35K cap and a minimum fee of $200.

b) Process for target revenue to be put in the rules:

(i) Target revenue will be the total amount needed to approximately match DEQ’s costs in implementing the E-Cycles program (ORS 459A.305-355).

(ii) Target revenue for 2012 is $415,000.

(iii) Target revenue for 2013 is $435,000

· Includes estimated costs for adding printers and registering printer manufacturers beginning in 2013 (for plans to begin collecting in 2015).

· Increased costs will be offset at least in part by registration fees for printer manufacturers

(iv) Require DEQ to report annually its program budget, revenue and expenditures

(v) Authorize DEQ to revise target revenue after consultation with an advisory workgroup consisting of representatives of manufacturers and other designated stakeholders.

(vi) Limit annual increases in target revenue to 10% without a rule change. Exclude recovery of unpaid fees and adding new products from the limit.

· Limit would include mandated cost increases (e.g., health insurance, cost-of-living increases) that cannot be offset by paring other program costs.

· Limit would also include costs of building the registration database (project is currently on hold to allow time to explore program changes that would reduce DEQ’s registration functions).

Questions:

1. What comments, suggestions or concerns do you have about the proposed fee model or process for setting/revising target revenue?

2. Does the target revenue process strike the right balance considering costs to implement, flexibility, cost controls, stakeholder involvement and oversight?

3. What changes do you suggest?

Presentations from the advisory committee meetings are posted on the E-Cycles rulemaking webpage: http://www.deq.state.or.us/lq/ecycle/rulemaking.htm. We have also added a new document, "Units and Price/Unit by Fee Tier," showing the average number of units and price/unit in each fee tier for the existing and proposed fee model to help address questions that came up at the meeting.

Please feel free to contact Jordan Palmeri if you have questions or want to discuss the fee models, palmeri.jordan@deq.state.or.us, (503) 229-6766. You may also contact me about the target revenue process and other issues. I will be out of the office through next Wednesday, 3/14, but will be checking email and voice mail periodically and will get back to you. You can also contact Mary Lou Perry, perry.marylou@deq.state.or.us or 503-229-5731.

We may also try to schedule a advisory committee conference call for late March.

Again, we appreciate your time, effort, and expertise in developing this registration fee proposal.

Loretta

Loretta Pickerell, Manager

Solid Waste Policy and Program Development

Oregon Department of Environmental Quality

811 SW Sixth Ave.

Portland, OR 97204

503-229-5808, fax 503-229-6977

pickerell.loretta@deq.state.or.us