From: PICKERELL Loretta
Sent: Thu Apr 05 12:53:38 2012
To: PICKERELL Loretta; MASON Palmer
Cc: WILES Wendy
Subject: RE: Questions on Senate Bill 82
Importance: Normal
Palmer – should add – we’ll get you a draft response.
Loretta
From: PICKERELL Loretta
Sent: Thursday, April 05, 2012 12:50 PM
To: MASON Palmer
Cc: WILES Wendy
Subject: RE: Questions on Senate Bill 82
Palmer –
Reducing fees for smaller manufacturers is one issue we expect to be addressed in comments (including internal) and will consider before recommending rules to the EQC.
Lowering fees for the smallest mfrs would not require paring program costs. The way the fee structure works, we distribute the revenue need (identified in draft rules) among manufactures, so reducing fees for the smallest mfrs means larger mfrs pay more. Example, if the 110-120 mfrs in Tier 6 (lowest) pay $200/year, the remaining 50-60 mfrs in the higher Tiers 1-5 collectively pay between $22,000 and $24,000 less. Reducing smallest mfr fees by 25% would mean larger mfrs would pay between $5,500 and $6,000 more/year.
The committee discussed fees for the smallest mfrs and thought the $200 fee was reasonable, including a small mfr rep (who may have moved up a tier in 2012). One of the small mfr reps did not weigh in on fee amounts. We also asked the committee to consider whether to eliminate fees for tiny mfrs (e.g., less and 50-100 units/year) and didn’t hear any support for that – but will likely consider it again in reviewing comments and drafting recommendations for final rules.
The small mfr rep that did not weigh in was upset that DEQ does not more aggressively go after more of the tiny mfrs who don’t register – and that has been a consideration in our suggesting we eliminate fees for the tiny mfrs. It costs more to go after them than we generate in revenue (likely even w/a $200 fee) – and we will likely hear during comment that there are many more tiny mfrs selling CEDs in Oregon than we have registered. Jim Craven was getting there in his observation that the larger mfrs are paying for most of the program – so we should cut those costs vs. worrying about the small change from the smallest mfrs.
Loretta
From: MASON Palmer
Sent: Thursday, April 05, 2012 12:04 PM
To: PICKERELL Loretta
Cc: WILES Wendy; MASON Palmer
Subject: FW: Questions on Senate Bill 82
Loretta-
We need to develop a response. I would keep it succinct and to the point. We should mention that the program operates with fewer FTEs now. Also, and I realize this complicates the rulemaking, but how much would a $50 reduction (or a $25 reduction) in the small manufacturer fee really amount to? Could it possibly be absorbed if we streamlined our program costs further? I know that this is asking a lot but could be worth thinking about.
Palmer
Palmer Mason
Interim Government Relations Manager
Oregon Department of Environmental Quality
mason.palmer@deq.state.or.us
503.229.6800
From: Rep Sprenger [mailto:rep.sherriesprenger@state.or.us]
Sent: Thursday, April 05, 2012 8:13 AM
To: palmer.mason@state.or.us
Subject: FW: Questions on Senate Bill 82
Good morning,
A few months ago you were very helpful in answering our constituent's questions regarding the E-Cycyles Program. He is now registered but contacted our office again with a few more questions; specifically if there is any exemption or reduction to the fees he now pays. Any assistance you could offer would be greatly appreciated. Thank you!
Rachel Kloor
Legislative Aide
From: Paul's Computer Repair [paul@paulrepair.com]
Sent: Friday, March 30, 2012 6:28 PM
To: Rep Sprenger
Subject: RE: Questions on Senate Bill 82
Hi Rachel & Rep. Sprenger,
I want to thank you and Rep. Sprenger's Office for giving me the info on the e-Cycles Program. However, there is a change pending, and it will significantly increase the amount I will have to pay.
I am now part of the program, paying $40 a year because my business is small and the amount of computers I "manufacture" is very small.
I am sure you will be shocked to hear that the e-Cycles administrative program has found that it cannot sustain itself and needs to raise its rates, before any money has even been generated.
So now there is a proposal to raise the rates to $200. I can understand and accept $40 a year for the low volume that I produce. But $200 is a large fee for the small amount of business that I do with new computer sales.
As a small computer business I build about 12 computers a year, approximately 1 a month. That means that I would have to pay a TAX of almost $17 per computer just to have the privilege of selling computers in Oregon.
A couple important points, as a local computer repair/sales business I give very personal service and make sure the computers I sell are working beyond their years expectancy. I also choose the highest quality of parts, unlike the big companies who use inferior quality parts because they are cheaper and they make more money on them.
The bottom line is that my computers will last longer than larger companies and I am sure I will be paying much more per computer as the big guys, because of the huge quantity they are selling.
When a customer deals with a small local company, it is much more likely that the computer will last longer and not enter the recycle program as soon as the big guys. Also I can reuse many of the parts of an old computer and resell it as a used refurbished system, avoiding the landfill or recycling. This is something none of the larger companies do.
I have been in business for 4 years, and I have not had one computer recycled or taken out of commission. I know and take care of each customer's computer that I sell.
I am going to email my comments and suggestions to the committee that is trying to change this fee.
Could your office please look into this and see if there is anything you can do from your end to make some sort of exception or reduction of fee for the lower tier of small computer businesses. This is just another tax to hurt the small businesses in our local community and pay for more bureaucracy and administrative programs.
Thank you,
Paul Aziz
From: Rep Sprenger [mailto:rep.sherriesprenger@state.or.us]
Sent: Monday, November 07, 2011 9:09 AM
To: Paul's Computer Repair
Subject: RE: Questions on Senate Bill 82
Paul,
Thank you for contacting our office about this policy. I will pass your message along to Rep. Sprenger and get to work trying to answer your questions. Please let me know if you have any further questions or concerns and I will follow up with you in a few days.
Rachel Kloor
Legislative Aide | Rep. Sherrie Sprenger
503.986.1417
http://www.leg.state.or.us/sprenger/
From: Paul's Computer Repair [mailto:paul@paulrepair.com]
Sent: Friday, November 04, 2011 10:45 PM
To: Rep Sprenger
Subject: Questions on Senate Bill 82
Hi Sherrie,
I know you are in the House, but I was wondering if you could have someone on your staff look into this for me.
I just found out about this new law, SB 82, for the Oregon E-cycles Program and how it affects small computer businesses like mine.
I am all for recycling and this all sounds nice and green and wonderful for our State. But there is a real problem that I do not see addressed, and is going to put people like me, out of business.
From what I gather, the bill says Retailers are responsible for putting the ecycle information into the customers hands, no problem, we actually have done that for a long time, and even taken customer's old stuff to have it recycled as a service.
It also states that all computer towers, laptops, screens, have to be State Approved Manufacturers to be sold in the state, ok, that is getting a little odd.
The reason that is odd, is that small shops like mine, make money off of buying higher quality parts and assembling computers that are much better than the junk Dell and HP put out. I sell a couple systems a month. They do not have any manufacturer name on them, because the parts are from many manufacturers.
So the problem comes in, there is no approved manufacturer name on the computer. I built it. Some companies put their name on the system, I just have never done that but I have considered it.
From reading this bill, it also appears that manufacturers have to pay for the ecycles program, which would kill my business.
What I gather from this program, the type of computer system I currently make and sell is now illegal.
If I wanted to make it legal, I would have to become a manufacturer and pay big bucks to be approved and go to the ecycle program.
This is insane, but maybe I am missing something. Obviously this was written by environmentalists, and small computer businesses were never even talked to, because selling custom systems is a big part of our business. This is why people pay a little more to get a better computer from Paul's shop, and get the service and dependability.
Please let me know if you could look into this.
Thank you,
Paul Aziz
PS, this is the link to the program I am going off of:
http://www.deq.state.or.us/lq/ecycle/retailers/index.htm
Paul's Computer Repair Services - Serving the Lebanon & Sweet Home Area
541-570-1632