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Description
My overall comment is that the proposal should be "skinnied down" as much as possible to avoid unnecessary opposition. The basic premise should be manufacturer's responsibility and no where should the proposal specify how the manufacturer will generate the revenue necessary to support the program except for the authority of the TPO to charge fees. We strongly support the "opt out" provision for manufacturers who choose to create an independent collection program. Further, the manufacturer's assigned responsibility should be based on return share as well as the orphan waste. Following are some specific comments by section. Thank you for the opportunity to comment. Section 1: • The less said the less to fight over. Delete unnecessary verbiage. • Paragraph 6 - Delete all reference to a fee and just simply say that the manufacturers shall be responsible for the cost of the program. Section 2: • The task force agreed to exempt retailers and manufacturer's from the certified collection registration. This did not get included in the draft. A suggestion is to require retailers and manufacturers to include this information on their assigned responsibility plan. This avoids a second registration. • Collection location should not be worded in a way that would prohibit retailers from collecting products because the location is not as convenient as curbside. • We support the small business exemption. • A CPU is a chip and not equipment. This is ...
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