Battery Stewardship Program Rulemaking (Informal Comment Period)

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Comment From: Julie Gilbertson (Julie Gilbertson)

1/31/25 @ 5:09 PM

The City of Vancouver contracts with a private collector to offer curbside battery pickup as part of resident's garbage and recycling service cost. As this cost is embedded in the cost of service it is difficult to uncouple the cost of this add-on se...↓

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Comment From: Washington Refuse & Recycling ... (India Brine)

1/31/25 @ 3:29 PM

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Comment From: Ridwell (Caleb Weaver)

1/31/25 @ 3:13 PM

To Whom it May Concern:

We appreciate the opportunity to provide comments on the Department of Ecology's proposed rulemaking for Chapter 173-905 WAC - Battery Stewardship Program. Ridwell fully supports Extended Producer Responsibility (EPR) and ste...↓wardship programs as effective frameworks for diverting hard-to-recycle materials from landfills and ensuring transparency in recycling.

Our comments focus on discussions from the December 16, 2024, Battery Stewardship Rulemaking meeting regarding disposal using recycling services operating outside of a battery stewardship program.

As an alternative waste diversion service that enables households to easily get reusable and recyclable items not included in curbside recycling to nonprofits and specialty recyclers, Ridwell has helped our customers responsibly recycle nearly 1 million pounds of household batteries. Operating as a permitted Common Carrier with the Washington Utilities and Transportation Commission (UTC), Ridwell's service extends the reach of drop-off recycling opportunities by transporting designated reusable and recyclable materials for households unable or unwilling to utilize drop-off sites. Our voluntary, supplemental alternative waste diversion service aligns with the new battery stewardship program and supports the success of the Battery Stewardship Organization (BSO) by extending the reach of the BSO's drop-off-focused efforts to households that might otherwise not participate.

Ridwell currently works directly with accredited specialty recycling companies like Call2Recycle, safely delivering our customers' batteries for recycling, and looks forward to working directly with the BSO to support the success of this program by providing Washington residents the opportunity to efficiently and safely get their household batteries into the BSO program without having to leave home. We are prepared to comply with all applicable safety and reporting requirements and share the belief that anyone involved in the recycling of batteries in the state should be doing so in a safe and environmentally responsible manner.

For these reasons, we support the development of rules clarifying that any collection activity outside the formal BSO program be appropriately reported and that any applicable documentation and handling standards must be followed. Accurate reporting is vital for transparency, accountability, and maintaining consistency in data collection across all recycling services, whether operating within or outside of the BSO plan.

In conclusion, we commend the Department's commitment to advancing battery stewardship in Washington State. Clear reporting protocols and innovative collection methods will expand access to recycling while ensuring accountability and responsible material management. We look forward to continued collaboration to achieve the program's goals and promote sustainable solutions.

Thank you again for the opportunity to provide comments.

Sincerely,

Caleb Weaver
Vice President of Public Affairs
Ridwell

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Comment From: City of Tacoma, Environmental ... (Preston Peck)

1/31/25 @ 1:39 PM

Hi,

I'm listing below some of the City of Tacoma's demonstrable costs associated with collecting and processing batteries covered under the bill at our Household Hazardous Waste Facility. It should be noted that our current agreement with SBK Recycl...↓

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Comment From: Clark County Solid Waste & Rec... (Bethanie Velasco)

1/30/25 @ 5:00 PM

Education and Outreach Requirements
b. The development and distribution of the education and outreach materials that will be used to inform consumers about the restriction on the disposal of covered batteries and provide information on how to proper...↓

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Comment From: City of Federal Way (Brittany McGrath)

1/30/25 @ 1:41 PM

This is Britt McGrath – Public Education and Outreach Coordinator on behalf of the City of Federal Way. I will be providing a cost breakdown on the demonstrable costs of education and outreach and recycling contractor costs for the battery recycling ...↓

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Comment From: Cirba Solutions (Richard Abramowitz)

1/30/25 @ 8:34 AM

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Comment From: Call2Recycle, Inc. (Carin Stuart)

1/30/25 @ 7:56 AM

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Comment From: Critical Materials Recovery, L... (Jesse McCullough)

1/23/25 @ 2:33 PM

Hello,

I operate an alkaline battery recycling facility. I believe my company's perspective can be helpful for the implementation of this program.

First, I want to voice confidence in Call2Recycle (C2R) as a potential stewardship organization to...↓

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Comment From: Redwood Materials (Dan Zotos)

1/23/25 @ 10:20 AM

Please see attached comments regarding outside organizations collecting batteries in addition to BSO.

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Comment From: Tatum Flowers

12/18/24 @ 6:54 PM

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Comment From: Sequim Electronics (Becky Northaven)

12/16/24 @ 11:28 AM

In (i) of the Education and Outreach-Plan Contents, you say: "(i) Sample materials to make retailers aware of their obligation to sell only covered batteries and battery-containing products of producers participating in an approved plan;"

Our concer...↓

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Comment From: Redwood Materials (Dan Zotos)

12/09/24 @ 5:42 PM

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Comment From: Susan Bernard

12/09/24 @ 1:40 PM

Please see attached comments from BCI.

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Comment From: Call2Recycle, Inc. (Carin Stuart)

12/09/24 @ 11:07 AM

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Comment From: Cirba Solutions (Richard Abramowitz)

11/20/24 @ 11:23 AM

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Comment From: Brian Hughes

11/12/24 @ 10:08 PM

Right to repair - right to build - right to use what you own how you see fit

Please do not pass laws or rules disallowing private purchase, sale, reuse and repurposing, and reconfiguration of used, salvage, and 2nd life EV battery packs and sub comp...↓

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Comment From: Christopher Pfaff

10/28/24 @ 2:33 PM

Reporting (1)(d) - it would be appreciated to identify if and where fire damaged batteries can be discarded, as these create additional hazards.

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Comment From: Clark County (Jess Fischberg)

10/16/24 @ 2:54 PM

(1) There is concern about the amount of time between the plan due date and the implementation date (only 6 months). There's 1 month for public comment, plus 6 months for Ecology review, and potentially longer due to the exception given to newly form...↓

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Comment From: Pacific Power Batteries (Steve Ahmann)

10/15/24 @ 2:49 PM

To the Commission for Battery Stewardship and Recycling Oct. 15, 2024
Dear Commission Members,
We are a family-owned battery retailer and wholesaler of many different types of batteries and battery-related products. We have been selling batteries...↓ to the public, commerce, and to resellers of all types batteries for 39 years, employing 30+ employees between the 7 retail stores here in WA. Our website is www.pacificpowerbatteries.com . We have lots of questions that have not been answered or even addressed in a language that we can understand. Your document is incredibly complicated, yet leaves many questions. For example:
1. WHO might or might not need to BE a "Battery Steward?" Specifically, who will need to pay a one-time fee of $50k plus an ongoing (undetermined) annual cost? But wait! We have more questions.
2. Why are you trying to penalize those of us who are already promoting battery recycling from the general public as well as those to whom we sell batteries? This program is huge! Why not promote and reward battery recycling rather than create a bureaucracy and complex set of rules that controls and taxes the collectors and manufacturers? Why would we be motivated any longer to accept batteries for recycling from the general public if it's costly and burdensome?
3. What about companies (like ours) that buy "black box" (no label other than the required haz-mat warnings) auto, marine, and commercial lead-acid (including AGM) batteries from various international manufacturers and retail them all under our own labels? Some of our auto batteries are made in The USA and some are from Korea, Colombia, The Philippines and all over. We apply our own trademark-registered names so the customer knows where thy bought them. We do not necessarily represent any particular manufacturer and neither do Interstate Batteries, Auto Zone, or Costco for that matter. Many battery manufacturers don't make every group size of automotive battery so they buy them from various other sources (often from Korea, Mexico, or China).
4. Many of today's lithium-ion marine, 12v, BCI sized auto and marine as well as golf cart sized (48v) batteries are made in China but assembled with Battery Maintenance Systems here in the USA. So who's the "battery steward" there? What about the Chinese battery manufacturers who are selling and shipping batteries directly to their customers through Facebook or Instagram? Who is the "Battery Steward" there? You don't seem to have anything in place for online, direct marketers. We don't want to be the only business selling batteries to WA residents who get stuck with having to comply with this program.
5. Currently, Amazon is selling automotive and marine lead-acid batteries from their website and is not compliant with WA laws regarding the one-for-one core requirements. Are you going to continue to allow that? Will all of your laws be the same for Amazon as every other vendor of various batteries?
6. My wife, son and I have attended your webinar held back in June or July and found it to be difficult (if not impossible) to ask questions for clarification, understand who represents what, and why we are not part of a normal or even a Zoom conversation? It's not an open discussion if we are required to submit questions in writing during the seminar. A conference call like the ones that you have hosted is like a meeting in a dark room: we can't identify who may or may not even be in the battery business. Most people don't have any idea how batteries are bought and sold today.
7. We do not believe that submitting our questions or concerns by texting in the comments area during the webinar is effective. By the time a question can be typed, the conversation has moved along. We have plenty of questions and are not going to start asking questions to a group that has probably already covered the topic.
8. We feel as though we, as small business owners, are being forced into a program that will definitely affect our livelihood as small business owners. Why do you not contact us and include us in how programs currently work?
9. We need to talk with someone on the commission who can answer our questions (while on a recorded line) and understand some of our concerns.
10. During your "open comment time period" we have been unable to copy and paste any of the pdf regulations for referencing questions. This is unfair because it takes a lot of time to refer to the subjects of our questions. When I started to write my questions, I found it difficult to refer to a specific sentence or paragraph without the ability to copy, paste and follow up with a question. We need the read-along copy to be copy and paste-able.
11. You seem to be ignoring the huge impact to small, brick and mortar businesses like our own. We have been battery specialists since 1985 and believe that you are too close to closing the comment time before considering our concerns. Therefore, we request:
12. Our questions be answered by someone in person; That the deadline for comments and questions be extended and that we have a seat at the table. We would also like to see some other battery specialists, like us, involved in this process. I can round up a few.
13. That we not be required to ask our questions in an open forum only. Some of our questions would be considered "basic" and require follow up questions such as "why is that?" And "have you considered" and "how will this apply to those businesses like ours that buy from our own buying group?" "What about those batteries that we are wholesaling to our smaller resellers in small communities?"
14. We are deeply concerned that the costs of your regulations will adversely affect us if we cannot pass the costs of "battery stewardship" and administrative costs on to our customers as a line item. Why would you not allow the cost of battery stewardship or recycling be passed along to the customers? Are you thinking that we, as a small, brick and mortar (and online) vendor of batteries have lots of extra profits in some big slush account from which we can access to pay for the added costs?
15. You may not understand how batteries are bought and sold in today's one and two-step marketplaces, re-branding markets, and how direct suppliers and marketers AND the likes of Amazon and Walmart sell batteries. Perhaps you aren't thinking of the small wholesalers who buy low somewhere in Nebraska or Delaware and sell either to other retailers or end-users. We believe that the out-of-state small and large on-line retailers will not pay any of their fair share.
16. Please don't count us out. We are a family-owned battery retailer and wholesaler business since 1985. We demand a voice. I hope that we are not "late to the party" with respect to this process but we want to help you simplify this process, make it more understandable, and be allowed to pass the costs of this weighty program on to the consumers who buy batteries from ALL marketplaces (online and from retail establishments). We are busy running our business but you have our attention and we can also bring other battery specialists like ourselves to help. We comply with each and every law and ordinance already and fear that this "freight train program" will put us out of business if we don't have some real input.
With best regards,
Pacific Power Batteries
Steve Ahmann
President
(425) 259-9260 office
(425) 238-60004 cell
sahmann@pacificpowerbatteries.com

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Comment From: Call2Recycle, Inc. (Carin Stuart)

10/15/24 @ 10:44 AM

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Comment From: Cirba Solutions (Alex Remy)

10/14/24 @ 8:21 AM

Cirba Solutions comments on draft language.

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Comment From: Redwood Materials (Tricia Dutcher)

10/11/24 @ 1:25 PM

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Comment From: Stan Moffett

9/16/24 @ 4:21 PM

I am very much in favor of this program. Will certainly increase costs of batteries, bit that's OK.
We need to do more to ensure that batteries don't end up on our landfills or alongside our roads.
I would also like to see a statewide program for alu...↓

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Comment From: Clark County (Jess Fischberg)

7/31/24 @ 6:32 PM

(1) Is 555.070 saying that local government is responsible for the batttery disposal cost at HHW events? Or that the stewardship organization will cover the HHW event disposal costs?
(2) "Special location" recycling suggestion: Homeless shelters / ai...↓

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Comment From: Cirba Solutions (Danielle Spalding)

7/30/24 @ 7:20 AM

Please find full comments in attached file. Thank you!

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Comment From: Redwood Materials (Don Tatro)

7/16/24 @ 8:57 AM

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Comment From: Clark County Public Health (Jess Fischberg)

5/31/24 @ 2:45 PM

The definitions/language in the RCW is understandable and clear. I have noted that Oregon is calling rechargeable batteries "secondary" batteries, but I don't think that is as understandable as "rechargeable."

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Comment From: Redwood Materials (Don Tatro)

5/31/24 @ 2:28 PM

Please see uploaded letter for comments.

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Comment From: Denver Brown

5/31/24 @ 9:29 AM

Dear Chris Fredley, Megan Warfield, and the Washington State Department of Ecology,

Before I begin, I would like to express my support for this program. I am in avid support because I can already see how a significant step towards managing battery w...↓aste can also contribute to the larger goal of protecting our environment. When batteries are improperly disposed they can leak dangerous chemicals, including battery acid, into the environment, which can cause severe damage. I hope this program and new law will be an effective solution to battery waste in Washington State and will serve as a role model for the rest of the country to follow.

Firstly, I would like to talk about the accessibility of these collection sites, as the way they are described might be impractical. As stated in the meeting, for portable batteries, there must be a collection site within a 15-mile radius for 95% of WA residents, and for medium format batteries, there must be 25 permanent collection sites and one site in each county with more than 200,000 people. This could become illogical, especially for collection sites handling portable batteries in less populated rural areas, as establishing these collection sites would be expensive, and not as useful because of the lack of people around them. Solutions to this could vary, but my suggestion would be to think about implementing mobile collection units, which could help serve these areas with fewer people without the need for a permanent collection site, therefore being more efficient and cutting down costs.

Speaking of costs, this program seems like it will be quite expensive, especially with all the collection site requirements. I am curious how costs will be covered in areas that aren't as profitable. Also, relying on producers alone may not entirely be sustainable. A downside to relying on producers only to fund this program might result in an increase in battery prices for customers. If possible, a more balanced and sustainable source of funding could come from the state or other places such as private partnerships. While this might not be the right thing for me to write feedback on, I couldn't help but comment my thoughts on this, as it caught my attention.

Ending the topic of collection sites, I would like to talk about the requirement of terminating non-compliant collection sites. While it is important to make sure collection sites are following the correct protocols and keeping the environment safe, this could lead to a disruption in service as well as an inconvenience for residents who rely on that specific collection site. There are other possible approaches to this instead of termination, which may include receiving additional resources from the state or other institutions or training more operators/authorized personnel for that collection site. This approach will eliminate the inconvenience for residents in surrounding areas needing to dispose of batteries and will also be more effective and ensure continuity in service.

Lastly, I would like to mention the inclusion of all battery types, more specifically, the batteries used in medical devices and non-removable batteries. I know that there would be some difficulties in recycling and properly managing batteries that aren't listed in the covered batteries, but if this program were to include all battery types, that would greatly improve the environment. This wouldn't need to happen right away, but it would be a good idea to implement in the future.

Thank you again for all the work you guys do, and I appreciate your time for considering my feedback. I hope together we can continue to better the environment inside of Washington State.

Sincerely,
Denver Brown