One of the largest challenges the collection box
operators are currently contending with are the plethora of upcoming city regulations.
Goodwill Industries, and to a lesser extent Salvation Army as well have been
actively lobbying various city officials in a number of cities for some time
now to paint collection boxes as something unnecessary that needs to be banned
from our cities.
The donation box concept is based on convenience on one end
and the ever increasing demand for used clothing on the domestic and
international markets on the other end. Campus California’s donation boxes
provide the public with an easy and convenient way of donating unwanted items
that can be (fairly) easily delivered to various markets, effectively returning
them into use as ready products (wearable clothing) or industrial feedstock
(rags, shredded/unusable pieces) materials that would otherwise be landfilled.
The periodically recurring complaint about “taking away” donations from other
charities (read: Goodwill) is baseless once one looks on the data from the EPA
and a number of waste characterization studies. These show that not only we are
recycling only about 15 % of all textiles disposed in the US, but the overall
volume of textiles in the waste stream is increasing as well, topping 13
million tons in 2010.
In short, the focus should be on increasing public
participation in the recycling programs that are out there to get people to
recycle more since this is clearly not a zero sum game with the textile
diversion numbers being where they are.
There are a few bad apples in this industry, just as in any
other, but not every solar company is called Solyndra! The fact is that you can
usually tell a sensible regulation by the support from all sides. Just as AB
918, setting disclosure requirements on collection boxes, had the support of
all parties, despite being introduced and sponsored by Goodwill. On the other
hand, the Sacramento city regulation from 2010 had the opposition of all
collection box operators in the city, but the support of the Goodwill CEO and
one of the highest paid lobbyists in the state presenting himself as “just a
regular property owner”. As a result, there is widespread compliance with the
state bill, at least amongst the honest box operators; but no legally placed
boxes in Sacramento.
Sensible regulations governing the operating of textile
collection boxes can be helpful for a city. Small enough permit fees and simple
rules encourage compliance, help the city to maintain oversight and make
enforcement easier. Drop off locations can get registered, so if any complaint
from the public comes in, the code enforcement knows exactly who does the box
belong to. In fact one of the sources of frustration for operators that try to
do the right thing is that all boxes just get thrown into the same bag, when
there are a number of players on the field and not all of them care the same
way for the boxes or any regulations for that matter.
Understandably the cities are also looking at boxes as a
possible revenue stream in the form of permit and other fees, but sometimes they get
a little carried away. Imposing a $2-3 000 fee for a single location, as
some places require, and a sufficiently complicated approval process to back
the fee up (sometimes with public hearings and planning commission approvals)
makes it impossible for the operator to actually comply with the rules and make
any surplus at the same time. The result is that the unscrupulous companies
will drop their boxes anyway, the city has to pay for enforcement from other
sources or not enforce the violations (just ask Richmond how much luck they had
in getting rid of the blue clothing boxes) and the people who wanted to comply
with the rules lose out on the market.
Clothing donation boxes are one of the few recycling
activities that thrives only in full public view. This causes
unease in some public officials; zoning administrators and others who wish to
design every aspect of our cities to the last minute detail. A drop off box
that “pops up” from one day to another (well, what does it take to place one?
Put it on a truck and place it on a site, done. Really not a big project!) and
can be moved away just as easily introduces almost an element of chaos, or
life, or change. Cities often consider recycling to be dirty and unsightly and
something to be hidden, tucked away in industrial parks, or maybe in the back
parking lots of large shopping centers where many of the bottle-and-can
buy-back centers are being pushed.
We believe for the ideas of reuse and recycling to
be firmly sitting on people’s minds and not slipping to the back burner;
recycling activities must remain visible, right in front of our eyes as well,
not hidden away.