Comment on FR Doc # 2012-02767

Response to questions posed in Notice-FAS-2011-01: 1. The reverse logistics process of reconditioning and returning refurbished equipment to the customer in a cost effective, efficient manner is feasible but will vary based upon the specific customer security and functionality parameters. Time between pick-up and return will vary based on quantity and quality of material. ERI can accept obsolete electronics, wipe the hard drives, remove old asset tags, verify the cell are functionality within the hard drive, clean and recondition units in a cost-effective manner, and redeploy to a designated location/s in accordance with customer specifications. 2. There is no minimum but consolidated quantity shipments are warranted for efficiency. To maximize efficiencies, it is best to transport 20,000 lbs. or more of material per truckload. However, it is feasible to transport less than full truckloads of material if warranted or needed. 3. Yes, providing refurbishment as a service fits into a viable business model. 4. Fees charged for refurbished items will vary greatly based on customer reconditioning specifics, security requirements and redeployment requirements. A cost effective estimate would be in the range between 20-25% of the cost of new equipment. 5. Equipment that has failed will be sent for environmentally proper recycling at the ERI facility at which the material was received. ERI will handle the recycling process internally at our R2 and e-Stewards certified facilities across the U.S. All ERI facilities are both R2 and e-Stewards certified. 6. ERI would be responsible for the disposition of equipment that cannot be refurbished. For material that cannot be refurbished, ERI will develop a cost-effective program with the customer to provide for final disposition of the material. 7. The government should require that firms providing refurbishment services be R2 and/or e-Stewards certified. Many firms that special in refurbishment are already certified.