Friday, September 21, 2012

Local Government Transition to EPR for Packaging - PART 3 of 3. Maintaining High Service Levels

PART 3.  Maintaining High Service Levels

Guest Blog by Raymond Gaudart & Alan Stanley

Raymond is the former Director of Environmental Services for the Regional District of Kootenay Boundary, a Director of the Recycling Council of British Columbia, and a recently retired board member of Product Policy Institute.  Alan is Director of Environmental Services for the Regional District of Kootenay Boundary and a Director and Past Chair of the Recycling Council of British Columbia.

Perhaps the most pressing concern for local governments currently providing packaging and printed paper recycling services is how they will guarantee uninterrupted service at the same levels that their citizens currently enjoy.

Among the various responses to this issue is some local governments requesting that the provincial government “force” stewards to use existing local government recycling services. An example of this is a recent City of Vancouver resolution demanding that the province “amend the Recycling Regulation to require that where local governments choose to provide recycling services to stewardship organizations that municipalities be fully compensated for those services”. Another example is a recommendation of a Union of BC Municipalities packaging and printed paper recycling working group that suggests a “right of first refusal” for local government for the provision of stewardship services.

A common theme in discussions regarding local government delivery of EPR programs is that some local government representatives feel that their programs are well established and effective with a touch of conceit that industry could not possibly run the programs as well as local government. With an issue as complex as this, there are numerous sub-themes including environmental performance, protection of turf, loss of control, fears of job losses, accountability etc. It is imprudent to pass judgement on the legitimacy of these concerns as each jurisdiction has different challenges.

Of great concern to the many jurisdictions, including RDKB, which sees the move to industry operated packaging and printed paper recycling as a rare and precious opportunity to repurpose their assets to other significant diversion programs such as organics and construction and demolition waste is that the demands from some local governments to remain “in the driver’s seat” may result in an ineffective hybrid program, where local government calls the shots on program design and delivery while industry pays. This would be contrary to the spirit of the recycling regulation that at its core gives stewards the freedom to design and deliver the most environmentally and economically effective programs.

Requiring the stewards to use existing, or legacy programs may severely hobble the design and operation of a province–wide program and simply replicate the patchwork situation that currently exists. A review of the Multi Materials BC report on the current programs across the province reveals that in many areas of the province, local government is doing a very poor job of diverting packaging and printed paper. What would result from an amendment to the recycling regulation that forces industry to fund poorly performing local government programs?

A valid counter to the point of setting the rules, getting out of the way and letting industry run the programs is that some existing EPR programs have provided poor levels of service across the province, particularly in rural areas, and the level of trust for something as significant as delivering packaging and printed paper recycling services is low. The result of poor EPR performance is often complaints to local government elected officials and staff demanding that they do something to correct the situation. In some underperforming EPR programs there is a clear lack of transparency and accountability, which can result, unfortunately, in missing the point that some EPR programs are performing very well. It is very frustrating to managers of the good EPR programs to learn that they are often lumped in with the bad actors, which can discredit the entire EPR policy direction.

These concerns can be addressed in a number of ways. The most important factor is that the packaging and printed paper stewardship plan must include more specific service level commitments than have been approved in some past plans. Also included in the plan should be a comprehensive description on how public complaints and queries will be handled. Space precludes a detailed listing of other measures that can be taken to insure adequate levels of service, but there are many ways to compel EPR programs to provide outstanding service and with a little imagination, it is easy to envision a very effective industry operated program. The highest value role for local government is to help define outstanding service and carefully review draft stewardship plans to insure that adequate service levels are properly defined and committed to with an emphasis on local knowledge of the various challenges that exist.

If the promise of the recycling regulation is to be achieved, it is important to avoid creating an unwieldy Frankenstein of mixed responsibilities and body parts that confuse and confound clear lines of accountability.

The Series
PART 1:    The BC Packaging Law and the Rural District of Kootenay Boundary
PART 2.    Shifting Public Funds to Composting
PART 3.    Maintaining High Service Levels

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