By Raymond Gaudart
As British Columbia moves forward
in implementing the first 100% producer-funded and managed collection and
recovery program in North America for packaging and printed paper, issues are
being raised that can serve as alerts for parties working on EPR for packaging
in the United States. A specific issue is that of service levels for rural
communities. Raymond Guadart describes
why the Board Chair of the Regional District of Central Kootenay (RDCK) recently
wrote the Environment Minister a letter
over concerns that the Steward’s plan to require that all drop-off sites be
manned would close the vast majority of such sites. It is worth noting that
RDCK supports EPR for packaging. This
episode illustrates the kind of issues that public-interest advocates in the US
need to ensure is dealt with in legislation.
/Bill S.
As Multi Material British Columbia (MMBC) moves forward in the
implementation of its approved Stewardship Plan for Printed Paper and Packaging
(PPP) some flaws in the process have become very evident. Most notably for rural and small communities
in BC is the lack of a requirement for the steward to ensure adequate access to
collection facilities for all residents of the province.
This requirement is one of the fundamental principles of a
stewardship program as defined in the government’s Industry Product Stewardship Business
Plan. It is also a matter of
public record that MMBC assured local governments during public consultations
leading up to the plan approval that there would be no change in service
levels.
Now local governments and non-profit societies, who provide
recycling services in the majority of the province’s extensive rural areas,
find themselves faced with the onerous requirement to staff and fence all
recycling depots in order to qualify as a collector and receive the
unilaterally imposed financial incentives offered by MMBC to continue to
deliver recycling services. The cost of
meeting MMBC’s depot criteria will effectively eliminate access to recycling in
large parts of rural BC. Not even large
waste management companies are likely to be able to afford to meet the criteria
and remain cost effective.
There is also no provision in the approved plan to require different
financial incentives dependant on distance from processing facilities or an
adjustment for increased costs over the duration of a five year contract (the
likely length of an agreement with MMBC).
Perhaps it is time for the Province of British Columbia to recognize
that its non-prescriptive approach to EPR doesn’t work in this instance. There
need to be some criteria included in an approved stewardship plan for PPP that
include guarantees of adequate access for all residents. Likewise, there needs to be recognition that
the cost of delivering services will vary from metropolitan centres to rural
areas, and that costs do not remain constant over the course of a five year
period.
There is an excellent opportunity in this process for British
Columbia to refine its approach to EPR to ensure the potential it offers for
both eliminating taxpayer subsidies for the production of waste and encouraging
industry to minimize its production of waste through Design for Environment.
USMAN VALIANTE COMMENTED:
ReplyDeleteThe statement, “There is also no provision in the approved plan to require different financial incentives dependant on distance from processing facilities” is incorrect.
The collection financial incentives in question are strictly for collection activities. The costs of “post collection” activities including consolidation, transfer and transportation of printed-paper and packaging (PPP) from collection vehicles and depots to processors, subsequent processing and marketing of PPP are borne directly by MMBC.
In practical terms, this means that once a depot collects PPP, MMBC will make all arrangements necessary to pick up the PPP from the depot and have it recycled.
If a depot also wishes to act as a processor it will eligible to bid under the MMBC post collection RFP process to provide the “post collection” services described above. If it is successful in its bid it will be paid a separate payment in addition to the collection incentive for providing those post collection services to MMBC.
Finally, MMBC recently posted a blog to help depot operators understand what ‘staffed’ and ‘fenced/locked’ means. There is a strong rationale for these provisions as they ensure material quality – unstaffed, uncontrolled depots typically lead to contamination of the recyclable material.