Wednesday, August 7, 2013

EPR for Packaging in Rural British Columbia – A Lesson for the U.S.

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. 

1 comment:


    The 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.


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