British Columbia is the latest province in Canada to regulate extended producer responsibility (or EPR) for printed paper and packaging. Publishers, packaging brandowners and first importers (collectively known as stewards) have until November 19 to deliver a plan on how to do it. The big difference with BC is that industry will not only be paying the full cost, it will also be having a large say in program design and execution (a first for North America).
So the BC stewards have a golden opportunity to design a program that works for them and that is not encumbered or restricted by elements of the current system (for example, municipal control of contracts and program design). The stewards need to assert control from the start by clearly defining the program scope. What exactly does it cover? This is not the time to produce a “patch-up” job that sits somewhere between steward and municipal interests. This is the time to design something that works for the stewards while meeting all regulatory obligations. What happens in BC has implications for stewards far beyond that province and is a great opportunity to create a new EPR model.
In our view, the stewards should assert their control over the proposed residential program by doing the following:
- Ensure effective legal control over the printed paper and packaging materials placed by householders at the curb, depots, and in “streetscapes” (public spaces)
- Ensure that collection is done in such a way that it makes economic and demographic sense (rather than, as at present, being limited by a particular municipality’s political and/or historical boundaries). Collection zones should be established on the basis of geographic and demographic logistics and not by whether they correspond to municipal borders
- Encourage Material Recycling Facilities (MRFs) and transfer stations to be sited where it makes most economic sense considering both residential and industrial, commercial and institutional (IC & I) sources of material
- Choose which printed paper and packaging materials are to be collected, processed, and marketed for recycling, composting, and energy-from-waste.
Whichever way you look at it, the scope of what is being designed here is basically a paper recovery program. As the consultants to the steward body developing the plan note: “Recycled paper has long been the backbone of both residential and IC and I recycling programs, both in terms of tonnes diverted and revenues generated.” In the residential stream alone, the paper component is estimated by the consultants to be 75 per cent. Clearly, the proposed BC program will succeed or fail on how well paper is recovered.
Given this fact, it would seem to make sense to design a system that advances paper recovery and its revenue potential. This can be achieved in the following ways:
- Collection should be dual (or multi) stream to separate the paper (fibre) portion from the container (plastic, glass, metal) stream. PPEC supports the consultants’ suggestion that film, poly and foam go to depots and that other film and laminants be considered as potential energy-from-waste (EFW) possibilities. This will help reduce the contamination of both the fibre and container streams, and enhance their revenue potential.
- MRFs need to be sited where economies of scale make sense. It is extremely important in this regard to look at the bigger picture here (residential and IC and I). A study that PPEC commissioned many years ago, for example, indicated that 75% of Ontario’s total paper stream (residential and IC and I) could be diverted by the strategic location of just four big MRFs. There were then 57.
- Apart from the fact that BC may one day add IC and I printed paper and packaging to its EPR stable, it makes sense to allow MRF operators to benefit from the economies of scale by using their MRFs to process industrial packaging and office papers in the same facility. These economies of scale will contribute to lower costs for residential paper and packaging and be reflected in their bids for contracts. Unnecessary processing capacity will be avoided.
- In designing its plan for residential paper and packaging, then, the stewards’ agency needs to create the climate and opportunity for the option of large strategically placed MRFs that can handle both residential and IC and I materials. No such large MRFs will be built unless the agency clearly indicates that there is a reasonable return on investment for such an undertaking.
In conclusion, this program will be paid for by stewards and thus should be developed in the stewards’ collective best interests. A simple political “quick-fix” or “topping up” of current municipal programs will neither meet the stewards’ long-term needs nor the ministry’s expectations. Harmonisation of program elements and control over implementation are essential for the success of this program. The stewards must ensure both, and lead from the front.