When Theory Meets Practice: Lessons from Decades of Packaging EPR Experiences in Europe

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Written by the Continuous Improvement Fund

Ontario is undertaking a transition to full extended producer responsibility (EPR) for packaging and paper products under the Resource Recovery and Circular Economy Act (the “RRCEA”). At their core, EPR policies seek to ensure that the pricing of products incorporates their social and environmental life-cycle costs, including end-of-life treatment and disposal. When products accurately incorporate such costs, industry is incentivized to design them in a way that considers their end-of-life environmental effects.

Decades of experience with mature packaging EPR systems in Europe, however, have not brought all the results that EPR intended to bring about. As Ontario undertakes its transition to full EPR under the RRCEA, there are lessons to be learned from Europe’s experiences with EPR.

European Packaging EPR Lessons on the Ground

In the European Union (EU), the Packaging and Packaging Waste Directive 94/62/EC (the “PPWD” or the “Directive”) creates the framework for implementing EPR programs in EU Member States. The Directive aims to reduce packaging and sets collection and recycling targets for packaging waste. The Essential Requirements provisions laid out in the PPWD provide criteria for packaging, such as weight and volume minimization requirements, hazardous substances levels and packaging reuse and recovery. It is notable, however, that while the Essential Requirements define the results to be attained, they do not specify or predict technical solutions, giving manufacturers the flexibility to meet the requirements of the Directive.

The PPWD has resulted in certain successes including an impressive increase in recycling rates for all Member States. By 2017, Member States achieved an average 42% recycling rate for plastics, well above the Directive’s requested 22.5%. There have likewise been improvements in individual packaging weight. On the other hand, the Directive has also had its shortcomings.

Vague definitions leave too much room for interpretation

Despite decades of packaging EPR in Member States, the European packaging market demonstrates a trend towards difficult-to-recycle packaging such as flexible multilayer composite packaging. Some trace this trend to a deficiency in the Essential Requirements in requiring design changes for re-use and recyclability and on definitions that leave too much room for interpretation, such as what qualifies as recyclable. Many producers have, as a result, tended to light-weight their packaging at the expense of its recyclability. At the same time, the amount of packaging waste generated in Europe continues to grow reflecting growth of global population and demand.

Enforcement left to Member States with varying resources

The vague and general formulations of the Essential Requirements also create enforcement challenges for Member States. Member States are responsible for reaching the national targets and ensuring good enforcement of the legislation. Authorities in Member States have expressed frustrations with judging which packaging is noncompliant with the Directive’s requirements. The Directive’s formulations are insufficient to enable a clear assessment of violations.

Many Member States do not have formal procedures in place to enforce or implement the requirements of the PPWD. Authorities also cite other priorities such as issues with food safety, or a lack of staff and finances. The few countries that have implemented measures and enforcement procedures for the requirements, including France and the UK, have delayed setting up systems to assess the effectiveness of their enforcement mechanisms.

Municipal costs are not fully covered

It should be noted that, despite producer responsibility for packaging waste, European municipalities generally remain in charge of waste management programs. Yet financial transfers from producers may not be covering the full amount of municipalities’ costs. A study of the cost coverage of packaging EPR programs in a number of European countries found that these programs failed to account for the full costs of the waste management of packaging. When excluding avoided costs (i.e., collection, landfilling, incineration, etc.) and subsidies (i.e., public grants), only 68% of the costs of packaging waste management in Portugal and 56% in France were being supported by industry in 2010. It bears mentioning that industry in France is obligated to cover 80% of local authorities’ “efficient costs” of collection and sorting.

Another study observed that producers’ motivation to improve waste management has also largely depended on the type of collection and management contracts that they establish with municipalities or on their dialogue with municipalities. Producers can tie their financial contributions to the municipalities’ collection or recycling rates, the quality of their collection or recycling, or on meeting requirements on the type of collection and treatment schemes to be implemented. When it comes to the fulsome reimbursement of municipal costs, the choice seems to be with Member States to determine what percentage of local authorities’ costs should be covered by packaging EPR. New amendments to European EPR laws, however, will ensure that industry will have to cover the full “necessary costs” of EPR schemes. Member States that wish to deviate from this requirement will have to justify their choices.

Europe Takes Action

In 2018, the EU reformed EPR rules in the context of its first Circular Economy Action Plan to require higher overall recycling targets for packaging (65% in 2025 and 70% in 2030) and higher material-specific targets (including 55% for plastics by 2030). At the same time, it moved the calculation of recycling targets based on the weight of municipal waste that enters recycling, removing any losses of materials due to sorting or other preliminary operations. The Directive now also requires Member States to establish “adequate” monitoring and enforcement frameworks to ensure that those responsible under the EPR framework carry out their obligations, use financial means properly and report reliable data.

As of June 11, 2020, the European Commission also published its plan for revising the requirements of the PPWD. The proposed changes will address the limited competitiveness of recycled materials relative to virgin feedstock, which is now even more inexpensive given the oil industry crisis brought about by the COVID-19 pandemic. The changes will also address the rise in public consumption of packaging driven by a shift from reusable to single-use disposable packaging, growing online sales and the over-packaging for goods.

The Commission has not been clear on whether the targets and measures under these upcoming changes will be general or set at the level of specific material or packaging formats, or whether they’ll be mandatory in nature. It is expected, however, that current and seemingly unenforceable definitions of terms such as “recyclable” or “reusable” will likely be updated.

Despite action at the EU-level, Member States appear to be lagging in their implementation of the 2018 update to the PPWD. Most missed the deadline to implement this Directive by mid-2020, some citing delays related to the COVID-19 pandemic.

At the same time, recycling markets were particularly impacted by the COVID-19 crisis. The crisis brought about safety concerns, employee shortages, manufacturing slow-downs and a historic drop to oil prices making virgin plastics much cheaper than recycled resin. European recyclers are encouraged by Europe’s recent focus on improving access to recycled resin as part of the EU’s Green Deal set of programs. However, they urge concrete actions such as mandatory recycled content rules in key products to ensure steady increases in the demand for recyclates.

Conclusion

It is unclear how many of these lessons will be implemented in the new printed paper and packaging regulation under Ontario’s RRCEA. Europe’s experiences demonstrate, however, the necessity of clear definitions, specific requirements for design changes for re-use and recyclability, adequate coverage of local authorities’ costs, and the allocation of resources to the oversight and enforcement of EPR programs. These practices help EPR programs better achieve their intended aims of ensuring that industry internalizes the life-cycle costs of their products and is incentivized to design products to account for their end-of-life environmental effects.

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This article was first posted by the Continuous Improvement Fund. The Continuous Improvement Fund (CIF) is a partnership between the Association of Municipalities of Ontario (AMO), the City of TorontoStewardship Ontario (SO) and the Resource Productivity and Recovery Authority (formerly Waste Diversion Ontario – WDO). The CIF’s mandate is to improve the effectiveness and efficiency of Ontario’s municipal blue box Programs.

Study on EPR’s effect on packaging prices: What you can and can’t do with data

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Written by Calvin Lakhan, Ph.D, Co-Investigator: “The Waste Wiki” – Faculty of Environmental Studies at York University

I’m actually really glad that Jodi Tomchyshyn London found and shared the following study by RRS: Impact of EPR for PPP on Price of Consumer Packaged Goods.

In short, after undertaking a fairly comprehensive examination of jurisdictions across Canada (both with and without EPR legislation), the study concluded that EPR policy has no affect on packaging prices.

The University had an opportunity to review this study as part of some technical advice that we were providing to the state of Oregon (specifically surrounding the impacts of EPR). The RRS study directly contravened our own findings, and as a result, we wanted to better understand why.

I want to preface this by saying that the intent of this post is not to criticize or undermine the work that RRS has done. It was well researched, and I applaud them for wading into such a messy and controversial topic and attempting to provide some clarity. However, the point I do want to make in this post is helping stakeholders understand what they can and cannot do with data. Jodi had made a really good point about understanding the context surrounding data – we need to understand how that information was collected, analyzed, interpreted and presented. I couldn’t agree more…. which is why I sometimes cringe when I see the conclusions that people arrive at, due to a fundamental misunderstanding of what you can do with data.

Going back to the RRS study, regardless of how you feel about EPR and its potential impacts, it is critical that stakeholders understand that the RRS study has some methodological deficiencies, and as a result, leads to erroneous conclusions that cannot be supported by the data. This isn’t a question of opinion – given the way the study was designed, it is not possible for RRS to make any statements regarding the effect of EPR policy on packaging prices. Comparing costs across jurisdictions (even for like products and retailers) is not likely to yield any meaningful inferences with respect to the impact of EPR policies. There are literally hundreds of variables that affect the price of goods across localities (even for the same product and retailer). Demographics, infrastructure, relative purchasing power, proximity to markets, density of competing retailers etc. all effect price. In order for RRS to make the statements they did, they would have to control for all of these factors using statistical techniques such as multivariate regression to specifically isolate the effects of EPR on packaging prices. Given that many of these explanatory variables are collinear, they would also need establish controls for interdependency among explanatory variables.

While the above description may be a tad technical, the best way to look at it is that we are trying to compare identical systems, where the only variable being changed is the presence or absence of EPR programs. All other variables that can potentially impact a product’s price need to be controlled for. As far as I can tell, RRS made no attempts to control for interdependent variables and arrived at a conclusion that cannot be substantiated empirically. The only observation that can be made is that product prices differ from province to province, but provides no insight as to why they differ.

Given that my perspective may be seen as biased given that the university developed an alternative model, I would *strongly* encourage you to have a third party expert with a background in statistics and study design to review the RRS methodology. I am absolutely positive that they would reach an identical conclusion.

This is what is so potentially dangerous about attempting to interpret data without having a sound knowledge of how that data was collected and what you can do with it. In my career, I have countless anecdotes of stakeholders from all walks of life who draw the wrong conclusions, imply causality or infer relationships that simply aren’t there. When a misinterpretation of data leads to policy and legislation, the results can be catastrophic.

In the very first presentation I ever gave on the Waste Wiki, one of the slides says “Data without consideration of context or design does not tell us very much”. That message rings true more than ever today.

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About the Author

Calvin Lakhan, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior.

How Neighbourhood Food Environments and a Pay-as-You-Throw (PAYT) Waste Program Impact Household Food Waste Disposal

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Researchers from three Canadian universities recently published the results of a study on how pay-as-you-throw (PAYT) waste programs impact household food waste disposal.  The purpose of the study was to gain a better understanding of current household food waste disposal in order to develop and implement more effective interventions to reduce the wasting of food.

The collaborative study from researchers working at Western University (London, Ontario), Simon Fraser University (British Columbia) and the University of Toronto conducted a four season waste characterization study of 200 single-family households across eight neighbourhoods in Toronto.

The City of Toronto provides residents with a pay-as-you-throw (PAYT) waste program that includes a choice of four garbage cart sizes ranging from small,  medium, large, and extra large.  Annual user fees range from $18 (small cart) to $411 (extra large cart).  Each household also gets a green cart for organic waste and a blue cart for recycling at no annual cost.

The results of the research show that, on average, each household disposed 4.22 kg/week of total food waste, 69.90% of which was disposed in the green cart, and disposal increased significantly (p = 0.03) by garbage cart size to L but not XL garbage carts. Of this total, 61.78% consisted of avoidable food waste, annually valued at $630.00–$847.00 CAD/household.

Toronto’s PAYT waste program has been effective at diverting food waste into the green cart but not at reducing its generation. Higher median incomes were positively correlated, while higher neighbourhood dwelling and population density were negatively correlated, with total and avoidable food waste disposal. Regression analyses explained 40–67% of the variance in total avoidable food waste disposal.

Higher supermarket density and distance to healthier food outlets were associated with more, while dwelling density was related to less, total and avoidable food waste disposal.

Distance to fast food restaurants and less healthy food outlet density were both negatively associated with avoidable food waste disposal in the garbage and green cart, respectively. Avoidable food waste reduction interventions could include increasing garbage cart fees, weight-based PAYT, or messaging to households on the monetary value of avoidable food waste, and working with food retailers to improve how households shop for their food.

The researchers conclude that the data from the stud can be used to help formulate avoidable food waste reduction interventions. In terms of the PAYT waste program, this could be accomplished by re-visiting and potentially increasing garbage cart fees. Alternately, PAYT could be switched to a weight-based approach which has been shown to be more effective at source reduction of waste.

Reduce, Reuse and Rethink: Re-defining our goals for a waste management system

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Written by Calvin Lakhan, Ph.D, Co-Investigator: “The Waste Wiki” – Faculty of Environmental Studies at York University

For the first time in my career, issues surrounding waste management have now become part of mainstream discussion. Whether it be my neighbors asking me “Can this really be recycled?” to growing concerns surrounding single use plastics, people (both the public and policy makers alike), care now more than ever regarding what is happening to our waste. We as Canadians recognize that issues surrounding waste require our immediate attention, and that our waste disposal behavior (both good and bad) can have significant impacts on the sustainability of our environment.

So with this in mind, I thought it would be prudent to revisit the topic of “What is the goal of our waste management system?” While this is a topic I have written about several times in the past, proposed legislative changes – not only to Ontario’s Blue Box program, but waste management legislation across North America, makes it a timely topic for discussion. Now, more than ever, we need to clearly define what our goals are, and whether our existing approaches are helping move us towards achieving those goals.

So, what is the goal of a waste management system? This seemingly simple question is actually surprisingly difficult to answer, as it depends on who you ask and what is being prioritized. While we may here terms like “Circular Economy” and “Zero waste” banded about, what do they actually mean? Are they intended to be aspirational or achievable goals? What is the time frame and the boundaries we use to define a circular system, and what do we choose to prioritize when different stakeholders have competing objectives? I am reluctant to answer these questions, as I don’t think there is a right or wrong answer other than – “it depends”: On who you ask, what you ask and why you ask. With that in mind, before proceeding with our discussion, I want to remind everyone about the three pillars of sustainability: A sustainable system must consider economic, environmental and social dimensions. By definition, we cannot consider a system sustainable if it does not address these three components. This is a critical consideration when deciding what a goal of a waste management system could (or should) be.

Ontario (and Canada) has a recycling problem

Historically, the emphasis of waste management has been on residential recycling. The Blue Box, a ubiquitous symbol of recycling that has been a fixture in our homes for the better part of four decades in Ontario. In fact, my very first memory as a budding environmentalist was washing out peanut butter jars before putting it in the recycling (less to do with concerns surrounding contamination, and more to do with a fear of attracting insects). For many Ontarians, the Blue Box is symbolic of recycling and sustainability, and it is something that we have been extraordinarily good at – which as it turns out, is actually a really bad thing.

During the summer of 2019, York University conducted a study to gauge what the public thought about various waste management initiatives. Participants were asked to rank, from best to worse, which end of life scenario resulted in the greatest environmental impact (shown in figure 1)

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From the above graph, recycling was seen as the most environmentally preferred option, with reuse second and waste reduction a very distant fourth place. Why does this matter? Because reduce, reuse, recycle isn’t just a catchy phrase – it is the order in which we are supposed to things. Recycling is our third most preferred option.

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Canada has become a victim of its own success – both households and policy makers now conflate recycling with sustainability. If it can’t be recycled, it is characterized as being “bad”. The “waste” problem is often framed as “We aren’t recycling enough”. Just last year, Deloitte made international headlines when they published a report indicating that Canada was only recycling 9% of its plastics. The response from the public was almost visceral – Households and government demanded change, with consumers even going so far as to say that they would be less likely to buy a product if it could not be recycled at the end of its life. Canadians are voting with their dollars and the message is loud and clear “We want recyclable products”.

While the sentiment and intent is in the right place, the approach is not. Not only is recycling not the most preferred outcome, it can actually have adverse economic, environmental and social impacts. Contrary to intuition – not everything that can be recycled, should be recycled. The decision to recycle everything, everywhere, is actually what is compromising the long term sustainability of the system.

Why the next diverted tonne will not (and should not) come from the Blue Box

As noted earlier, the residential recycling system (for printed paper and packaging) has been enormously successful, so much so that policy makers continue to put all of their eggs in one basket, and attempt to drive future diversion from this waste stream. The proposed Blue Box transition in Ontario, which shifts 100% of the physical/financial responsibility of managing the system on to producers, continues to emphasize and prioritize recycling based outcomes. Why this is problematic is threefold:

1)     We are already doing a great job of capturing the “low hanging fruit”. Recycling rates for core Blue Box materials (newsprint/OBB/OCC etc.) are already well in excess of 80%, and future increases in diversion are not likely to come from these materials

2)     The overall packaging mix is increasingly being made up of composite and light-weight materials that are extremely difficult to recycle given existing technology, infrastructure and end markets. If future increases in diversion come from these materials, the cost of recycling is potentially prohibitive.

3)     The environmental benefits associated with recycling many light weight and composite materials are negligible given existing processing technology.

In short, not all recycling is created equal. Figure 3 below summarizes the amount of money you would have to spend on recycling a given material, to abate one tonne of carbon ($/TCO2e).

Figure 3: 

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Using the above example, you would have to spend almost $1500 on recycling to abate one tonne of carbon from plastic film, and only $65 on recycling newsprint to achieve the same result. Let that sink in for a moment – Film is 23 times more expensive than newsprint from a carbon to recycling expenditure ratio.

To further drive home this point, please refer to Figure 4 below:

Figure 4

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Figure 4 shows the change in net system costs that results in a 1% change in the recycling rate, on a material by material basis.

If we wanted to increase the overall recycling rate of the Blue Box program by 1%, and we had to achieve it by increasing recycling of plastic laminates, overall system costs would increase by more than 14%.

Why this matters is that (as noted earlier), future increases in recycling rates are not going to come from core Blue Box materials. As a result of the changing nature of packaging over time (also referred to as the evolving tonne), increasing the Blue Box recycling rate will involve trying to collect and recycle materials such as composite and light weight plastics. To increase Ontario’s Blue Box recycling rate to 70% by recycling composite/light weight plastics (which is about 6% higher than our current recycling rate), we would have to spend in excess of $70 million dollars – and that is assuming that we have capacity within the existing system and end markets to accommodate increased recovery.

This is both prohibitively expensive, and has questionable environmental benefits. Once again, we are forced to ask ourselves, what is the goal of our waste management system? Increasingly, that answer is not going to be about increasing recycling rates, particularly for printed paper and packaging.

This begs two questions: 1) If the next diverted tonne shouldn’t come from the Blue Box, where should it come from? And 2)  If light weight and composite packaging is so terrible, why do we continue to use it?

As for where our next diverted tonne will come from, please refer to: https://www.linkedin.com/pulse/where-our-next-diverted-tonne-come-from-diversion-calvin-lakhan-ph-d/

The second question is a bit trickier, as there is a subjective element to how you choose to evaluate the merits of a particular packaging type. Why a producer makes the packaging decisions they do is largely a function of economics and safety – some factors include: Does the packaging I use make it safe to transport materials, protect the product, avoid spoilage or contamination, increase shelf life, increase the number of units I can place on the shelf/in the store, allow for easy brand recognition etc.

The increased adoption of light weight packaging can be attributed to the benefits of durability, transport and ease of consumption, while also allowing for a reduction in overall packaging used. Interestingly, when taking a life cycle approach, the environmental impact of light weight and composite packaging can actually result in superior environmental outcomes when compared to conventional packaging. This may seem counter intuitive, given the relatively low recyclability of these materials, but upstream benefits (packaging reduction, logistical efficiencies when transporting materials, avoided food waste/spoilage, discretionary consumption etc.), actually outweigh whatever you lose from not recycling that material.

All things being equal, the recyclability of a package his historically ranked as a relatively low priority for producers.

In a 2017 study conducted by the university examining the relationship between packaging fee rates, and packaging recycling performance, there was no statistically significant correlation between the two. Even for products such as paper laminates and plastic film, where the corresponding fee was significantly higher than all other materials, recycling rates remained largely unchanged, or did so in response to broader macro market conditions. The price signal sent by the fee, was insufficient to change packaging choices.

With that being said, the optics surrounding whether a package can be recycled (and more broadly, diverted) has now become a key issue for producers, and increasingly, you are seeing brand owners talk about solutions for how to recycle their products. The rise in prominence of organizations such as Terracycle speak to just how important “recyclability” has become for consumers. We have spent the better part of 40 years inundating the public with the message “recycling is good for the environment” and attempting to change that narrative is extraordinarily difficult. This issue is exacerbated by the fact that the government is continuing to develop policy that prioritizes recycling as a preferred end of life option. Between consumer demand and government legislation, producers face the daunting task of trying to recycle the unrecyclable, and in doing so, incurring a bill that is experiencing double digit percentage increases in recycling system costs year over year.

The importance of a socially sustainable waste management system

Historically, waste management (at least in a Canadian context), has not been seen through the lens of social sustainability – somewhat of a surprise, given how socio-economic inequality manifests itself in the form of impeded access, awareness and exposure to waste. Much of the existing academic research on environmental justice has been on the unequal distribution of environmental hazards and benefits along racialized lines, where there are consistent indications that waste facilities and waste related hazards are disproportionally located in lower income areas (or those predominated by minorities).

In all fairness, the connection between waste management and socio-economic inequality is not something that is top of mind for most policy makers. Generally speaking, there is an idea that a municipality will provide waste management services to a particular area, support that initiative through a combination of promotion and education efforts, and hope for sustained public participation. However, the costs of service delivery, the means and mediums of engagement, service accessibility and affordability vary widely, even within the same city.

Economic Exclusion

Taking a step back for a moment, I want to share with you three brief anecdotes that capture how seemingly oblivious our waste management system is with respect to social sustainability. These are actual conversations I have had with people in my day to day life

1)     “Consumers should purchase fewer packaged goods and opt for things like fresh produce instead of getting something shipped to us from half way across the world”.

2)     “We don’t need to use plastic film anymore, consumers can go out and buy reusable beeswax clingwrap”

3)     “Packaging programs focused on reuse (Loop) are going to be revolutionary and cut back on the amount of packaging waste we generate”

All of these are valid observations… but not necessarily ones that are realistic for many households. What people can and choose to purchase is largely a function of economics –those of us that have the luxury of being conscientious consumers, can shop locally and avoid pre-packaged goods. However, it is important to recognize that the ability to do so is a luxury – in a focus group conducted of more than 1800 consumers in the Greater Toronto earlier this year, more than 80% of respondents indicated that price was the primary determinant for making a purchase. If possible, respondents indicated that they would like to make more sustainable purchases, but budgetary restraints largely impeded them from doing so.

More than 60% of respondents also indicated that they did not have the ability to travel outside of a 5km range to make daily purchases, and often shopped at specific retailers because of a mix of multiple factors such as: convenience, price, familiarity and purchasing agglomeration (one stop shopping). In a 2019 analysis of consumer purchasing preferences in the Greater Toronto Area, households characterized as “low income” (household income less than $40,000 per year) consumed 18.4% more pre-packaged goods (namely grains, produce and frozen meats), when compared to families whose household income exceeded $100,000 a year. There is an inverse, statistically significant correlation between household income and % of prepackaged foodstuff of overall weekly purchases.

The expectation that households have the ability to readily switch between products based on packaging type doesn’t appear to be a realistic one. People might like the idea of Loop or beeswax and want to engage in more sustainable consumption, but at present, they are priced out of “taking part”.

A perhaps more insidious impact on consumers is the potential impacts to their cost of living attributable to increases in recycling system costs. As noted above, the costs of operating our recycling system are rapidly increasing, and these costs are ultimately born by consumers. In both late 2019 and early 2020, York University conducted research to better understand the link between an increase in basket of goods costs and increases in the steward obligation. While I have received many critiques and questions pertaining to how prices for packaged goods change in response to changes in the steward obligation (see post script for explanation), our research showed that consumer basket of goods prices increased by 6-12% (depending on locality). The economic and social impacts of this are potentially enormous, as lower income families are disproportionately affected by increases in packaging costs. As stated earlier, they purchase more prepackaged goods as a proportion of their overall purchases when compared to high income families.

While the ultimate intent of producer responsibility is to have the generator bare the financial costs of end of life management, the magnitude of those impacts is relative to the consumer’s ability to absorb them. As such, when we ask ourselves “What should the goal of a waste management system be?”, it is imperative that we also give thought to “How do we account of social sustainability?”. A focus on recycling/diversion based outcomes paints an incomplete picture of a much more complex and nuanced problem. What good is a circular economy if not everyone can participate or benefit from it?

Reduce, Reuse and Rethink

I will go on record and say that I think if we pursue an approach premised on prioritizing recycling above all else, it will be destined for failure. Shifting financial responsibility onto producers will not magically fix what is broken, and I think it naive to assume the financial incentive will result in fundamental shifts in producer behavior.

To echo a position I have shared in the past, the province needs to embrace a “macro approach” when it comes to sustainable materials management – Viewing end of life waste management as separate from other stages of a products life cycle is too myopic in scope.

Past emphasis on recycling rates and the recyclability of materials is no longer compatible with the changing nature of packaging. Recycling should not be the main objective, but rather, emphasis should be placed on promoting sustainable outcomes.

If a particular packaging type cannot be readily recycled, but abates more carbon at a lower cost (i.e. avoided food waste), should that be discouraged? Will forcing producers to pay 100% of the cost of recycling light weight plastics result in technological innovation and new end use applications? Or will it result in a bill in the hundreds of millions for Ontarians?

At present, the way waste management systems and legislation are designed is “siloed” – Blue Box is a distinct entity from the Green Bin, which is a distinct entity from waste electronics etc. While this may be a necessity from an operational perspective, it is imperative to take a step back and look at the entire waste management system. There is an opportunity cost to whatever decision we make – a dollar spent on one end of life management option is a dollar not spent on another. As such, our priorities should be designed to reflect what we want to achieve in waste management as a whole. Policies and legislation need to enable the province to work towards that goal in an economic, environmental and socially sustainable way. Measuring success in terms of diversion or recycling rates is no longer good enough.

APPENDIX (Calculating increases in consumer basket of goods)

As an example, the proposed increase in the steward obligation in Ontario resulting from the transition to full producer responsibility is $135 million dollars (this is a known number). The university’s methodology uses a six step process:

1) Quantify the potential reduction in the municipal tax base resulting from the transfer of recycling and landfilling costs onto producers (if any)

2) Determine how producers respond to the increased obligation. We operate under the assumption that stewards are not going to internalize any of this $135 million dollars, and that it it will either manifest itself in one of two ways a) costs are transferred to consumers (both directly via the fee allocation model and indirectly via increased pricing, b) contraction of the company resulting in job losses etc. (a less likely scenario, but one that does have a precedent – most of our modeling assuming consumers absorb this cost).

3) Examine the existing basket of good costs across localities (basket of goods costs vary significantly depending on whether it is rural/northern community, urban areas etc.) – part of this analysis is to also to determine the relative price elasticity of the consumer good basket within those communities. We calculate relative price elasticities for a range of consumer goods and household services using measured data in dozens of cities across Canada. Elasticity is very much a function of locality – price elasticity in Northern Ontario is sometimes 200% greater than in Southern Ontario, i.e. you increase the transportation costs for 4 litres of milk by 50 cents, the corresponding price increase in Red Lake is more than $2.00. This also explains why our modeling shows that the increase in the price of consumer goods resulting from producer responsibility is more acute in certain communities.

4) Using a logit-loglinear regression model, we adapt an input-output table that has been regionalized for the Ontario market (or whatever province we are examining). A log-linear analysis is necessary to specifically isolate what percentage of the $135m increase in the steward obligation specifically manifests itself with respect to price changes in the consumer basket of goods.

5) As noted in step 3, we know that certain communities are much more sensitive to changes in the prices of goods based on their relative elasticity measure. Using the output of Step 4, we then apply how price changes manifest in specific communities across Ontario (or a given province). This is how we develop a range of estimates for potential increases in the consumption basket.

6) Once we have determined the potential change in the consumer goods basket, we then backout potential savings resulting from a potential decrease in the municipal taxbase (if any) to arrive at our final estimates.

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About the Author

Calvin Lakhan, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior.

The Benefits of Regulatory Convergence on Sustainable Plastics Management within the Pacific Alliance

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Written by Maria Vizeu-Pinheiro, German Sturzenegger, Denisa Mertiri, and Jonathan D.Cocker

Plastic pollution, including through single-use plastics (SUPs), continues to plague natural environments around the world, including in Latin America and the Caribbean (LAC). The region produces around 28 million tons of plastic waste every year (12% of total municipal waste), of which around 36% is SUP. It is estimated that about 4 million tons of plastic waste could enter the ocean in 2020 due to inadequate solid waste management in coastal cities, where a significant portion of the population lives.

In LAC, there is growing interest in combating the shared problem of marine plastics. The countries of the Pacific Alliance (PA) -Chile, Colombia, Mexico and Peru- have launched an Environmental and Climate Change action plan, including a Presidential Declaration on Sustainable Use of Plastics[1] focused upon:

  • an analysis of plastic bag regulation and recommendations for the reduction of their use;
  • a targeted single-use plastic ban;
  • research and support for new productive models for plastic alternatives;
  • action on the reduction of plastic contamination in water, including marine environments;
  • strengthening the culture of responsible use of plastics and recycling;
  • circular economy model advancement;
  • promotion of re-use of plastic; and
  • the setting of a Road Map implementing these commitments.

In addition, individual PA countries, have each been active in promoting domestic strategies on plastic products and packaging, setting targets and developing regulations such as Extended Producer Responsibility (EPR), innovative recycling mechanisms such as “e-Coins”, and Circular Economy programs.

These initiatives, however, may not be enough in light of the proliferation of plastic pollution and the limited domestic waste management infrastructure. This shared understanding within the PA must now give rise to a coordinated regional action on plastics for which greater regulatory convergence is pivotal to its success.

10 Reasons for Adoption of a Regional Plastics Strategy

While the work on regulatory convergence around plastics, including SUPs, will not be easy, there are compelling reasons to do so:

1. Facilitation of Materials Flows

  • the wide variety of plastics material has left local governments and industry to unnecessarily dispose materials as “scrap” domestically. These materials could be valorized in other PA countries if barriers to transfer were lifted, an issue particularly pressing in light of the Basel Convention Ban.

2. Regional Scale Needed for Plastics Recycling Markets

  • addressing both the leakage of plastics and their value loss in less productive uses requires sufficient economies of scale that regional, and not domestic-only recycling infrastructure resources.

3. Innovation and Specialization:

  • with economies of scale will also come the conditions for investment in innovative products and resource recovery specialized solutions, potentially serving the entire region. These solutions will be imported into PA countries (based upon the regional needs and goals of others) if its members don’t otherwise develop their own;

4. Commercialization Through EPR Favours Regional Consistency

  • as EPR may well be part of the solution for plastics resource recovery, the formation of effective Producer Responsibility Organizations (PROs) is enhanced through regional PRO models, servicing discrete industry segments and able to administer programs consistency, with lower transactions costs across multiple countries;

5. Product Standards Development Suitable for PA

  • outside of the PA countries, there is current growth of plastics content standards (such as bioplastics) with corresponding resource recovery process requirements and specifications. These standards will be implemented in PA countries absent a regional alternative – even though these standards are based upon socio-economic and environmental conditions dissimilar to those of LAC;

6. Material Bans Feasible Regionally

  • critical issues remain as to which types of plastics, for which uses and of what plastic material (and its potentially hazardous content) should be permitted by PA countries. Only through a regional strategy will the PA be able to ensure their domestic choices are implementable;

7. Regional Market Data Will Attract Investment

  • the early adoption of regional terminology and methodologies will generate PA-wide data necessary to better attract investment;

8. Ensuring Safety

  • food and other safety and quality measures must be imposed upon any plastics packaging or SUPs introduced within the PA. A regional strategy allows for commonly adoptable tracking and tracing technology, as well as labelling, to ensure the providence of the plastics introduced in the region’s markets;

9. Near-term Financial Recovery Opportunity

  • plastics represent a resource for which there are clear near-term recovery solutions, such as energy production and valuable products made with recovered plastics, which will result in tangible economic gains for local communities across the PA; and

10. International Stakeholder Funding Available

  • along with the push for plastics pollution solutions has come significant funding from international stakeholders, which will be acutely needed during the challenging post-COVID-19 economic fallout;

In summary, there are both immediate and long-term benefits to a PA-focused plastics strategy.  Plastics offers PA countries a relatively easy entry point for the types of economic and environmental joint efforts envisioned in the region’s action plan.

The opportunities for plastics within the region are, however, time-limited. International pressure for conformity with policies most suitable elsewhere will intensify in the absence of demonstrable success.

Further, delays in moving towards convergence will make harmonization more difficult. With individual PA countries developing disparate programs, for which investments and long-term commitments will be based, a move to harmonize internally will be more difficult over time.

The PA countries should move to engage stakeholders, including regional private sector parties, in developing a critical pathway towards achieving these ambitious goals.


[1] This declaration was signed during the 2019 Pacific Alliance summit in Peru

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About the Authors

Maria Vizeu Pinheiro is a lawyer specializing in environmental and natural resources issues at the Environment, Rural Development and Disaster Risk Management Division of the Inter-American Development Bank (IDB). Maria works on the analysis of environmental policies, governance and regulatory frameworks for the Bank’s operations.

Germán Sturzenegger is a Senior Water and Sanitation Specialist at the Inter-American Development Bank. He has participated in the design and implementation of water and sanitation projects throughout Latin America and the Caribbean. Germán leads the recycling and green infrastructure agenda for the Water and Sanitation Division of the IDB, working on the implementation of river conservation and inclusive recycling projects.

Denisa Mertiri, J.D. (Green Earth Strategy) provides legal and policy advice to clients on waste management, single-use reduction, circular economy and extended producer responsibility laws. Denisa has worked with the City of Toronto and other municipalities in Ontario, Canada, on Ontario’s transition to EPR and on single-use reduction and circular economy policies.

Jonathan D. Cocker heads Baker McKenzie’s Environmental Practice Group in Canada and is an active member of the firm’s Global Consumer Goods & Retail and Energy, Mining and Infrastructure groups. Mr. Cocker provides advice and representation to multinational companies on a variety of environmental and product compliance matters, including extended producer responsibilities, dangerous goods transportation, GHS, regulated wastes, consumer product and food safety, and contaminated lands matters.

EPR FAQ: Answers to commonly asked questions and claims

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Written by Calvin Calvin Lakhan, Ph.D, Co-Investigator: “The Waste Wiki” – Faculty of Environmental Studies at York University

Oh goodness gracious, I appear to have really stepped in it this time (although I do suppose I have a history of doing that). My last article about EPR really rankled some feathers and resulted in some heated exchanges with people that disagree.

A little birdie even told me that the word on the collection route is that I am in cahoots with producers and that I am trying to derail the Blue Box transition. If I’m on the take, can someone please let my bank know? I apparently am not receiving any of the money they are paying me to speak out against EPR.

My response to criticism has always been more or less the same – show me the data. My last article asking for any information that supported the efficacy of EPR for packaging waste was met with radio silence. I did have one individual tell me I was wrong, but when I asked them to provide evidence, they responded that I should pay them for their time…. that was a bit of a head scratcher.

In any event, I thought I would share a document I recently put together for the Ontario Environment Ministry outlining some of York University’s responses to commonly asked questions or claims regarding EPR for packaging waste. I also want to re-iterate that I have no issues with EPR as a concept, nor do I think producers should be absolved of their physical and financial responsibility at end of life. My issue has to do with the way EPR is currently implemented, and the challenges that arise when our goal is increasing recycling.

Please note that some of these comments are Ontario specific and refer to proposed changes in the Blue Box legislation. I still think it is of value to those outside of the province to better understand the issues we face as we transition to 100% EPR.

Questions surrounding Extended Producer Responsibility

Extended Producer Responsibility subscribes to the “Polluter Pays” Principle (transferring the responsibility of managing end of life waste to the polluter.

While the polluter pays principle is certainly the spirit of EPR, people often erroneously conflate “polluter pays” with the inability to recycle a material. The most sustainable outcome is not necessarily the one that recycles the most material – from a life cycle perspective, package light weighting has far greater environmental benefits, even in instances where the package cannot be recycled. Instead of encouraging or incenting producers to develop the most sustainable solution, we are telling them to develop recyclable solutions, which in many instances, results in inferior economic and environmental outcomes. Our fixation on using recycling rates and recyclability as the measuring stick for success is why program costs are increasing by double digits year over year, while diversion is actually decreasing.

EPR is not intended to create cost containment; it purely a funding mechanism to shift the burden from the taxpayer to the consumer

A system that does not contain costs is not tenable or sustainable. This is the fundamental issue with existing approaches to EPR. Proponents will say costs are now born by the right party, but what that cost is has significant implications to all stakeholders. Further to that point, while the intended purpose of EPR is intended to make consumers responsible for end of life costs, existing and proposed approaches to legislation are obliging consumers to pay for the costs of operating the recycling system. Recycling is not and should not be the only end of life option that we consider for how printed paper and packaging is managed. Not all materials are created or recycled equally – thus, it seems prudent that we explore options that maximize environmental and economic outcomes by differentiating how and where certain materials should be managed. The decision to recycle everything, everywhere, is the foremost issue facing the long term tenability of the Blue Box program.

The proposed Blue Box transition will save Ontario taxpayers money

A common refrain made by advocates of the transition to 100% producer responsibility is that transitioning program costs to stewards will result in taxpayer savings. Under the proposed legislation, stewards will be responsible for an additional $135 million dollars in program costs (exclusive of proposed changes to what sectors are obligated). The underlying intuition behind the tax savings hypothesis is that municipalities will pass this $135 million in savings onto households, either through a reduction in property tax or utility rates.

While this would be an optimal solution, there is no evidence to suggest that this will be the case. Municipalities (particularly in a post COVID world), grapple with significant budgetary shortfalls and are in all likelihood going to take the funds “saved” from transitioning the Blue Box program and re-allocating those funds to other programs and services. In British Columbia, there is no data to suggest the transition to 100% EPR has resulted in a tax savings for households.

While there is an argument to be made that the reallocation of funds to support other municipal programs and services benefits households, the benefits that are accrued are indirect and do not offset the increase in packaging costs that are attributable to EPR.

EPR does not increase cost of living

As a tangent to the previous point, advocates of EPR often contend that there is no appreciable impact in the cost of living attributable to the transition to full producer responsibility.

An examination of how the fee model works and how producers respond to a corresponding increase in fee rates demonstrates that this is not true. In fact, the transition to a 100% EPR system has been modeled to increase “basket of goods” costs for consumers by anywhere from 6-12%.

While a supplementary document that accompanies this FAQ explains the relationship between EPR and the cost of packaged goods in greater detail, in short, the costs to consumers are both “direct” (an increase in fees directly translates into a proportional increase in packaging costs) and “indirect”(cost escalation resulting from producers passing costs onto the consumer resulting from an increase in their funding obligation).

A direct increase in costs are shown in how the fee model works. Any increase in recycling system costs are re-distributed to obligated materials in direct proportion to that materials share of overall costs. In Ontario’s case, the additional $135 million dollars in program costs that stewards are now obligated for are immediately translated into an increase in fee rates, which in turn, are built into the price of packaged goods.

Indirect costs are slightly more difficult to quantify, but are based on a log linear adaptation of an input/output model used to quantify the economic and labor impacts of waste management activities. Our adapted model attempts to isolate the specific impacts of increases in waste management costs on consumption baskets.

While the materials in the accompanying document describe this model in greater detail, increases in costs borne by producers can manifest in the following ways: 1) costs being passed directly onto the consumer in the form of increased prices or a reduction in product size 2) costs are internalized, but results in reduced investment, job losses, company contraction etc. 3) some combination thereof (most realistic outcome).

What few people seem to recognize is that the potential increase in costs borne by the consumer are multiples higher than the direct increase in the steward obligation. As an example, if producers collectively reduced their investment in the province by $135 million dollars, the overall impact on the economy is north of half a billion dollars in both direct and indirect costs (as per the input/output multiplier).

A steward lead EPR program will inherently contain costs

An argument this is made in favor of steward lead EPR programs (where producers assume responsibility for the entire system), is that they have a greater ability to control costs relative to muncipalities, as they are not bound by geographical boundaries.

This is a logical fallacy for a number of reasons. The foremost issue is that there is no evidence to suggest that stewards are more efficient at operating a recycling program or containing costs. Recycle BC, which is often touted as a best practice model of steward lead EPR, has experienced the highest increase in year over year recycling system costs of any province in the country. In the past 3 years, recycling system costs have increased by more than 45%. The purported benefits of cost containment by stewards can only be achieved if there is a coordinated effort that represents the collective interests of all obligated stewards. However, due to the sheer number of participants (that vary in size, sector and locality), most stewards are largely passive participants in the Recycle BC program.

A comment made by ministry staff that “Private industry has always claimed to be more efficient than government” is a bit of a half-truth. Private companies who operate in the same space/sector as a government equivalent is often claimed to be more efficient. However, handing producers the reigns to the Blue Box is not the same thing – this isn’t a situation where the Waste Managements, Emterras and GFLs of the world are being compared to municipal waste management operators. This is a situation where we are asking major CPG companies to take control of the waste management system. By their own admission (and feel free to ask – they aren’t shy in telling you), most packaging companies have no clue how to operate an efficient waste management system. They will in all likelihood have to engage in individual contracts with waste service operators (both private and municipal) who are managing the programs now…. Except, we have the added administrative costs of having to coordinate multiple companies with multiple contractors.

There is a term in economics that we refer to as “communication externalities”. Efficiency of communication and coordination becomes more difficult as a greater number of participants enter the system, particularly if participants are of unequal size, power or do not have access to the same information. Communication externalities are often sufficient to completely deter cooperation all together. This is a very real risk as producers take over the system, particularly because they lack a common voice or entity that represents their collective interests.

A steward lead EPR program will lead to new end use applications and end markets for difficult to recycle materials

There have yet to be any examples in Canada where stewards have been able to develop new end markets or viable end use applications for composite and light-weight materials. While there have been “one off” situations where producers have worked collaboratively with the waste service providers to capture and recycle a specific materials (i.e. Green Mountain and Recycle BC partnering to recycle the K-Cup), those solutions were neither scalable (only available in one locality) or economical.

The above example highlights the issue with this line of reasoning – in the absence of a relationship that is site and situation specific, stewards do not and should not have the ability to disrupt commodity markets. If a material inherently has value, the market will signal that this material should be captured, and that there will be an end market willing to purchase that material. If commodity markets dictate that a material has nominal or no value, then attempting to collect and recycle that material will result in a significant cost, with virtually no benefit. Unless there is prescriptive recycled content legislation that mandates the use of that material in new products (which may or may not have technical barriers), then the only use for that material will be in bespoke recycling solutions that are more novel than practical.

At present, recycling markets for composite and light weight plastics remains virtually non-existent, and it is unlikely that stewards will be able to change that in the near term.

A steward lead EPR program will incent producers to design more sustainable packaging

Referring to the principles of the waste management hierarchy – reduction is preferred to reuse, and reuse is preferred to recycling, then through that lens, many producers are already developing more sustainable packaging. Once again, the issue is that most people (both policy planners and the public) conflate recycling with sustainability – if it can’t be recycled, it must be bad.

While package light weighting has often been characterized as a negative due to low levels of recyclability, most life cycle analysis studies demonstrate that the “upstream” environmental savings (resulting from a reduction in material used, efficiencies in transportation and logisitics and increased shelf life) significantly offsets the environmental impact of being unable to recycle those materials.

Existing and proposed legislation incents recycling (and in some instances, takes punitive measures towards materials that have low levels of recyclability), but offers no credit for the waste reduction that is achieved. In many ways, the existing approach may result in an environmentally and economically perverse outcome, where producers “switch back” into heavier, but more recyclable packaging.

Issues Surrounding Proposed Impacts of the Blue Box Expansion into the IC&I Sector

We have no data

EPR is fundamentally premised on being able to allocate end of life management costs to the correct obligated party. In doing so, the following information is required:

1)     Who are the generators?

2)     What is the total quantity of material being generated/recovered (by sector and by generator)

3)     What types of material (composition) are being generated/recovered (by sector and by generator)

4)     How is waste currently being managed? (who is collecting it, where does it go, where does it end up etc.)

5)     How much does it cost to manage? (Including costs by activity type – collection/sorting/baling)

At present, there is no reliable data regarding the aforementioned data points with respect to the IC&I sector. We know neither the size nor scale of the issue, and have no ability to track how waste is managed throughout the system.

In the absence of having this data, is it is virtually impossible to determine what the steward obligation should be, or how to allocate those costs to individual stewards.

We don’t have the administrative infrastructure

Collecting the necessary data (including who is responsible for gathering this information, who owns it, and how this data is verified/vetted) is something that needs to be figured out before we can even begin to have conversations surrounding expanding the Blue Box into the IC&I sector.

Further to that point, the province also needs to be able to know the roles and responsibilities of affected stakeholders regarding quantifying and allocating costs to the appropriate steward.

Given the sheer # of producers who operate in the IC&I sector, the administrative externalities associated with the above activities are enormous, and are costs that have yet to be quantified when estimating what the increase in the steward obligation may be.

We don’t know if we have the infrastructural capacity

At present, the province has no way of knowing whether there is sufficient capacity within the existing system to accommodate for increases in diversion attributable to any legislative changes. With respect to material recycling facilities for printed paper and packaging, we do not even have a list of all the private and public facilities in the province, nor do we have any estimates surrounding their approved and existing capacity.

It seems entirely plausible that capturing more PP&P from the IC&I sector would require infrastructural investments to expand system capacity (for both collection and processing), which is a cost that has not been quantified.

Ministry staff have indicated that proposed changes are not intended to take effect for 6 years, and as such, it is impossible to understand what system capacity will be then, and what changes will need to be made now. This is not an adequate answer – the decision to invest in infrastructure, even if those changes are not anticipated for another 6 years, is something that needs to be planned for now. As an example, if we know that the proliferation of light weight and composite plastics is likely to increase over time, then significant changes will have to be made to existing infrastructure will be required (although I personally feel that spending money trying to capture these materials is a fools errand).

It is not good enough to say “I don’t know what the future will look like, but you will have to pay that bill when it comes due”.

Material from schools, long term care facilities and multi-residential sectors are heavily contaminated

According to waste audits conducted for these sectors, contamination rates are significantly higher for the recycling stream when compared to waste generated from single family homes.

Schools and long term care/retirement facilities struggle with fiber contamination in particular, which significantly impairs its value, or in some instances, makes it completely unrecyclable. As such, an expansion of the steward obligation into these sectors is likely to result in an even more acute escalation in costs (beyond what has been estimated), as revenues received from the sale of collected recyclables is likely to be depressed.

Markets for recyclables are deteriorating, and an expansion is going to make it worse

Setting aside concerns surrounding contamination and its negative effect on revenue, there is also the practical issue that collecting more printed paper and packaging from the IC&I sector is going to exacerbate already deteriorating prices for recyclables.

Beginning with the Chinese sword and further compounded by the global economic slowdown resulting from COVID, prices for most PP&P is languishing. As a result, any proposed legislative change that is likely to result in more recyclable material being marketed is going to make a bad situation even worse. With that being said, that is not necessarily an outcome that needs to be avoided – as noted earlier, allowing commodity markets to operate freely is likely to result in the most economically efficient outcome.

However, lower prices for recyclables poses significant challenges to domestic recycling brokers and re-processors, which necessitates that any legislative change that can potentially affect commodity prices is approached with caution.

Existing estimates surrounding the cost of expanding the steward obligation assumes a fixed IC&I material management cost

Current estimates by the ministry surrounding the proposed expansion of the Blue Box into the IC&I sector does not take into account the composition of material from these sectors. The general expectation is that stewards will be obligated for the total system cost of servicing these sectors, and will negotiate individual relationships with PROs for how this material gets managed.

For as much as I can understand and appreciate that the obligation does not refer to specific material categories, we cannot in good faith estimate a cost for servicing these sectors without taking into consideration what materials are generated by these sectors.

Collecting uncontaminated office paper from Office Buildings is fundamentally different than collecting a mixed bale of contaminated fiber and tetrapaks from a school yard. The delta in material management costs is enormous. To say that we don’t need to take that into consideration when developing our existing estimates completely ignores the reality of the situation.

No one size fits all approach

A sentiment expressed earlier is that not all materials are created equal, and neither is all recycling. So with that in mind, why should legislation treat all materials the same way?

Proposed legislative changes under the Blue Box transition has the potential to adversely affect a significant number of stewards, particularly those who manufacture light weight and composite plastics. However, these same changes are being embraced by beverage stewards, who are looking to capture as much material as they can from both the residential and IC&I sector. Ideally, legislation should be able to allow stewards the approach that yields to most economic and environmentally sustainable outcome, while ensuring that they meet their legislative requirements.

This is why it is so critical that the goals of Blue Box legislation should be outcome based (total carbon abated) as opposed to tonnage based (recycling/diversion rates). It is possible to recycle less material in an absolute sense, but achieve a superior environmental and economic outcome by prioritizing certain materials for recovery.

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About the Author

Calvin Lakhan, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior.

The End of Landfills in Ontario? Proposed amendments to the Environmental Assessment Act and the Impact on Waste Management

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Written by Harry Dahme and Jessica Boily, Gowlings WLG

On July 8, 2020, the Ontario government introduced Bill 197 in the Legislative Assembly. Entitled the COVID-19 Economic Recovery Act, the proposed changes within the Bill amend twenty different Acts, including the Environmental Assessment Act.

While some of the amendments proposed in Bill 197 seek to address challenges encountered during COVID-19 (such as the changes to the Provincial Offences Act, covered in our COVID-19 Update), the Bill primarily includes reforms that were on the government’s agenda prior to the COVID-19 pandemic. These reforms include some of the most significant reforms to Ontario’s environmental assessment regime in many years. The Gowling WLG Environmental Law Group will be publishing a series of articles on these proposed reforms, which are expected to be fast-tracked through the Legislature this week.

From the point of view of waste management in Ontario, one of the most significant changes to be made by the Bill is the addition of a new section to the Environmental Assessment Act that would give municipalities the right to veto new landfills proposed to be located within their own borders or in adjacent municipalities where the proposed new landfill is within 3.5 kilometers of the municipal border. This amendment to the EAA would provide municipalities with the unprecedented ability to stop new landfills for any reason, even where the environmental assessment for that landfill would otherwise be satisfactory to the provincial government.

Demand the right coalition emerges

In 2018, Ingersoll Mayor, Ted Comiskey, started the “Demand the Right” Coalition of Ontario Municipalities, seeking support from other municipalities for legislation that would allow municipalities to say no to projects like windfarms and landfills.

On March 1, 2018, Ernie Hardeman, MPP for Oxford, the riding that includes Ingersoll, introduced a private members bill dealing with the issue. Bill 201Respecting Municipal Authority over Landfilling Sites Act, 2018, would have amended the EAA to prevent the Minister of the Environment, Conservation and Parks from giving approval to an undertaking unless the municipal council had passed a resolution supporting the establishment of the landfilling site. The Bill did not receive Second Reading in the Legislature and died on the Order Paper when the Legislature was dissolved for the last provincial election.

During that election in 2018, Doug Ford stated that he respected “the right for local municipalities to make the decisions best for their communities.”

Following the election in 2018, the Ministry of the Environment, Conservation and Parks (“MECP”) released the Made-in-Ontario Environment Plan, which stated it intended to provide “municipalities and communities they represent with a say in landfill siting approvals “. No firm commitment to a veto was made at that time and there were no consultations on the proposed amendments to the EAA affecting landfills prior to the introduction of Bill 197.

The state of landfill capacity in Ontario

Many Ontarians are not aware of the waste disposal crisis in which Ontario finds itself. The Ontario Waste Management Association reports that unless new landfills are built, Ontario’s landfill capacity will be exhausted by 2032. More than 80% of this capacity is located within a small number of sites (15 public and private landfills). These predictions assume that Ontario will continue to export approximately 30% of its waste to the United States, primarily to landfill sites in Michigan and New York. Should those exports stop, Ontario’s landfill capacity would be exhausted by 2028: only eight years from now. This is significant since it takes years, and sometimes more than a decade, to obtain approval for a new landfilling site.

Even before the introduction of Bill 197, the length and uncertainty of the environmental assessment process for new landfills and expansions to existing landfills meant that this crisis was not improving. While increased waste diversion is a laudable goal, even with significantly improved waste diversion rates, existing landfill capacity will be put under significant pressure in the next ten years.

Bill 197

Given the near future waste disposal crisis in the province, there is a demonstrated need for new landfills to be built and existing landfills to be expanded. While Bill 197 aims to streamline existing environmental assessment processes for some projects, it introduces a municipal veto over new landfills that is expected to almost entirely halt the planning for and building of new landfills in Ontario.

Section 10 of Schedule 6 to Bill 197 proposes to amend the EAA by adding a new section 6.01, which would provide that proponents who wish to establish a landfilling site that is subject to Part II of the EAA obtain “municipal support” for the undertaking. Municipal support must be obtained, not only from the local municipality in which the landfilling site is situated, but from any other municipality located within a 3.5 km distance from the property boundary of the proposed landfilling site. This support, as set out in s. 6.01(5), is demonstrated by providing a copy of a municipal council resolution from each of the municipalities, indicating that the municipality supports the undertaking.

This requirement applies to not only new future landfill proposals but also to landfills currently undergoing the environmental assessment process, even though EAA approval had been previously obtained for the Terms of Reference for that environmental assessment process and even though the environmental assessment process was proceeding in compliance with the approved Terms of Reference.

Proposed section 6.01 applies only to landfills, as opposed to all types of waste management facilities based on the definition of “landfilling site” which is defined as a waste disposal site where landfilling occurs.

While section 6.01 certainly applies to new landfills within the province, it could also potentially  be read to apply to expansions of existing large landfills as well. Section 6.01(3) states that the section applies “in respect of a proponent who wishes to proceed with an undertaking to establish a waste disposal site that, (a) is a landfilling site; and (b) is subject to this Part.” While the plain meaning of “establish”, which connotes the initial or first approval and construction of a project, is consistent with the meaning used within the Environmental Protection Act in the context of waste disposal sites, “establish” is not defined within the EAA itself. This leads to the possibility that the unique characteristics of any landfill expansion could lead to an interpretation that the expansion involves the establishment of a waste disposal site. If that interpretation is adopted, then that has huge ramifications with respect to the future availability of landfill capacity in Ontario, exacerbating even more the imminent waste disposal crisis in Ontario.


NOT LEGAL ADVICE. Information made available on this website in any form is for information purposes only. It is not, and should not be taken as, legal advice. You should not rely on, or take or fail to take any action based upon this information. Never disregard professional legal advice or delay in seeking legal advice because of something you have read on this website. Gowling WLG professionals will be pleased to discuss resolutions to specific legal concerns you may have.

 

About the Authors

Harry Dahme is a partner in Gowling WLG’s Toronto office and past leader of the firm’s Environmental Law Group. He has practised exclusively in the area of environmental law since 1984, and has a solid reputation as one of the foremost environmental lawyers in Canada. Harry is certified by the Law Society of Ontario as a specialist in environmental law, and is described by Who’s Who Legal: Canada 2014 as “widely regarded as a leading authority in the field,” by Legal 500 Canada 2017 as “absolutely fantastic” and by Acritas Stars 2017 as “an acknowledged expert in environmental law.”
Jessica Boily is an environmental lawyer in Gowling WLG’s Toronto office. Her practice focuses on environmental litigation, drawing on her commercial litigation background to achieve successful and cost-effective outcomes. She uses her procedural expertise and technical knowledge to advocate for her clients. Jessica understands that complex disputes require creative scientific and legal approaches. Her clients appreciate her practical advice when managing and resolving multi-party environmental disputes. When litigation is necessary, her clients know her courtroom and tribunal experience will help them achieve the outcome they want.

Lessons Learned on Collection Policies in Ottawa

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Written by the Continuous Improvement Fund

In anticipation of the curbside collection contracts renewal, pending regulatory/policy change and the development of a 30-year Solid Waste Master Plan, the City of Ottawa retained Dillon Consulting Limited (Dillon) to complete a study and develop a curbside collection model. The model assisted the City in identifying the most cost-effective curbside waste collection system to help support increased waste diversion and reduce residential garbage, while also considering greenhouse gas impact, and cost of implementation.

The Microsoft Excel model was designed as a tool to assist staff in developing curbside collection options and/or new policies. It is based in Microsoft Excel.

The different waste diversion policies that were considered in the model were:

  • Bag/container limits for garbage
  • Pay As You Throw
  • Clear bag program for garbage
  • Containerized garbage program
  • Mandatory participation in diversion programs
  • Material bans e.g., grass clippings, organics and recyclables in garbage

The collection options considered in the model were:

  • Status quo
  • Weekly co-collection of blue/black box
  • Status quo level of service with a 4-day collection week
  • 4 day collection week
  • Status quo with separate weekly leaf/yard waste collection
  • Separate bi-weekly leaf/yard waste collection
  • Weekly collection of recyclables and leaf/yard waste

The model requires input of household information, collection seasons/periods, materials collected, truck compartment and utilization parameters, collection factors, collection costs and waste tonnage breakdown by material type to establish a baseline scenario, which is then used to compare against several different collection and policy options. It can compare new collection and policy options against status quo parameters including costs, vehicles required for servicing, diversion rates, and greenhouse gas (GHG) impacts.

Modeling required resources and system performance

Designed for adaptability, the model will allow other Ontario municipalities to analyze their integrated waste collection system by revising the inputs to the model and waste collection program policy customizations. The model produces several estimated outputs, including:

  • Number of trucks required (per season, per collection stream);
  • Number of hours required to collect materials (per season, per collection stream);
  • Annual cost per household and per person ($);
  • Capture rate (kg/person);
  • Diversion rate (%); and
  • GHG impacts (tonnes CO2 equivalents per year).

Note that this study only looks at residential households that receive curbside collection and does not include bulk material collection.

Lessons learned in Ottawa

Key outcomes of the modelling exercise for Ottawa were:

  • Higher curbside collection costs are attributed to weekly co-collection of dual stream recyclables and leaf/yard waste over a four-day collection week due to the number of vehicles required.

  • The lowest collection costs are for the status quo, and separate weekly or bi-weekly leaf/yard waste collection due to a lower number of vehicles being required than the other scenarios. Separate bi-weekly leaf/yard waste collection may produce less CO2 equivalents per year than status quo for all policy scenarios modeled.

  • Weekly co-collection of blue/black box under a four-day collection week is likely to produce the most CO2 equivalents per year due to the number of vehicles required and hours collecting waste materials.

  • There appears to be a correlation between cost effectiveness and greenhouse gas emissions; higher costs are attributed to model runs that have the higher number of CO2 equivalents per year.

  • Enforcement is key.

New study in the publication Nature finds compostable coffee pods a superior alternative to plastic pods

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Written by Calvin Lakhan, Ph.D, Co-Investigator: “The Waste Wiki” – Faculty of Environmental Studies at York University

Recently, the esteemed academic journal Nature, published a study by University of Tennessee – Knoxville, which undertook a Life Cycle Assessment of compostable coffee pods. This study specifically examined the economic and environmental viability of compostable pods, relative to more conventional alternatives made from plastics.

The study found that compostable coffee pods readily broke down when included as part of the organics stream, resulting in both a cost savings of 21% relative to disposal, in addition to *improving* the quality and value of the compost.

These findings largely echo what was observed in a York University study conducted in the fall of 2018, which found that compostable coffee pods readily broke down in existing composting facilities in Ontario, and resulted in superior economic and environmental outcomes when compared to plastic and aluminum pods.

Why these findings are of particular importance in an Ontario context, is that detractors of compostable pods (which include the City of Toronto, Environmental Defense etc), continue to question the viability of compostable pods in existing composting facilities, and have even gone so far as to claim that the majority of compostable pods are being landfilled. Not only is this not true, but it adds further confusion to the conversation surrounding what materials are suitable for the green bin program.

The University of Tennessee study adds further credence to our initial findings, and adds some much needed clarity to a topic that is increasingly becoming politicized.

For any questions, comments or concerns regarding the York University study, please contact [email protected].

Goal Setting in a post Covid waste world: How have our priorities changed? What comes next?

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Written by Calvin Lakhan, Ph.D, Co-Investigator: “The Waste Wiki” – Faculty of Environmental Studies at York University

Prior to almost every facet of our world being upended by a terrible and unexpected pandemic, stakeholders were working closer and closer to what some may even call a consensus with respect to waste management. Terms like circular economy and zero waste were not just buzz words, but the cornerstone of emerging waste management policy at both local and federal levels. Both brand owners and municipalities alike scrambled to find ways to transition away from single use packaging, promoting sustainable, recyclable and reusable products to help break our addiction to disposable packaging. Plastics in particular was a term often viewed with derision, with the federal government announcing a Zero Plastic Waste initiative. Several large CPG companies followed suit, making lofty declarations of going “Plastic Free”.

It’s funny just how much can change in a matter of months.

COVID has given the entire industry (and world) a moment to pause and really ask ourselves “What it is that we want to achieve? What are the steps we need to get there? Who are the people/organizations/sectors that need to be involved? and What time frame are we operating under?”

Now some of you may be asking, why on earth would our goals change just because of COVID? Isn’t it best to keep working towards the goals and aspirations that we currently have? In short, the answer (in my opinion) is no.

While I don’t intend to come across as arrogant or some sort of authority on the topic, I have held (and voiced) significant concerns regarding existing approaches towards waste management policy and practices,  and attempted to highlight that the goals we actually had were more aspirational than pragmatic.

Consider the following statements (all actual goals)

1)    Canada will move to divert at least 75% of plastic waste from federal operations by 2030 (Canada)

2)    Canada will move to ban single use plastics by the year 2021

3)    Toronto will divert 95% of all waste by the year 2050

4)    The Province of Ontario will divert 30% of all wastes by 2020, 50% by 2030 and 80% by 2050

5)    The Ellen Macarthur Foundation’s goal is to ensure that 100% of all plastic packaging is designed to be fully reusable, recyclable and compostable (waste to energy DOES NOT count)

All of the above goals represent a tremendous amount of work and thought by individuals and organizations far smarter than me – however, when examining these goals through the lens of a sustainable framework, we see some of the practical challenges that arise, particularly in a post COVID world.

Where is the Data?

To me, the biggest challenge facing our waste management sector is a complete lack of data, most of which is necessary information before we can even begin designing policies and systems that are more sustainable in the long term.

As an example, if Toronto would like to divert 95% of all waste by the year 2050, it would seem prudent that we know just how much waste we are talking about. What so few people understand is that the figures we see regarding waste generation, waste recovery, percentage of material recycled/diverted etc. are largely based on best guess estimates.

Sometime last year, I remember coming across a news headline that boldly stated “Canada is only recycling 9% of its plastics”. The idea that a country as “green” as Canada could be doing such a poor job was almost unfathomable – both the public and policy makers alike demanded to know how we could do better. My response was perhaps more muted, and my first question was “How do we even know how much plastic we are generating the first place?”( ? (Please see my previous article https://advancedwastesolutions.ca/separating-fact-from-fiction-are-we-really-only-recycling-9-of-plastics/))

The picture that was painted for the public was heavily sensationalized – plastics are piling up in our landfills, in our waterways, and now, more than ever, consumers needed to stand up and say “NO MORE!” to single use plastics. It was an easy message to get behind, and suddenly, plastics was public enemy number 1.

Digging a little bit deeper into the issue (and the study behind the headline), it was quick to see that the projections surrounding plastic generation, recovery etc. were all modeled, using a set of heavily caveated assumptions. Without delving into an excessively long technical discussion surrounding how those figures were modeled, in short, I can say with confidence that we do not know how much plastics is being recycled – nobody does.

I don’t think many people, both within and outside the waste sector, truly understand just how little data publicly exists when it comes to waste.

As a thought exercise, which of the following information do you think we have?

1)    Total quantities of plastics (or any material) generated and sold into Ontario in the last calendar year (both residential and IC&I)?

2)    How many tonnes of potentially recovery materials ending up in landfills?

3)    The costs of attempting to recycle material at end life? (if recyclable)

4)    What quantities of waste are being self-managed on site for commercial generators which discusses on site material management in greater detail)

5)    Estimates to determine long term landfilling capacity for both residential and IC&I sources

6)    Detailed and methodologically defensible waste auditing strategies to approximate for the waste generation profiles of individual municipalities (both single family and multi-residential),

7)    A detailed overview of waste management infrastructure currently available. This includes the number of material recycling facilities, transfer stations, depots, as well as information regarding the operational capabilities of each of these sties (capacity, throughput etc.)

8)    A mass balance of where materials that is recycled, goes (what end market? In what application? Etc.)

9)    Credible and publicly accessible data pertaining to the waste generation and recovery from the IC&I sector

10) A common data repository managed by an independent body that is responsible for collecting, maintaining and analyzing data pertinent to the waste management sector that can be used to assist in policy formulation and decision making.

For all intents and purposes, we don’t have any of the above. You would be genuinely shocked just how many stakeholders overestimate how much data we have, or what can be done with it. My professional career is full of anecdotes involving stakeholders who would conduct waste audits with no consideration of sample stratification or how to develop a time series. Perhaps the most egregious example was working on a project that modeled future landfilling requirements and lifespans based on a single (and unrelated) variable. While we could probably spend a very long time debating who’s fault that is, and point fingers at one another, it doesn’t change the fact that the state of data in the waste management sector is poor. In many ways, policy planners have actually done a commendable job in doing what they have been able to given the patchwork of reliable information that exists.

However, if COVID-19 has given all of us a reason to pause, we may as well pause and see whether the data that we have, or have access to, is supportive of our ambitious goals. The lack of “good data” poses numerous challenges, namely, how we do we develop *realistic* goals that we can track, measure and work towards. What is of critical importance is that any discussions surrounding waste management policy and programming *must* be rooted in sound data. This is particularly true of any potential legislation that involves the IC&I sector – we cannot develop a potential solution for encouraging diversion in these sectors, without having a sense of the size and scale of the problem.

Vowing to keep all plastics out of landfills is a commendable goal, but only if we could tell you how much there is to actually keep out.

The importance of goal setting

The discussion surrounding data’s role in helping develop goals is a useful segue into the second part of this paper – the importance of goal setting.

As noted above, goal setting is critical for the success of a waste management program, however, goal setting should ideally address the following characteristics:

1)    What is the goal, and what am I measuring?

2)    Is my goal realistic given access to existing information, resources and infrastructure?

3)    Is there consensus about what the goal should be among stakeholders?

4)    If different stakeholders have competing goals/objectives, how do we encourage collaborative dialogue to avoid antagonism?

5)    Is there quantifiable metrics to track and measure progress towards my goal?

6)    Am I able to change my goal in response in new situations or information?

7)    How will I know if I have achieved my goal?

8)    How can I monitor the results of my goal over time to ensure continued success?

9)    How do set new goals once our initial goal has been reached?

What makes goal setting in waste management particularly problematic (beyond the lack of data), is the lack of consensus regarding what it is we are trying to achieve.

As noted earlier, there was a significant amount of momentum across the sector to work towards a circular economy and achieve zero waste – however, despite this seeming consensus, there are multiple paths to achieving a particular outcome, with very different sets of winners and losers depending on what we choose to prioritize.

To use a practical example, let’s revisit the City of Toronto’s 95% diversion target by the year 2050. In this case, our goal is diversion, and we are measuring % of total waste diverted relative to overall quantities of waste generated. As noted prior, we have acknowledged that there are data concerns regarding credibly quantifying total generation, but let’s set that aside for a moment.

In my opinion, while the 95% diversion target is certainly an ambitious and aspirational goal that we should strive for, it is not something that I would characterize as being readily achievable, for two reasons: 1) Weight based key performance indicators, and 2) The definition of diversion.

1)    The foremost issue is that diversion is a weight based KPI, in a world where our packaging and products is becoming increasingly lighter and lighter. This phenomenon, which has been characterized as the evolving tonne by the likes of industry experts @Chaz Miller and @Mariah Kelleher, shows that the proliferation of light weight, composite materials results in materials that are volumous, but not heavy. Compared to the average mix of materials found in the Blue Box a decade ago, current materials are anywhere from 15-25% lighter.

Why this maters is that a diversion target (measured against total waste generation), is inherently going to be handicapped by the fact that the total tonnes being managed in our waste management system is decreasing over time. It is also worth noting that the types of materials that will need to be collected to achieve incremental diversion will be difficult to recycle material. These materials are often incompatible with existing collection and processing infrastructure, with limited end market applications. In short, there is very little economic incentive to recover these materials – the economics of diversion, and more specifically, recycling, is often untenable (to be discussed in greater detail later in this paper)

2)    While other jurisdictions (i.e. Belgium) have significantly higher diversion rates for their residential recycling programs, the way we choose to define diversion in Ontario differs. In certain jurisdictions, waste to energy (the 4th R), is considered a viable method of keeping materials out of landfills. However, in Ontario, waste to energy is not considered a viable form of diversion. While this short article is not intended to debate the merits or viability of waste to energy, I do want to highlight that the goals that we set should be consistent with the infrastructure and rules we have in place.

In short, it is impossible for Toronto to reach their goal of 95% diversion without considering some form of energy to waste facility. Even if we assume an idealized scenario where all households put their waste in the appropriate Blue and Green bins, residue losses at sortation facilities often range from 8 – 12%.

Balancing goals with our budgets

Returning to the topic of economics, it is impossible to develop sustainable waste management goals without carefully considering the economic impacts of attempting to realize those goals.

As noted in an earlier section of this paper, some of the goals we have defined for the waste management sector include the recyclability of products/packaging. The Ellen MacArthur foundation has even gone so far as to say that ALL products must be made up of materials that can either be recycled, reused or composted.

While this goal is certainly commendable and something that should be worked towards, it is also not realistic given the practical constraints of existing waste management systems. Even prior to the COVID pandemic, the recycling industry for printed paper and packaging was already on extremely unsteady legs as a result of the Chinese National Sword. These effects were only exacerbated by the impact of COVID, which has essentially pulled the rug out on commodity pricing and adversely impacted the flow of markets. In some instances, virgin resin is cheaper than recycled resin, and is threatening to undo years of progress with respect to increasing recycled content in consumer goods.

What industry will do in response to this crisis remains uncertain – there is no guarantee that recycled markets will recover in the immediate future. Policy planners are now facing the very real choice of continuing to pursue a goal of recyclability/compostability/reusability, despite a rapidly changing landscape that is extraordinarily difficult to predict and plan for. In turn, manufacturers must make design decisions today that will have an impact on their operations for months, if not years to come.

Second chances: Plastics, can we try again?

While COVID has provided the waste sector with an opportunity to pause and evaluate both short and long term priorities, perhaps the most interesting (and unintended) impact is how attitudes towards plastics have shifted.  Historically, the characterization of single use plastics is that they are terrible and should be discouraged. However, in a post COVID world, both households and retailers are at a heightened state of anxiety with respect to product safety. Suddenly the individually wrapped cucumber and the plastic bag of apples doesn’t seem quite as silly as before, as it minimizes direct food handling and helps mitigate against the risks of contracting or spreading the virus. Increasingly, both consumers and retailers are looking for opportunities to minimize the risk of contamination (largely through direct handling of a particular item), while simultaneously increasing shelf life, both at the store, and in the home. The use of plastic packaging, particularly plastic film, has been shown to act as a barrier to bacteria and viruses, while also promoting product longevity and avoiding food waste/spoilage.

Plastic has also played a critical role with respect to personal protective equipment. While these items are largely characterized as single use (i.e. plastic gloves), the relative scarcity of PPE relative to the overwhelming demand demonstrates that there are no readily available substitutes that can be used in lieu of plastics. Whether we like to admit it or not, plastics plays a vital role in the war against COVID, and decisions to ban or limit the use of plastics can have detrimental and unanticipated impacts. Very rarely are material bans an effective long term waste management strategy – generally speaking, optimal outcomes are born out of giving manufacturers more options, not less.

What the COVID pandemic has demonstrated is that plastics have a role to play in our economy, but we need to recognize that not all plastics are created equal, and by extension, not all goals are going to apply to everything, everywhere. Perhaps one of the biggest failings of the prior framing of the plastics issue, is that the topic was often characterized in binary terms: Good/Bad, For/Against. No issue, particularly one as nuanced as product design for the environment and end of life, can ever be distilled into a clear black and white answer. The same consumers who were calling for plastic bans are now the same ones clamoring for plastic gloves. Of note, the momentum behind reusable and refillable packaging has also come to a grinding halt as a result of COVID. Many retailers have pressed the pause button on implementing reusable packaging at a wide scale, while many of the mediums in which reusable/refillable containers are encouraged (e.g. using a refillable mug for coffee) have been abandoned temporarily until the pandemic begins to abate. In addition to the normal risks associated with cross contamination when allowing used containers into a retail space, consumers have expressed ambivalence about the risks associated with COVID.

I use this aforementioned example to demonstrate that opinions and attitudes are often malleable, while infrastructure and legislation are not. Responding to changes in consumer sentiment or political will, must be weighed against what can reasonably be achieved given resource and time constraints.

While the COVID crisis will ultimately be seen as a black stain in our history, it does present a unique and fairly rare opportunity to take stock of our waste management system, and decide what should come next.  This unprecedented situation highlights that we need to crawl before we can walk, and walk before we can run. Setting ambitious goals is definitely something that should be encouraged – however, ambition is not the same as hubris. Without data, stakeholder consensus, jurisdictional harmonization and the ability to monitor, evaluate and re-calibrate our goals, we are setting the sector up for failure. Always keep in mind that the goals of today, are not necessarily the goals of tomorrow – as COVID has demonstrated, life can change when we least expect it.

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About the Author

Calvin Lakhan, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior.