Extended Producer Responsibility (EPR) Update
EPR Update: August 11, 2014
It has been over year since this site was last updated with new information on the progress of PPP EPR in BC. Rest assured this was not due to a lack of events – quite the opposite in fact!
Here is a run-down of the key events that have taken place since our last update:
- Local governments across BC made their decision about whether a) to accept MMBC’s “Market-Clearing Price” incentive and continue running their programs themselves, b) to hand over control and operation of their recycling programs to MMBC, or c) to opt-out of the MMBC system altogether. The vast majority chose option a), with only a handful going for b) (i.e. Coquitlam) and c) (i.e. Delta).
- MMBC solicited bids from material processing companies in the fall of 2013 and in February selected a single entity to process all of BC’s material
- There was a tremendous amount of controversy and concern from all types of stakeholders in the lead up to program implementation, including a province wide-campaign call “RethinkItBC” petitioning for a delay and more consultation
- The program commenced as per the original plan, on May 19th, 2014
For local governments, material collectors, depot operators, processors and obligated-producers, the last few months have seen a wholesale change in the world of residential recycling. The transition to a producer-run system has changed the relationships of all stakeholders in the recycling supply chain. Even those with decades of experience in waste and recycling have never seen anything quite like what has occurred with PPP.
And some new developments over the last few weeks suggest that the ride isn’t quite over yet. Unlike other provinces with government-mandated single stewardship agencies (i.e. Stewardship Ontario and Multi-Material Stewardship Manitoba), BC’s Recycling Regulation’s 100% producer responsibility model allows for any obligated producer or a stewardship agency (aka a PRO or “Producer Responsibility Organization”) to submit a stewardship plan. This means that there can be more programs than just MMBC’s and that they can potentially compete with one another. And just as MMBC’s program has begun to roll out, a new organization called “StewardChoice” (www.stewardchoice.ca) is now in the process of offering an alternative way for producers to discharge their obligations under the Recycling Regulation.
StewardChoice is proposing a system centered around free market based competition. The full details of the StewardChoice plan can be read here: http://stewardchoice.ca/wp-content/uploads/2014/06/StewardChoice-Stewardship-Plan.pdf . The plan is currently undergoing consultation, including direct discussions with key stakeholders and webinar sessions open to anyone interested in hearing about the plan. At the end of this consultation period, a final plan will then be submitted to the BC Ministry of Environment for approval. StewardChoice’s hope is to have their program underway by 2015.
An additional stewardship plan was also submitted by the Brewers Distributor Ltd., exclusively for domestic beer packaging. This plan was submitted at the same time as MMBC’s however it is still awaiting approval and has yet to be implemented (it can be read here: http://www.bcbda.com/sites/default/files/BC%20-%20Schedule%205%20-%20product%20stewardship%20plan%20-%20FINAL%20-%20Nov%2012.pdf )
At this time, no other plans have been submitted, however the regulation allows for new plans at any time. It appears as though it may be a while before BC’s PPP stewardship system takes shape for the long term. Interesting times ahead to be sure, so stay tuned.
EPR Update – July 9th, 2013
A lot has happened with PPP-EPR in the three months since our last update. Here is a quick run-down of the key events:
PPP Stewardship Plan Approval: On April 15th 2013, the BC Ministry of Environment officially approved the 3rd version of MMBC’s proposed stewardship plan (available here: http://www.multimaterialbc.ca/sites/default/files/documents/pdf/plan/MMBC-PPP-Stewardship-Plan-Apr8-2013.pdf ). This was a critical event because the process had basically been put on hold pending approval. With the Ministry giving the okay, MMBC has since moved on with the next stages of the process.
“Market Clearing Prices” Released: At the beginning of June, and following a period of surveying and researching, MMBC finally released its various “Market-Clearing Prices” (MCP) for the different types of collection:
For single-family curbside: a system of incentives paid per household serviced, tiered based on household density and method of collection (single vs. multi-stream), with an increasing schedule of “performance bonuses” available for higher and higher kgs recovered per household
For multi-family collection: a system of incentives paid per household serviced, tiered based on household density and method of collection (single vs. multi-stream), with an increasing schedule of “performance bonuses” available for higher and higher kgs recovered per household (with lower thresholds compared to single family)
- For depot: a system of incentives paid per tonne of each different type of material collected and shipped from the depot
- For glass: a single collection incentive of $80 per tonne of source-separated glass collected, across the board (no differentiation based on density or method of collection)
- Local government participants will also be eligible for both “Resident Education” and “Service Administration” Top-Up Allowances (a set dollar amount per household serviced in the area).
Statements of Work and Other Documents Released: Following the release of the MCPs and a corresponding information session on June 7, MMBC then released a series of detailed documents outlining the expectations for the different types of collectors (single-family curbside, multi-family curbside, and depot). MMBC has many expectations of program collectors, from things like reporting and contamination in loads, to driver etiquette and keeping trucks clean, as well as a long list of others. All of these details can be found in the documents accessible here: http://createsend.com/t/j-0C5F454BB4042F37
So what happens now? Here is a basic timeline of expected events over the next year or so:
- Local governments consider whether or not to accept MMBC’s offered MCPs (or to opt out of the program entirely and maintain the status-quo, at their own cost); responses are due by September 26, 2013
- Once all local government responses have been received, MMBC will simultaneously put out RFPs for “post-collection services” (primary material processing such as what Urban Impact does) and for collection in any municipalities that decline the MCP; they will also finalize service agreements and other documentation with those local governments that accept the MCP
- MMBC will review proposals from this round of RFPs and begin to select service providers across the province; there will be literally hundreds of contracts to set up
- Once all the administrative work is done, the program is projected to begin operations in May of 2014, however given the work to be done and the tight timelines, this is likely a very optimistic start date
It is also important to not forget about the producers in all this (an easy thing to do when you are a recycling company!). MMBC is currently trying to track down all PPP “producers” in the province and get them signed up with the MMBC program. Getting as many as possible signed up will be crucial to making sure everyone pays their fair share, to keeping individual producer costs down and to minimize free-riding. MMBC is actively sending letters to potential “producers” to make them aware of what’s happening and encourage them to sign up.
Stay tuned for more updates as the process steams ahead!
EPR Update March 22, 2013
It has been a few months since our last update on the PPP situation in BC, and therefore high time we got everyone back up to speed!
A few days following our last post in November, MMBC submitted an official stewardship plan to the BC Ministry of Environment. This was followed by submission of a slightly revised plan on February 25, 2013, which included clarification of some plan aspects, as well as full reproduction of additional stakeholder feedback (follow this link to view the report: http://www.multimaterialbc.ca/sites/default/files/documents/pdf/plan/MMBC-PPP-Stewardship-Plan-Feb25-2013.pdf ).
At the most general level, the plan follows this framework:
-MMBC will determine a “Market Clearing Price” for collection of PPP, based on their perceived cost of an efficient collection program; both depots and curbside collectors will receive an MCP, but it is not yet known how many different MCPs there will be for different scenarios (i.e. urban vs. rural, curbside vs. depot)
-Local governments currently in charge of collection will have the option (a “Right of First Refusal”) to accept the MCP and continue their existing programs, or to reject it, in which case MMBC would take over recycling altogether.
-In addition, MMBC will seek bids from material processors (such as Urban Impact) for different regions’ material throughout the province; there will be contracts between MMBC and their processors, which may also be contingent on certain arrangements between collectors and the processors bidding on their material.
There is no doubt that the system being envisioned is a significant departure from what exists now.
One departure that recently exploded in terms of the mainstream news media, is the issue of glass in the Blue Box. Part of MMBC’s mandate is to harmonize recycling of PPP throughout the province, part of which means a standardized list of acceptable materials collected at curbside, at depots, or not at all. MMBC has put out a draft version of such a list that includes a proposal to remove glass from Blue Box curbside programs and have it collected by other means (i.e. depots or drop spots). This suggestion spurred a backlash of sorts, mainly from local governments and residents concerned about “taking a step backwards on recycling”, and convenience issues. The main reasons to remove glass center on its negative effects on other materials in the mix and on processing equipment, as well as its negative value and limited recycling applications when collected using curbside systems.
Check out this Global News story on the issue, featuring Urban Impact President, Nicole Stefenelli: http://www.globaltvbc.com/metro+vancouver+shocked+by+call+to+dump+glass+from+blue+boxes/6442800303/story.html.
Here is another link to some of Nicole’s opinions on the issue from her blog: http://blog.urbanimpact.com/
We have also seen a recent uptick in EPR interest from producers – those responsible for making the stuff in the Blue Box and paying for the new system. MMBC hosted information sessions for producers during March which were well attended by a wide variety of increasingly interested producer groups. Following the end of March, MMBC will likely be charging late fees for new producers signing up with their program, so producers would be advised to get informed and start looking at their options immediately.
The next big event in the process will be when MMBC proposes their official Market Clearing Prices to municipalities, who will then have to decide whether they are in, or out. This will likely be a very difficult decision for many cities to make, and they will only have 60 days to do it. Things definitely have the potential to get political and controversial, so stay tuned.
EPR Update November 14, 2012
The last few weeks have seen a flurry of activity on the EPR front. At the time of our last update, the group representing BC newspapers had left MMBC to investigate alternative options for newsprint recycling, including the possibility of a separate stewardship plan and system just for newspapers. This group has since weighed their options and is looking like they will re-join MMBC on a single plan for PPP.
The original schedule had the plan consultation and drafting process taking place between June and November prior to the final draft being submitted to the government on November 19th. However, due to the circumstances with newspapers as well as some apparent behind-the-scenes wrangling, the process has been significantly compressed, with the same group of consultants that worked on Phase 1, attempting to complete Phase 2 over the course of just a few weeks. They definitely have their work cut out for them!
Since the beginning of October, MMBC’s consultants have been pounding the pavement across BC, consulting with stakeholders and working to put together an initial stewardship plan for PPP. This process culminated in the publication of an initial draft plan (available here: www.multimaterialbc.ca ) on October 23rd, followed by an official stakeholders meeting on October 29th.
The meeting on the 29th was similar to the one that took place in February for Phase 1. There was a series of presentations of different parts of the plan, each followed by a Q&A section. At this point, the plan is relatively short – only 30 pages – and there is a lot of important detail left out. It was no surprise, therefore, that a lot of questions were asked throughout the session. The main stakeholders: “producers,” local governments, the private sector recycling industry, as well as citizens’ groups, all had a lot of questions to ask.
Following this session, MMBC gave an open invitation for any and all interested parties to prepare and submit comments and questions on the plan as part of the official consultation process. Initial comments were due on November 9th, but the consultants made it clear that consultation will continue beyond this date, through to the end of December.
For a great example of the type of comments MMBC will be getting, Urban Impact highly recommends a recent blog post from John Mullinder of PPEC: www.ppec-paper.com/index.php/grocers-need-to-manage-change-not-give-away-the-store Urban Impact shares a lot of the same concerns found in this blog.
Anyone with an interest in the plan should put their comments together and submit as soon as possible.
MMBC Makes First Big Decision; Newspapers Decide to Go it Alone
When we last left off, the MMBC group of stewards had just received a list of program design options, along with a slew of feedback from the many stakeholders involved. Reports were that 150-200 separate stakeholder submissions were received, so MMBC obviously had a lot to consider in the lead up to the decision.
In the end they chose a combination of two options outlined in the report: “1A – Contract with Collectors for All Services” + “2B – Provide Incentives for Processors for All Services.”
A lot of the stakeholders involved had hoped that the decision on an option would provide some much needed certainly as to where things are headed. In reality though, this particular decision does the opposite. Because it is a combination of options, the specific operational details in the report don’t necessarily apply anymore. In addition, the precedent-setting nature of this decision means that we don’t have existing case studies to look at and learn from. This all means that we still have some more waiting to do before getting anything close to a clear picture of what the new system will look like.
Following this decision, MMBC released an RFP soliciting consultants for “Phase 2” of program plan development (to see the RFP, visit: http://www.wmabc.ca/#!forms-&-files). Whoever wins this contract will help determine a wide variety of highly significant “details” that will have massive consequences for recycling in BC. Among other things, they will be reporting to MMBC on:
-which materials should be included in the program
-the roles and responsibilities of all impacted stakeholders
-how the system will be financed
-how performance will be measured and reported
-a consumer-awareness education strategy
-a stakeholder engagement and consultation strategy
The project will be no small feat for the successful bidder!
MMBC hopes to have the consultant selected by mid-June, with the work beginning immediately and culminating in a final submission to the Ministry of Environment in November. Although not set yet, the next round of official stakeholder consultation will likely take place in early fall.
In other big EPR news, one of the 5 founding members of the MMBC group, the Canadian Newspaper Association, has pulled out and will be going it alone from here on in. It is likely that they saw the MMBC group heading in the same direction as Ontario, where newspapers have had some bad experiences, and thought it in their interests to design their own system. Some allusions were made to this in a Vancouver Sun article that came out just before this decision.
The consequences of this could be far reaching. Does it mean there will be a whole separate system for Newspaper? Might writing and packaging papers go along as well? What does it mean for multi-stream vs. single stream collection? Time will tell (hopefully sooner than later)!
February 29 , 2012 EPR Update
Big Things Happening in EPR in BC!
February saw some major movement on the EPR front. Early in the month, MMBC’s team of consultants from Glenda Gies & Associates released two important reports:
Current System for Managing Residential Packaging and Printed Paper in British Columbia
Packaging and Printed Paper Stewardship Design Options
The first report basically explains what residential recycling in BC looks like right now. It summarizes which municipalities receive curbside vs. depot collection, which have single-stream vs. multi-stream, which materials each city accepts in Blue Boxes etc.
The second report gives us the first, high-level glimpse at what the new EPR program for packaging and paper might look like. It sets out a variety of different options for how the financing on the new program might work: using contracts, incentives, direct delivery, or some combination thereof. Both reports are available in the links below.
Two weeks after releasing the reports, MMBC and their team of consultants held a special, all day update to explain the content of the reports and field questions. The Q&A session that followed was lively and revealed that there is still a lot of uncertainty about EPR for paper and packaging. In particular, the audience demanded a clear answer on the new program’s diversion and recycling goals; the 75% number has been mentioned by the government, but at this point nobody seems to be able to answer the question, “75% of what?”
Following the session, stakeholders had until February 28th to provide commentary on the reports. There is no doubt that a wide spectrum of local governments, private recycling firms, non-profit organizations and citizen groups made their voices heard. MMBC now has the difficult task of reviewing the submissions and making a final decision on which option to select in a month’s time. Stay tuned!
Click on the following links to find copies of the MMBC reports as well as other information on what is happening in EPR in BC!
Update on Designing a Producer Responsibility Program for the Packaging and Printed Paper for British Columbia: Glenda Gies and Associates
A team from Glenda Gies and Associates, who are undertaking an analysis of the current Packaging and Printed Paper Product (PPP) recycling system in BC, are also developing program design options. Glenda Gies, Maura Walker and two additional team members, Geoff Love of Love Environmental and Usman Valiante of Corporate Policy Group, joined Coast Waste Management Association on Tuesday December 6, 2011 to share information about their project and to listen to suggestions from the audience on designing a producer responsibility program for printed papers and packaging for BC.
What’s Been Happening with EPR Lately?
Urban Impact has been front and centre at recent Packaging and Printed Paper EPR consultation sessions. The BC Ministry of Environment is currently in the middle of a Fall Consultation tour.
The largest event thus far was held in Richmond in September, cohosted by the Solid Waste Management Association of North America’s (SWANA) Pacific Chapter. This session was very well attended and included delegates from various local governments, the recycling and retail industries, as well as a wide variety of consultants and one citizens’ initiative.
At some of the more recent EPR events, the Ministry of Environment has been been accompanied by Allen Langdon. Mr. Langdon is the chair of the new Multi Material British Columbia industry stewardship agency, which is taking the lead on the new EPR regulations as a representative of packaging and printed paper producers in BC. At the session, Mr. Langdon has been presenting information about MMBC and its role, as well as fielding many questions.
The consultation sessions have shown that there is a lot of stakeholder interest in EPR developments in British Columbia, particularly from local governments and the recycling industry, who each are concerned about how their roles might change under the new 100% steward-run program. It is interesting, and perhaps somewhat concerning, that although the aforementioned stakeholders have been out in full force, regular citizens – all the people who actually put their recyclables in the Blue Box and help keep the program going – have been notably absent. We believe that it is very important that their voices be heard in this debate, as they are really the biggest stakeholders of all.
EPR Questions and Concerns Raised During the Consultations
- Why has such a broad range of materials been condensed together into just one product category?
- The “Packaging and Printed Paper” category encompasses a huge variety of materials, many of which are not recyclable. Are we going to be putting them all in our Blue Boxes under the new program? If so, what’s going to happen to all the non-recyclable stuff? Will it be incinerated to recovery energy?
- How exactly is the financing of the new system going to work? Who will pay, and based on what?
- In some situations it’s tough to identify a “producer” . Who will be responsible for paying for waste that enters BC via cross-border shopping or mail-subscription magazines, for example?
- How will all producers, even the smaller ones, be held financially accountable?
- Will the new programs be oriented towards local or global recycling markets?
- Will there be some “Continuous Improvement Fund,” like in Ontario to provide financial incentives for recycling infrastructure and R & D in BC?
- Where will municipalities fit in? What will happen with all their existing capital such as trucks and carts?
- Will the existing beverage container deposit system be affected? Will deposits be added to new products such as milk containers?
- Why has only the residential collection system been considered ? Why not the ICI (Industrial, Commercial, Institutional)?
- How can we ensure that we don’t make the same mistakes as other jurisdictions that have implemented packaging and paper EPR?
Where do we go from here
Check the Recycling Council of British Columbia website for updates regarding MMBC-led consultations, tentatively scheduled for next fall.
Find a new Ministry of Environment information brochure on EPR on the RCBC website: http://rcbc.bc.ca/files/u7/epr_111018_pppbrochure2011.pdf
A new online consultation tool Placespeak is being used for continuous consultation throughout the whole EPR development process.
Visit the website, register and contribute your questions and comments for consideration: http://www.placespeak.com/topic.php?id=321
Interested in finding out more about EPR?
Be part of the EPR conversation! If you have any questions or want further information on anything related to the above, please contact:
New Westminster Plant
Tel. 604-517-0640 ext. 402
Urban Impact Upcoming EPR Events
Stay tuned for information about an upcoming Urban Impact event where we will explore sustainable solutions to the challenges surrounding EPR.
Urban Impact featured in the News commenting on EPR
Urban Impact President and CEO Nicole Stefenelli believes that the recent introduction of EPR for paper and packaging is worth paying attention to.
Click here to listen to Nicole’s interview on CKNW’s Weekend Morning News with Jill Bennett regarding the future of waste reduction in our region.
EPR Useful Resources and Links
Want to be at the front of the developments in EPR? We have suggested some resources that you may find useful. This is not an exhaustive list. If you can’t find what you need here, please contact us and we will do what we can to help.