Okay, for about a week I’ve left the reply up in this space from Ontario Electronic Stewardship’s (OES) to my blog entry criticizing Ontario’s program for waste electronics and electrical equipment (WEEE). (See “Ontario’s WEEE program world’s costliest and worst?” October 21, 2010.) Now it’s time to respond.
It’s important to note that my initial blog entry regarding the performance of Ontario Electronic Stewardship’s (OES) WEEE program was made at a time when OES had failed to publish any reports of its program performance for over 6 months — contrary to S. 33 of the Waste Diversion Act. When OES did respond to my blog post they never mentioned anywhere in their response that a summary of the program’s performance was quietly posted on Waste Diversion Ontario’s (WDO) website sometime late in October. That report– not to be found on OES’s own website — OES Report on Performance of Phase 1 Waste Electrical & Electronic Equipment (WEEE) Program April 1, 2009 to March 31 2010 confirms the following
• Verification that OES collected a total of 17,303 tonnes in its first year of operation (Page 7) and that OES collected $44,508,436 in eco-fees from consumers in its first year (Page 8) – therefore the Year 1 WEEE program cost Ontario electronics consumers $2,572.30/tonne – the most expensive in Canada. This number does not jive with the unreferenced $1,604/tonne claimed by OES. Why?
• The Ontario WEEE program recovered 1.31 kg/person in its first year of operation — the lowest in Canada – versus 1.9 kg WEEE/person for Alberta in its first year of operation — an abysmal disaster given that the GTA alone has 51% more people in it than does all of Alberta.
I would make a couple of additional points about OES’ response in context of the Report on Performance:
• I’m not sure what a global recession has to do with pulling WEEE from people’s basements and into the Ontario WEEE diversion program; in fact were OES to reward people financially for returning WEEE for recycling that probably would do more for increasing recovery in a downturned economy than otherwise. That OES also cites the Toronto garbage strike as part of the cause for poor performance just makes the case that OES is relying on municipalities to recover what the OES program should be proactively recovering through financial incentives and a comprehensive collection network.
• The revised “baseline” for all WEEE generated in Ontario available for collection is 63,968 tonnes (Page 15) of which OES recovered again only 17,303 — that means 46,665 tonnes or 73% tonnes of e-waste flowed outside of the OES program to places unknown.
• OES planned to have 9,994 tonnes of electronics sent for refurbishment and reuse in year 1 but only managed 215.7 tonnes or 2% of their target.
• 3,314 retails signed up with OES to collect eco-fees from consumers and pay them directly to OES on electronic product manufacturers’ behalf. So, where the Ontario government has been claiming manufacturers pay for the program in fact manufacturers have signed up retailers to levy consumers directly and thereby take themselves out of the payment process completely.
It is not true that our, “…magazine and editors always opposed the concept much less the reality of the OES program.” What we have opposed is how the OES program is designed not to work. OES employs a bizarre quota and allocation scheme that undermines rather than promotes the recovery and recycling of WEEE. That the OES program would fail was predicted in 2008 when a group of Ontario processors noted that what OES was proposing as its WEEE diversion plan was, “…a monopolistic “flow control” model (with a new convoluted OES processor tendering scheme to provide a price control scheme with a façade of “competition”) that will achieve nothing except disruption to the existing collection and processing market.”
Fast forward almost three years and that is exactly what has happened. The OES economic design of its program is fatally flawed. Consider this description of the OES model by Sims Recycling Solutions — Ontario’s largest WEEE processor (and one established long before Ontario’s WEEE program arrived):
“Under the WEEE program all WEEE collected by registered collectors is consolidated (in OES controlled consolidation centers) and then allocated to WEEE processors under a quota system. There is no way for a processor to “grow the business” — any WEEE collected by a given processor on its own initiative is then allocated to its competitors by OES based on the set quotas.
As an example, if Sims Recycling Solutions were to organize and fund a creative collection event (say through a school board or Rotary Club) we would only receive our allocated 30% of the WEEE we collect for processing despite the fact that Sims Recycling Solutions was responsible for recovering 100% of this material. The other approved processors would receive the remaining 70% of what Sims Recycling Solutions collected despite not being involved in the development or execution of the innovative collection event.”
The most fundamental problem is that while OES operates this quota system and its stewards pass on electronic stewardship eco-fees to consumers, the financial incentives paid to OES approved WEEE processors registered with its program are insufficient for them to compete with entirely unregulated WEEE “recycling” businesses operating outside of the Ontario WEEE program. The result is that most WEEE generated in the province bypasses the OES program and is simply brokered out-of-province to destinations unknown.
As remedy I think the government:
— Should dissolve OES and call for a new Industry Funding Organization that includes participation of stewards, WEEE processors (reuse/refurbishers and recyclers), environmental groups and consumer advocates;
— The WEEE program should have diversion targets and environmental performance standards written into regulations under the Waste Diversion Act;
— WEEE stewards need to be held to the Competition Act to ensure that both recyclers that provide service to the program and consumers that pay electronic stewardship eco-fees are protected from anti-competitive behavior.
— WEEE materials should be banned from landfill (with the ban phased in as diversion options become available, but the phase in should not be overly drawn out).