In the interest of fairness, I have reproduced a letter from Carol Hochu, Executive Director of Ontario Electronic Stewardship (OES) responding to my recent blog post about Ontario’s underperforming (in my opinion) WEEE program. I offer the letter unedited and in its entirety without editorial comment. I will leave this posted for a week and next week (Monday, November 15) probably comment or reply to it in this space, depending on other comments that might be posted. My goal has been to get a conversation going about this program. Anyway, here’s Ms. Hochu’s letter:
I am writing in response to the blog posting from your editor-in-chief Guy Crittenden dated October 21st (Ontario WEEE Program World’s Costliest and Worst?). Given that Mr. Crittenden obviously shares Ontario Electronic Stewardship’s (OES) commitment to the safe and responsible diversion of electronic waste in our province, it is a shame that he didn’t take more time to research the topic. The posting contains incorrect facts and misleading comparisons and assertions that can only be fairly described as unfounded. All of these could have been avoided with the benefit of contact with OES to confirm information. One also suspects that, at the heart of the matter, is a fundamental policy difference as to how electronic waste should be managed in Ontario – and by whom. Such differences of opinion are well worth debating, but only in the presence of a transparent and accurate set of facts.
Allow me to highlight just a few of the most glaring examples:
• The posting says that Ontario’s WEEE program is the most costly in the world at $3500 to $4400 per tonne. This is incorrect. The true cost for the Year 1 WEEE program was $1604 per tonne. Publicly posted data obtained from most recent annual reports for various provincial programs shows the per tonne cost varies from roughly $1180 to $1840 per tonne. OES fits comfortably within that range, notwithstanding the fact that the program has only just completed 18 months of operation.
• The author condemns the efficacy of OES’ performance as compared to Alberta. But his figures are misleading. To compare Ontario’s performance in its first year of operation with Alberta’s performance in its fifth year will obviously lead to exaggerations. With four additional years of operations, consumer education and community involvement, any jurisdiction is going to do better. A fair comparison would be to ask what Alberta did in its second year of operation as compared to where Ontario stands now half-way through its second year. The answer is that Alberta was handling1.9Kg/per capita of electronic waste whereas Ontario is managing 2.39Kg/per capita as of September 30th (i.e. after 6 months of our second year of operations).
• The posting makes much of the fact that OES collected only 17,000 tonnes of e-waste during its first year of operation. While accurate, that figure is employed in a misleading fashion. All early-year WEEE-type programs underperform as compared to later years. In Ontario’s case, not only did the program launch during a global recession, it was challenged by host of issues including a city-wide municipal strike in Toronto (the program’s largest municipal collector), legacy contract obligations in many municipalities that reduced initial local participation in OES, and the natural nascent awareness issues that will confront any first year program, to name but three. Evidence that these factors are not only germane but are being overcome is found in the fact that to-date, OES Year 2 performance has improved by more than 100%.
There are other examples of weak arguments. Comparing Ontario’s program performance with Switzerland, for example, is strange. Europe includes wholly distinct categories of product (e.g. white goods) within its programs, boasts significant cultural and geographic differences when it comes to recycling and waste diversion habits, and has had a far longer experience in this program area.
OES does not lay claim to perfection. Due to the factors cited earlier, we did witness a lower-than-desired rate of participation in Year One. Naturally, we are eager to see stronger results. However, the program is confronting its challenges, building momentum and improving its performance. Tonnes collected are up substantially compared to the first year. New incentives have been implemented that will intensify our service provider participation. And a comprehensive performance audit with WDO is scheduled to begin shortly. Ontarians should have no doubt as to the commitment from OES to ongoing and demonstrable performance improvement.
It bears mentioning however, that underlying the errors and questionable arguments, there remains a fundamental disagreement of policy. It is even acknowledged by the author when he states that his magazine and editors always opposed the concept much less the reality of the OES program.
Given the editor’s fondness for jurisdictional comparisons, it may come as a surprise to learn that the facts are clear: When jurisdictions involve industry and retailer collectives in taking responsibility for e-waste, results get delivered. This approach places performance under a spotlight. It creates accountability. It incentivizes action. Jurisdictions without WEEE programs such as OES simply don’t get the diversion job done.
OES welcomes the opportunity discuss its performance and its operations with those in the industry. We are in constant search of improvements and therefore welcome such advice. However, we naturally ask that any such dialogue be based on actual data, facts and fair comparisons. Perhaps in the future, we can work more closely to ensure an objective and unerring set of facts is offered to the public.
Carol Hochu, Executive Director
Ontario Electronic Stewardship