On February 10, 2014, Matt Prindville, Associate Director at Upstream (formerly the Product Policy Institute) published an online article entitled”The Burning Question” that I reproduce in full below. (If you wish to skip quickly to the link, it is here: http://upstreampolicy.org/the-burning-question/)
I have a lot to say about this article, all of it positive, and I suggest you simply read Prindville’s article and then my comments below it on the Upstream website, along with other people’s comments. It’s one of the more interesting discussion threads I’ve come across recently.
Prindville’s article concerns British Columbia’s EPR programs and the way in which Metro Vancouver’s incineration plans may undermine the potential for design for environment (DfE) as the waste-to-energy option will swallow up all the non-recyclable packaging, instead of forcing producers to adopt fully reusable or recyclable materials.
As I mention in my reply to Prindville’s article on the Upstream website, I recently completed a long article on Metro Vancouver’s waste plan (and related issues) that will be the cover story for the forthcoming edition of Solid Waste & Recycling magazine (February/March edition). In that article I touch on some of the issues raised by Prindville.
One more thing: at the Recycling Council of Ontario’s recent Annual General Meeting one of the speakers was from Germany’s competition bureau. He noted big improvements in that country’s recycling rate ever since Germany broke up the monopolies that used to control the Green Dot stewardship programs mandated by Germany’s packaging ordinance. (It’s the same kind of thing being called for by our magazine contributors in Canada.) He was asked in a fairly pointed way if he’d seen much “design for environment” over the years and the answer was “no.” Sure, there was quite a bit of “lightweighting” (because that saves industry money) but not much change in design and materials.
To my mind, this underscores the validity of Prindville’s argument. Germany, like most other European countries, combines product stewardship/EPR with incineration. The consequence is a largely “business as usual” scenario with stewards picking up the net cost of recycling but not making a lot of other changes. Why bother when the laminates and other difficult materials can just be fed into the maw of waste-to-energy plants?
This is something worth thinking about, especially in BC which is doing the best job of any jurisdiction in North America of promulgating EPR for products, paper and packaging, but whose largest regional government — Metro Vancouver — is intent on building one or more large waste-to-energy plants.
Wouldn’t it be great to see BC test EPR in a more true way, and stimulate DfE, without the incineration escape hatch? Without DfE, the whole EPR exercise degenerates into a limited debate about who should pay for blue box recycling (as is happening in Ontario) rather than the more transformative exercise about creating a sustainable economy.
Anyway, here’s Matt Prindville’s article, and the link to the interest comments and queries:
What should we do with materials that have no value at end-of-life?
There has recently been some controversy concerning the implementation of Extended Producer Responsibility (EPR) regulations for packaging and printed paper (PPP) in British Columbia, and a separate proposal to build a new waste incinerator by Metro Vancouver. While the incinerator proposal began long before the EPR packaging program was developed, they are seen as linked by some recycling advocates. They are concerned that producers of PPP, who are now legally responsible for financing its recycling, will want to burn any excess materials they cannot easily sell.
The question centers around what to do with all the packaging and paper products that don’t currently have value in recycling markets. Because producers are responsible for meeting a 75% waste diversion target for PPP, they want to collect as many containers, newspapers, cans and other products as possible to meet their targets. However, not everything they collect is recyclable.- Many packaging materials – especially plastic packaging like plastic/foil laminates, polystyrene and films – are either unrecyclable or lack accessible markets.
Because recycling these problem products isn’t economically – or in some cases technically – feasible, the companies paying for PPP collection are happy to burn or bury these materials and relieve themselves of the management burden, while focusing on maximizing collection and sale of commodity materials that have value and markets – like cardboard, aluminum, steel, HDPE (#2) and PET (#1) plastic.
Burning unrecyclable packaging has been the predominant approach in European Union EPR programs for PPP where landfilling is severely restricted. Most EU programs: 1) make producers responsible for collection and waste diversion targets and 2) allow them to burn anything that they can’t sell. Many people working in waste management and recycling in the U.S. also advocate for this approach. The EPA and numerous state solid-waste hierarchies put incineration ahead of landfilling.
While there are many environmental and public health reasons to oppose new “waste-to-energy” proposals or prop up failing incinerators (visit the Global Alliance for Incinerator Alternatives website to learn more), there are two practical reasons from a waste prevention perspective why policy makers should keep incineration off the table for materials collected through EPR programs.
Incinerating low to no-value PPP materials prevents consideration of a critical waste reduction strategy: design change. The central reason why incineration is appealing to producers is because their designers created a packaging product that has no value after consumers are finished with it, and under EPR, they’re on the hook to do something with it. If producers focused on maximizing the value of their packaging – and minimizing life-cycle environmental impacts – through the end-of-life phase, they would make different design choices. This carries over to other issues as well. Let’s pretend that all businesses that use polystyrene-foam takeout containers and to-go cups were required to fund beach cleanups, stormwater drain servicing and other mitigation strategies to clean up these materials in the environment. You can bet that those companies would find a different biodegradable material to use instead – and they would do it overnight.
Incinerators make waste issues seem to “go away,” and decrease investment in design-for-the-environment, waste prevention, recycling and composting. Incinerators require large quantities of waste materials to be profitable and lock communities into feeding them for 20 years or more. Because of this, they compete with waste prevention, recycling and composting policies that prevent waste and steer materials away from landfills and incinerators and back into productive use – creating jobs and entrepreneurial opportunities along the way. In addition, because they are the most-expensive waste management technology, they also rob communities’ financial resources, which could instead be employed in the natural resource-preserving, job-creating businesses that arise from pursuing coordinated Zero Waste and EPR policies.
So what should producers do with materials that have no value at end-of-life? The answer is relatively simple: redesign them so that they do. We understand that there are significant political hurdles to achieving this vision, but it is the prudent, forward-thinking path. In order to get there, we need to employ the right mix of incentives and disincentives to drive design for the environment and steward the materials in products from one generation to the next.
We need polices that address our unsustainable production and consumption practices both upstream at the source, and downstream post-consumer, to create linked, cyclical and sustainable systems of delivering goods and services. Polices that:
1) Ensure that products and packaging are designed with safe, sustainable materials and designed to be reused, recycled or composted;
2) Reduce materials, toxics and energy use to the greatest extent possible, upstream of the consumer; and
3) Provide for effective reuse and recycling systems to turn today’s unwanted stuff into tomorrow’s goods.
Allowing PPP materials collected in EPR programs to be incinerated moves us in the wrong direction. If we are to reverse the catastrophic ecological impacts if our unsustainable, global production and consumption systems, then we must pursue bold actions and policies that build more sustainable, equitable and healthy economies. Getting rid of “built to burn” and “designed for the dump” is a good way to start.
[Visit the website link above to see the extensive comment thread.]