2013 Proposed Designated Materials Recycling Regulation...

2013

January 27, 2014

Proposed Designated Materials Recycling

Regulation Consultation Workbook

Feedback Summary Report

Proposed Designated Materials Recycling Regulation Consultation Workbook Feedback Summary Report

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Prepared for: Alberta Environment and Sustainable Resource Development Prepared by: The Praxis Group For copies of this report, contact: Information Centre Government of Alberta Phone toll free: 310-ESRD (3773) Email: [email protected] Website: www.environment.alberta.ca Pub. No.: I/I ISBN No.: 978-1-4601-1519-0 (on-line) Published: February 2014


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Table of Contents

LIST OF TABLES ......................................................................................................................7

LIST OF FIGURES ................................................................................................................... 10

ACRONYNMS ....................................................................................................................... 12

EXECUTIVE SUMMARY ......................................................................................................... 13

INTRODUCTION ................................................................................................................... 16

Background and Purpose......................................................................................................... 16

Approach ................................................................................................................................. 17

Quantitative Data .................................................................................................................... 18

Qualitative Data ....................................................................................................................... 18

Structure of the Summary Report ........................................................................................... 19

1 CONSOLIDATION OF EXISTING REGULATIONS ................................................................. 20

1.1 Background........................................................................................................................ 20

1.2 Proposed Change .............................................................................................................. 20

1.2.1 Consolidate Alberta’s existing recycling regulations (for beverage containers,

used oil materials, tires, electronics, and paint) under one regulation, the

Designated Materials Recycling Regulation, which will also be the governing

regulation for all future designated materials ........................................................ 20

1.2.2 Sector/Organization Findings .................................................................................. 21

1.3 Comments ......................................................................................................................... 21

1.3.1 Do you have any additional comments or suggestions regarding the

consolidation of Alberta’s eight recycling regulations under one regulation? ....... 21

2 ENVIRONMENTAL FEES .................................................................................................. 24

2.1 Background........................................................................................................................ 24

2.2 Proposed Change .............................................................................................................. 24

2.2.1 Remove environmental fees from regulation while still ensuring consumer

protection ................................................................................................................ 24


2.2.3 Supporting Changes ................................................................................................ 26

2.2.4 Require specific criteria to be followed when setting environmental fees and

provide evidence of doing so in stewardship plans ................................................ 26



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2.2.6 Require director approval of environmental fees as part of the overall

stewardship program plan, as well as any subsequent environmental fee

increases.................................................................................................................. 27


2.2.8 Require annual reports to include audited financial statements on program

revenues and expenditures ..................................................................................... 28


2.3 Comments ......................................................................................................................... 29

2.3.1 Do you have any additional comments or suggestions regarding the removal

of environmental fees from regulation in Alberta? ................................................ 29

2.3.2 Do you have any specific suggestions for additions or changes to criteria for

setting environmental fees? ................................................................................... 30

3 ELECTRONICS RECYCLING PROGRAM EXPANSION ........................................................... 32

3.1 Background........................................................................................................................ 32

3.2 Proposed Change .............................................................................................................. 32

3.2.1 Expansion of Alberta’s electronics recycling program to include: audiovisual

equipment; telecommunications equipment; small household appliances;

power tools ............................................................................................................. 32


3.3 Supporting Changes .......................................................................................................... 35

3.3.1 Proposed environmental fees on the expanded list of electronic products........... 36


3.3.3 Alberta Recycling to continue management of the expanded electronics

program ................................................................................................................... 37


3.4 Comments ......................................................................................................................... 38

3.4.1 Do you have any additional comments or suggestions regarding electronics

recycling in Alberta? ................................................................................................ 38

4 USED OIL MATERIALS RECYCLING PROGRAM: ENVIRONMENTAL FEE & EXPANSION ......... 42

4.1 Background........................................................................................................................ 42

4.2 Proposed Changes ............................................................................................................. 42

4.2.1 Increasing the environmental fee for used oil containers to 10 cents per litre

of container size ...................................................................................................... 42


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4.2.3 Adding automotive (antifreeze/coolant, windshield washer, diesel exhaust

fluid) containers to the program ............................................................................. 44


4.3 Supporting Change ............................................................................................................ 46

4.3.1 Proposed environmental fee of 10-cents per litre of container size on

expanded list of containers ..................................................................................... 46


4.4 Comments ......................................................................................................................... 48

4.4.1 Do you have any additional comments or suggestions regarding used oil

material recycling in Alberta? ................................................................................. 48

5 ENABLING OF EXTENDED PRODUCER RESPONSIBILITY ..................................................... 52

5.1 Background........................................................................................................................ 52

5.2 Proposed Change .............................................................................................................. 52

5.2.1 Enable extended producer responsibility ............................................................... 52



5.3.1 Allowing producers to meet their regulatory obligations individually or by

joining a collective ................................................................................................... 55

5.3.2 The regulatory requirements of stewardship program plans ................................. 55

5.3.3 Annual reporting requirements on program performance .................................... 55


5.4 Comments ......................................................................................................................... 57

5.4.1 Do you have any suggestions for changes or additions to the regulatory

requirements for stewardship programs? .............................................................. 57

5.4.2 Do you have any additional comments or suggestions on enabling extended

producer responsibility, including comments related to governance of

extended producer responsibility programs and government oversight? ............. 62

6 DESIGNATION OF PACKAGING AND PRINTED PAPER ....................................................... 68

6.1 Background........................................................................................................................ 68


6.2.1 Designation of packaging, service packaging and printed paper for a

provincial stewardship program. ............................................................................ 69


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6.2.3 Managing Packaging and Printed Paper under an Extended Producer

Responsibility Program ........................................................................................... 71


6.3.1 The proposed timeline of 12 months for submitting a stewardship program

plan for packaging and printed paper ..................................................................... 73


6.3.3 The proposed timeline of 18 months (from the time a program stewardship

plan is approved) for implementing a packaging and printed paper program. ...... 74


6.3.5 Excluding agricultural plastics as a designated material under a packaging

and printed paper program .................................................................................... 75


6.4 Comments ......................................................................................................................... 76

6.4.1 Comments regarding materials from the non-residential sector ........................... 76

6.4.2 What role do you see municipalities playing in packaging and printed paper

program? ................................................................................................................. 78

6.4.3 Do you have any additional comments or suggestions regarding packaging

and printed paper in Alberta? ................................................................................. 79

7 DESIGNATION OF HOUSEHOLD HAZARDOUS WASTE ....................................................... 81

7.1 Background........................................................................................................................ 81


7.2.1 Designate flammable liquids, pesticides, toxics, corrosives, physically

hazardous cylinders, compact fluorescent lights and fluorescent tubes................ 83


7.2.3 Manage household hazardous wastes under an extended producer

responsibility program. ........................................................................................... 86




plan for household hazardous waste ...................................................................... 87


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plan is approved) for implementing a household hazardous waste program ........ 87

7.3.3 Sector/Organization findings .................................................................................. 88

7.4 Comments ......................................................................................................................... 89

7.4.1 What role do you see municipalities playing in a household hazardous waste

program? ................................................................................................................. 89

7.4.2 Do you have any additional comments or suggestions on household

hazardous waste management in Alberta? ............................................................ 91

8 FINAL THOUGHTS ........................................................................................................... 93

8.1 Feedback on the Consultation Process ............................................................................. 93


8.2 Comments ......................................................................................................................... 94

8.2.1 Do you have any further input you would like to provide on the proposed

Designated Material Recycling Regulation? ............................................................ 95

8.2.2 Do you have any suggestions for improving the (consultation) process? .............. 96

9 APPENDIX 1 ................................................................................................................... 98

9.1 Invitation to Stakeholders ................................................................................................. 98

10 APPENDIX 2 ................................................................................................................... 99

10.1 Summary of Written Submissions ................................................................................... 99

10.1.1 Consolidation of Existing Regulation ..................................................................... 99

10.1.2 Electronics Recycling Program Expansion ........................................................... 100

10.1.3 Enabling of Extended Producer Responsibility .................................................... 100

10.1.4 Designation of Household Hazardous Waste ...................................................... 102

10.1.5 Environmental Fees ............................................................................................. 102

10.1.6 Used Oil Materials Recycling Program: Environmental Fees and Expansion ..... 103

10.1.7 Designation of Packaging and Printed Paper ....................................................... 104

11 APPENDIX 3 ................................................................................................................. 107

11.1 Sector/Organization Breakdown of Workbook Responses ........................................... 107


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LIST OF TABLES

TABLE 1 - STAKEHOLDER GROUPS .............................................................................................................. 17

TABLE 2 –CONSOLIDATING ALBERTA'S EIGHT RECYCLING REGULATIONS UNDER ONE REGULATION ...... 21

TABLE 3 - REMOVAL OF ENVIRONMENTAL FEES FROM REGULATION WHILE STILL ENSURING

CONSUMER PROTECTION ........................................................................................................... 25

TABLE 4 - SPECIFIC CRITERIA TO BE FOLLOWED WHEN SETTING ENVIRONMENTAL FEES AND

PROVIDE EVIDENCE OF DOING SO IN STEWARDSHIP PROGRAM PLANS ................................... 27

TABLE 5 - DIRECTOR APPROVAL OF ENVIRONMENTAL FEES AS PART OF THE OVERALL

STEWARDSHIP PROGRAM PLAN, AS WELL AS, ANY SUBSEQUENT ENVIRONMENTAL FEE

INCREASES .................................................................................................................................. 28

TABLE 6 - ANNUAL REPORTS TO INCLUDE AUDITED FINANCIAL STATEMENTS ON PROGRAM

REVENUES AND EXPENDITURE ................................................................................................... 29

TABLE 7 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE

AUDIOVISUAL EQUIPMENT......................................................................................................... 34

TABLE 8 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE

TELECOMMUNICATIONS EQUIPMENT ....................................................................................... 34

TABLE 9 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE SMALL

HOUSEHOLD APPLIANCES ........................................................................................................... 34

TABLE 10 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE POWER

TOOLS ........................................................................................................................................ 35

TABLE 11 - PROPOSED ENVIRONMENTAL FEES .......................................................................................... 37

TABLE 12 - CONTINUED MANAGEMENT OF THE EXPANDED ELECTRONICS PROGRAM BY ALBERTA

RECYCLING ................................................................................................................................ 38

TABLE 13 - INCREASING THE ENVIRONMENTAL FEE FOR USED OIL CONTAINERS TO 10 CENTS PER

LITRE OF CONTAINER SIZE ......................................................................................................... 44

TABLE 14 - ADDING AUTOMOTIVE ANTIFREEZE / COOLANT CONTAINERS TO THE PROGRAM ................. 45

TABLE 15 - ADDING WINDSHIELD WASHER CONTAINERS TO THE PROGRAM ........................................... 46

TABLE 16 - ADDING DIESEL EXHAUST FLUID CONTAINERS TO THE PROGRAM .......................................... 46


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TABLE 17 - PROPOSED ENVIRONMENTAL FEE OF 10 CENTS PER LITRE OF CONTAINER SIZE ON

EXPANDED LIST OF CONTAINERS .............................................................................................. 48

TABLE 18 – ENABLING PRODUCER RESPONSIBILITY IN REGULATION......................................................... 54

TABLE 19 - ALLOWING PRODUCERS TO MEET THEIR REGULATORY OBLIGATIONS INDIVIDUALLY OR

BY JOINING A COLLECTIVE ........................................................................................................ 56

TABLE 20 – REGULATORY REQUIREMENTS OF STEWARDSHIP PROGRAM PLANS ..................................... 56

TABLE 21 - ANNUAL REPORTING REQUIREMENTS ON PROGRAM PERFORMANCE ................................... 56

TABLE 22 - DESIGNATION OF PACKAGING AS DEFINED FOR A PROVINCIAL STEWARDSHIP

PROGRAM ................................................................................................................................. 70

TABLE 23 - DESIGNATION OF SERVICE PACKAGING AS DEFINED FOR A PROVINCIAL STEWARDSHIP

PROGRAM ................................................................................................................................. 70

TABLE 24 - DESIGNATION OF PRINTED PAPER AS DEFINED FOR A PROVINCIAL STEWARDSHIP

PROGRAM ................................................................................................................................. 71

TABLE 25 - MANAGING PACKAGING AND PRINTED PAPER UNDER AN EXTENDED PRODUCER

RESPONSIBILITY PROGRAM....................................................................................................... 72

TABLE 26 - THE PROPOSED TIMELINE OF 12 MONTHS FOR SUBMITTING A STEWARDSHIP

PROGRAM PLAN FOR PACKAGING AND PRINTED PAPER ......................................................... 74

TABLE 27 - THE PROPOSED TIMELINE OF 18 MONTHS (FROM THE TIME A PROGRAM

STEWARDSHIP PLAN IS APPROVED) FOR IMPLEMENTING A PACKAGING AND PRINTED

PAPER PROGRAM ...................................................................................................................... 75

TABLE 28 - EXCLUDING AGRICULTURAL PLASTICS AS A DESIGNATED MATERIAL UNDER A

PACKAGING AND PRINTED PAPER PROGRAM .......................................................................... 76

TABLE 29 - MATERIAL FROM THE NON-RESIDENTIAL SECTOR (INDUSTRIAL, COMMERCIAL,

INSTITUTIONAL) SHOULD/SHOULD NOT BE INCLUDED IN A PACKAGING AND PRINTED

PAPER PROGRAM BY SECTOR/BUSINESS .................................................................................. 77

TABLE 30 - DESIGNATING FLAMMABLE LIQUIDS FOR A PROVINCIAL STEWARDSHIP PROGRAM .............. 84

TABLE 31 - DESIGNATING PESTICIDES FOR A PROVINCIAL STEWARDSHIP PROGRAM ............................... 84

TABLE 32 - DESIGNATING TOXICS FOR A PROVINCIAL STEWARDSHIP PROGRAM ..................................... 84

TABLE 33 - DESIGNATING CORROSIVES FOR A PROVINCIAL STEWARDSHIP PROGRAM ............................ 85


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TABLE 34 - DESIGNATING PHYSICALLY HAZARDOUS PRODUCTS FOR A PROVINCIAL STEWARDSHIP

PROGRAM ................................................................................................................................. 85

TABLE 35 - DESIGNATING COMPACT FLUORESCENT LIGHTS AND FLUORESCENT TUBES FOR A

PROVINCIAL STEWARDSHIP PROGRAM .................................................................................... 85

TABLE 36 - MANAGING HOUSEHOLD HAZARDOUS WASTE THROUGH AN EXTENDED PRODUCER

RESPONSIBILITY PROGRAM....................................................................................................... 86

TABLE 37 - THE PROPOSED TIMELINE OF 12 MONTHS FOR SUBMITTING A STEWARDSHIP

PROGRAM PLAN FOR HOUSEHOLD HAZARDOUS WASTE ......................................................... 88

TABLE 38 - THE PROPOSED TIMELINE OF 12 MONTHS (FROM THE TIME A PROGRAM

STEWARDSHIP PLAN IS APPROVED) FOR IMPLEMENTING A HOUSEHOLD HAZARDOUS

WASTE PROGRAM ..................................................................................................................... 88

TABLE 39 - THIS DOCUMENT PROVIDED SUFFICIENT INFORMATION TO ALLOW YOU TO RESPOND

TO THE QUESTIONS ................................................................................................................... 94

TABLE 40 - YOU WERE COMFORTABLE WITH THE PROCESS FOR GATHERING YOUR INPUT ..................... 94


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LIST OF FIGURES

FIGURE 1 –CONSOLIDATING ALBERTA’S EIGHT RECYCLING REGULATIONS UNDER ONE

REGULATION, THE DESIGNATED MATERIALS RECYCLING REGULATION (N=191) .................... 20

FIGURE 2 - REMOVAL OF ENVIRONMENTAL FEES FROM REGULATION (N=194) ....................................... 25

FIGURE 3 – SUPPORTING CHANGES FOR REMOVING ENVIRONMENTAL FEES FROM REGULATION ......... 26

FIGURE 4 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE

AUDIOVISUAL EQUIPMENT, TELECOMMUNICATIONS EQUIPMENT, SMALL HOUSEHOLD

APPLIANCES, AND POWER TOOLS (N=182) ............................................................................... 33

FIGURE 5 - PROPOSED ENVIRONMENTAL FEES ON THE EXPANDED LIST OF ELECTRONIC PRODUCTS,

AND THAT ALBERTA RECYCLING CONTINUE MANAGEMENT OF THE EXPANDED

ELECTRONICS PROGRAM (N=172) ............................................................................................ 35

FIGURE 6 - INCREASING THE ENVIRONMENTAL FEE FOR USED OIL CONTAINERS TO 10 CENTS PER

LITRE OF CONTAINER SIZE (N=164) ........................................................................................... 43

FIGURE 7 - ADDING AUTOMOTIVE ANTIFREEZE, DIESEL EXHAUST FLUID, AND WINDSHIELD

WASHER FLUID CONTAINERS TO THE PROGRAM ..................................................................... 45

FIGURE 8 – PROPOSED ENVIRONMENTAL FEE OF 10-CENTS PER LITRE OF CONTAINER SIZE ON

EXPANDED LIST OF CONTAINERS .............................................................................................. 47

FIGURE 9 – ENABLING EXTENDED PRODUCER RESPONSIBILITY IN REGULATION (N=186) ........................ 53

FIGURE 10 - ALLOWING PRODUCERS TO MEET THEIR REGULATORY OBLIGATIONS INDIVIDUALLY

OR BY JOINING A COLLECTIVE; THE REGULATORY REQUIREMENTS OF STEWARDSHIP

PROGRAM PLANS; AND ANNUAL REPORTING REQUIREMENTS ON PROGRAM

PERFORMANCE ......................................................................................................................... 54

FIGURE 11 - DESIGNATION OF PACKAGING, SERVICE PACKAGING AND PRINTED PAPER MATERIALS ...... 69

FIGURE 12 - MANAGING PACKAGING AND PRINTED PAPER UNDER AN EXTENDED PRODUCER

RESPONSIBILITY PROGRAM (N=177) ......................................................................................... 71

FIGURE 13 - SUPPORTING CHANGES FOR DESIGNATING PPP TO BE MANAGED UNDER AN EPR

PROGRAM ................................................................................................................................. 73

FIGURE 14 - DO YOU THINK MATERIAL FROM THE NON-RESIDENTIAL SECTOR (INDUSTRIAL,

COMMERCIAL, INSTITUTIONAL) SHOULD BE INCLUDED IN A PACKAGING AND PRINTED

PAPER PROGRAM? .................................................................................................................... 77


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FIGURE 15 - INCLUSION OF SPECIFIC HAZARDOUS PRODUCTS IN A PROVINCIAL A STEWARDSHIP

PROGRAM ................................................................................................................................. 83

FIGURE 16 - MANAGING HOUSEHOLD HAZARDOUS WASTE THROUGH AN EXTENDED PRODUCER

RESPONSIBILITY PROGRAM (N=171) ......................................................................................... 86

FIGURE 17 - SUPPORTING CHANGES .......................................................................................................... 87

FIGURE 18 - ASSESSMENT OF WORKBOOK AND PROCESS ......................................................................... 93


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ACRONYNMS

AUOMA Alberta Used Oil Management Association

C&D Construction and demolition materials

CCME Canadian Council of Ministers of the Environment

CFLs Compact fluorescent lights

DAO Delegated Administrative Organizations

ELV End-of-life vehicle

EMS Environmental Management Standard

EOL End-of-life

EPR Extended Producer Responsibility

EPRA Electronics Products Recycling Association

ESRD Environment and Sustainable Resource Development

GoA Government of Alberta

HDPE High-density polyethylene

HHW Household hazardous waste

IC&I Industrial, Commercial and Institutional Sector

MRF Materials Recovery Facility

PPP Packaging and printed paper


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EXECUTIVE SUMMARY

The Proposed Designated Materials Recycling Regulation Consultation Workbook was designed to

gather stakeholder input on several proposed changes to Alberta’s existing regulatory framework for

recycling designated materials. The purpose of the workbook was to provide all stakeholders with the

opportunity to provide their input on the proposed changes. Stakeholder input will help ensure

Alberta’s current and future recycling programs meet stakeholder needs, keep pace in changing times,

and lead to positive environmental, social, and economic outcomes.

The workbook survey was available on-line from October 16th to December 13th, 2013 to gather

stakeholder comments and views on the proposed Designated Material Recycling Regulation (DMRR).

The vast majority of participants used the on-line workbook. Nine participants provided letters

(submissions) outside of the workbook. Letters submitted outside of the workbook framework have

been theme analyzed and the analysis is provided in Appendix 1. The workbook included background

information and an overview of proposed regulatory changes, followed by a more detailed discussion

of each proposed change and questions requesting stakeholder feedback on key areas. In addition,

opportunities were provided throughout the workbook for respondents to provide additional input or

comments important to Alberta’s regulatory framework for recycling designated materials.

Participation in the workbook survey was voluntary. As participants were not selected through a

random process, the ‘self-selected’ respondent population can be considered representative of

‘interested stakeholders’; however, it may not be representative of the entire stakeholder population.

As participants were anonymous, information about respondents cannot be verified. Data has not

been weighted in the quantitative summary since the relationship of the sample to the population is

unknown. The summary of data provided reflects the aggregate response of those who participated.

Further, while all opinions and perceptions are valid, it should be understood that respondents have

varying degrees of knowledge on the topics presented. It is also important to note that comment

themes are reported based on what has been articulated in the workbook without judgment as to the

correctness or validity of the comment. The views and opinions expressed herein are those of

participants and not necessarily those of Alberta Environment and Sustainable Resource Development

(ESRD).

The purpose of this summary report is not to generate recommendations regarding regulations for the

Government of Alberta (GoA), rather to present the views of stakeholders as expressed through the

workbook instrument.

Overall, stakeholders generally support the proposed changes outlined for the designated materials

recycling regulation. Stakeholder opposition to the proposed regulatory changes was minimal. While

some differences of opinion were evident across the sectors or organization represented in the

consultation, overall stakeholders understand the need for the proposed regulatory changes, but want


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to ensure that they are developed and implemented in a manner that considers and builds upon

existing strengths, best practices and multi-stakeholder input.

A number of recurring themes emerged throughout the workbook. Repeatedly, participants called for

further face-to face consultation to develop a comprehensive and meaningful program that addresses

a number of concerns:

� many respondents want to see draft regulations and more details of how programs will work

together, with some offering their specific expertise to consult further with the GoA;

� program harmonization needed between programs as well as across jurisdictions;

� philosophical differences between sectors and industry types about whether to move forward

with a full Extended Producer Responsibility (EPR) model vs. retaining some or all of the

existing governance elements;

� clarification of terminology needed; input to come from those who are most experienced in

dealing with the specific product;

� need for multi-stakeholder involvement.

Many respondents indicated the importance of cost recovery throughout the workbook, specifically

that cost recovery be directed to those who manage, facilitate and operate programs. They felt that

cost recovery should also protect and/or promote the local market place and local jobs. Many

respondents also felt that if fees are assigned to a product in the supply chain, appropriate reduction

in municipal taxes must occur to ensure consumers aren’t paying twice.

Continuity and protection of existing strengths, expertise and programs was felt to be necessary,

whether at the community level or the municipal level. Municipalities were recognized as strong

participants with an important role to play by some respondents, while others indicated a desire for

no government role at all. Many industry associations and business share the view that municipalities

will simply be another supplier in a competitive arena, feeling they should get first right of refusal, but

not a guarantee.

Many respondents identified a need for clarification of items to be included or excluded from

programs. They expressed concerns regarding potential charging of double fees (e.g., recyclable

products that are potentially managed under more than one program, such as containers under both

packaging and printed paper (PPP) and household hazardous waste (HHW) programs) and a need for

cross-over programs to address and minimize public confusion related to recycling these products.

Some respondents question whether the principle in play is still "recycle only that which should not go

to landfill" and what is being done to address products such as polystyrene (e.g., StyrofoamTM) and

agricultural plastics. Respondents held conflicting views regarding the inclusion or exclusion of

industry, commercial and institutional (IC&I) materials. Strong views were expressed on both sides.

Some question whether there is capacity available to handle additional designated materials. Many

call for further consultation, best-practices review and research in program development and


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regulatory designations; desire for more detailed analysis and evidence from other jurisdictions on

program performance and success.

Requirements for monitoring and evaluation was recognized by respondents throughout the

workbook. There was a general recognition of the necessity of monitoring and reporting to prove

program success, however conflicting views were expressed regarding the extensiveness of reporting.

A desire for transparency, simplicity and fairness in reporting was expressed by many respondents.

While many felt that reporting is appropriate, it should be simple to minimize administrative burden.

Some felt that only return rates should be required to be reported to government.

Harmonization between provinces and/or programs was also a consistent theme mentioned

throughout the workbook. There was considerable concern raised regarding inconsistencies between

jurisdictions.


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INTRODUCTION

Background and Purpose

In the fall of 2013, the Government of Alberta (GoA) initiated consultation on the proposed

Designated Materials Recycling Regulation (DMRR). The proposed changes to the existing regulatory

framework are intended to reduce waste in Alberta, streamline Alberta’s regulatory framework, and

shift costs from taxpayers to those who produce and use products. The proposed new regulation

would advance initiatives outlined in Alberta’s Too Good Too Waste Strategy, better align Alberta’s

approach with neighbouring provinces, and support developing extended producer responsibility

(EPR) programs as outlined by the Canadian Council of Ministers of the Environment (CCME).

Specific objectives include:

� To identify and quantify specific areas of support for the proposed regulation;

� To identify and quantify specific areas where there is less support for the proposed regulation;

� To identify stakeholder concerns regarding the proposed regulation and explore potential

solutions or opportunities for addressing the concerns.

The Proposed Designated Materials Recycling Regulation Consultation Workbook was designed to

gather stakeholder input on the following seven proposed changes to Alberta’s regulatory framework

for recycling designated materials, including:

1) Consolidation of Existing Regulations;

2) Environmental Fees;

3) Electronic Recycling Program Expansion;

4) Used Oil Materials Recycling Program-Environmental Fee and Expansion;

5) Enabling of EPR;

6) Designation of Packaging and Printed Paper (PPP); and,

7) Designation of Household Hazardous Waste (HHW).

The purpose of the workbook was to provide all stakeholders with the opportunity to provide their

input on the proposed changes. Consultation feedback will help inform next steps.

The workbook survey was available on-line from October 16th to December 13th, 2013 to gather

stakeholder comments and views on the proposed Designated Material Recycling Regulation. The

workbook included background information and an overview of the proposed regulatory changes,

followed by a more detailed description of each proposed change and questions requesting

stakeholder feedback on key areas. In addition, opportunities were provided throughout the

workbook for respondents to provide any other input or comments important to Alberta’s regulatory

framework for recycling designated materials.


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This report is one of two reports arising out of the consultation process. The Designated Materials

Recycling Regulation Public Opinion Poll summarizes public feedback gathered through a random

telephone survey of Albertans 18 years of age or older and is available ESRD’s website:

http://esrd.alberta.ca/waste/default.aspx

Approach

The general purpose of the stakeholder consultation process was to obtain input from stakeholders

(see Table 1) known to have an interest or involvement with waste and recycling.

TABLE 1 - STAKEHOLDER GROUPS

Sector/Organization

Municipal Government

Federal or Provincial Government

Business/ Industry

Industry Associations

Delegated Administrative Organizations

Government Agency/ Board/ Commission

Non-Government/ Non-Profit Organizations

General public

Other (e.g., Education, Consultant)

An initial invitation (see Appendix 1) was sent by email from ESRD to approximately 300 stakeholder

groups and individuals who had requested to be kept apprised of the consultation or were identified

through staff networks (e.g., municipalities, waste commissions, industry associations). Within the

invitation, the stakeholder was provided an online link to register for the on-line workbook. Upon

registering, an automatic password was generated and sent to the registrant with a link for the

webpage to the consultation workbook. Stakeholders were able to pass on the information for the

review to any other organizations or individuals they felt would have an interest in the proposed

regulatory changes. Stakeholders were able to access the workbook survey online through the ESRD’s

website. A hardcopy workbook was also made available for participants preferring to complete the

workbook off-line. Stakeholders were allowed approximately eight weeks to complete the

consultation workbook (October 16th to December 13th).


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Quantitative Data

A total of 202 workbook surveys were completed by interested stakeholders (see Appendix 2 for

Sector breakdown). Respondents could choose to fill in all the sections or only those of interest to

them. Data gathered for the questions asking respondents to rate a series of statements or choose

from a set of response options are presented as ‘frequencies of response’, where frequency refers to

the number of times a particular response occurred. This is presented in either table or figure format.

For each question, the ‘n’ value (number of responses) is included in the table or figure.

Participation in the workbook survey was voluntary. As participants were not selected through a

random process, the resultant ‘self-selected’ respondent population can be considered representative

of ‘interested stakeholders’; however, it may not be representative of the entire stakeholder

population. As participation was anonymous, information about respondents cannot be verified unless

they specifically identified their feedback be shared with ESRD. Data have not been weighted in the

quantitative summary since the relationship of the sample to the population is unknown. The

summary of data provided reflects the aggregate response of those who participated.

Further, while all opinions and perceptions are valid, it should be understood that respondents have

varying degrees of knowledge on the topics presented. It is also important to note that comment



participants and not necessarily those of ESRD.

Qualitative Data

The open-ended comment questions generated a large volume of qualitative data. Comment themes

have been identified throughout the report. There has been no attempt to weight the comments (i.e.,

this person’s comment is more important than others). There has also been no attempt to quantify

the themes, although general terms have been used to illustrate an order of magnitude when a

particular theme prevails. For example the use of qualitative language has been used– few, some,

many, most, and all – as these data cannot effectively be represented numerically. These categories

express the level of responses in relative terms given quantification of the data is limited beyond

providing the key themes in order of frequency of mention.

It is important to note that while many participants directly addressed the specific questions asked

within the workbook sections, others opted to express their general views or concerns specific to the

industry or sector they represent or operate within.

It is also important to note that comment themes are reported based on what has been articulated

in the workbook without judgment as to the correctness or validity of the comment. The views and

opinions expressed herein are those of participants and not necessarily those of ESRD.


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Although 202 respondents participated in the workbook survey, the number of individuals providing

comments varied for each question.

Structure of the Summary Report

The workbook results are presented by section reflecting the structure of the workbook. The

workbook consists of eight parts including: seven sections specific to proposed regulatory changes and

a final section for any additional thoughts or comments.

The purpose of this report is to provide an overview of the key themes and priorities identified

through the workbook consultation. A number of participants have provided extensive commentary. It

is the purpose of this report to capture the recurring themes and identify where there is cohesion or

disparity around certain issues. The verbatim comments from those participants who indicated they

would like their feedback to be shared with ESRD were provided to the department in a separate

report broken down by sector and organization. We recommend ESRD review the submissions and

responses individually to gain a more in-depth understanding of the issues.

The vast majority of participants used the on-line workbook. Nine participants provided letters

(submissions) outside of the workbook. A few provided both letters and workbook submissions.

Letters submitted outside of the workbook framework have been theme analyzed and the analysis is

provided in Appendix 2. These letters have also been provided to ESRD for consideration. Well over

300 pages of comments (from the on-line workbook and individual submissions) were provided as part

of the consultation.


Page 20

1 CONSOLIDATION OF EXISTING REGULATIONS

1.1 Background

Alberta currently has eight separate regulations for the five provincial recycling programs. Each

program is operated by a delegated administrative organization (DAO) and applicable regulations.

Consolidating the separate regulations into one will streamline the GoA’s regulatory approach and

make it easier for people to find relevant regulatory requirements for all of Alberta’s regulated

recycling programs.

1.2 Proposed Change

1.2.1 Consolidate Alberta’s existing recycling regulations (for beverage containers,

used oil materials, tires, electronics, and paint) under one regulation, the

Designated Materials Recycling Regulation, which will also be the governing

regulation for all future designated materials

As illustrated in Figure 1, most respondents indicated being in support of consolidating Alberta’s

existing recycling regulations (for beverage containers, used oil materials, tires, electronics, and paint)

under one regulation, the Designated Materials Recycling Regulation (62 per cent strongly support, 27

per cent somewhat support). Several respondents indicated being impartial (seven per cent neutral),

while few respondents opposed the change (two per cent strongly oppose, three per cent somewhat

oppose).

FIGURE 1 –CONSOLIDATING ALBERTA’S EIGHT RECYCLING REGULATIONS UNDER ONE REGULATION, THE DESIGNATED MATERIALS

RECYCLING REGULATION (N=191)

2 37

27

62

0

10

20

30

40

50

60

70

Strongly oppose Somewhat oppose Neutral Somewhat support Strongly support

Pe

r ce

nt


Page 21

1.2.2 Sector/Organization Findings

Table 2 provides detailed results of the degree of opposition or support for consolidating Alberta’s

recycling regulations under one regulation by respondent sector or organization breakdown. Support

was strong across all sectors or organizations represented by respondents; with 77 per cent to 100 per

cent of respondents having indicated that they somewhat or strongly support the proposed change.

TABLE 2 –CONSOLIDATING ALBERTA'S EIGHT RECYCLING REGULATIONS UNDER ONE REGULATION

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support

Municipal government 30 3% 10% 87%

Business/industry 72 1% 4% 11% 32% 51%

Industry association 27 4% 19% 33% 44%

Delegated administrative organization 2 100%

Government agency/board/commission 9 33% 67%

Non-government/non-profit organization 12 8% 25% 67%

General public 20 5% 20% 75%

Other 5 60% 40%

1.3 Comments

The following section provides a summary of the key themes that emerged and is presented in

descending order of frequency of mention; in this case, frequency refers to the number of times

respondents identified a particular idea or theme without consideration of which sector or

organization respondents represent. The key themes are presented in bullet form, for ease of reading.

The summary represents the general indication of the opinions and views of those

sectors/organizations who responded to the question. It is also important to note that comment




1.3.1 Do you have any additional comments or suggestions regarding the

consolidation of Alberta’s eight recycling regulations under one regulation?

Of the 191 participants who responded to the question, 99 provided comments. Of the participants

who responded, a large majority communicated support of the proposed regulatory change and

shared the belief that having one regulation encompassing all of Alberta’s recycling regulations will

simplify the process of recycling. Many perceived that the implementation of this new regulation

offers the opportunity to create harmonization between programs across jurisdictions. Respondents


Page 22

mainly agreed that consolidation of regulations would make information more accessible, less

confusing, and easier to manage.

Many respondents expressed the need for the government to ensure a seamless transition for the

existing programs and DAOs. Conversely, some feel that program administration should operate

individually and remain at arm’s length from the government. Other concerns identified by some

respondents included: the overhead cost to implement; monitoring of accountability and

enforcement.

Benefits include simplification and harmonization

� One comprehensive regulation will result in simplification of the recycling process.

� Consolidation offers the opportunity to create harmonization between programs.

� Consolidation makes information more accessible, less confusing, and easier to manage.

� Simplification will ultimately be less expensive, and will conserve time and effort when

compared to the current method.

Governance required for program transitions

� Government needs to provide a seamless transition for the existing programs and delegated

administrative organizations.

Autonomy for program administration

� Program administration should operate individually and remain at arm’s length from the

government.

Cost implication concerns

� Concerns of increased administration and bureaucracy involvement, and the monitoring of

accountability and enforcement.

� Concerns that additional administration would be necessary and that increased costs would

follow.

Need for consultation and education

� Need for public education regarding the proposed regulation changes to ensure awareness.

� Need for consultation with stakeholders, producers and the general public during the

consolidation process and in decision-making regarding a governing structure for the system.

Concerns about transparency and fairness

� Concerns that consolidation may result in items being hidden within legislation.


Page 23

� Concerns that consolidation could cause difficulty for companies to recognize their

responsibilities.

� Concerns that consolidation could potentially inhibit companies who operate within one

specific regulation.

Concerns regarding centralization

� Household hazardous waste should not be combined with other regulations, but should remain

specialized and separate.

� Regulations should remain separate as different sectors will not adequately serve all materials

once combined together.

� Centralization only benefits the government and will not have an impact on recycling or waste

management systems.


Page 24

2 ENVIRONMENTAL FEES

2.1 Background

Currently, funding for most provincially regulated recycling programs comes from environmental fees

levied on the sale of designated products sold in Alberta. The fees are typically added on to the price

of the product when it is purchased at the till. The environmental fees are placed into dedicated

accounts that can only be used to fund the recycling program associated with those products.

Government neither funds nor receives money from the recycling programs. The programs are

required to submit annual reports to government, including audited financial statements showing how

much money was collected and spent. The annual reports are posted online and are available to the

public.

Maximum environmental fees are listed in the regulations for tires, paint, used oil materials and

electronics. To increase a fee beyond the amount specified in regulation, a regulatory amendment is

required.

Alberta also has some voluntary industry-run stewardship programs (for example, cell phone recycling

and pesticide container recycling) that internalize recycling costs into the price of the product. For

these programs, financial information is not shared with government or the public on program

revenues and expenditures.

Other Canadian provinces with regulated EPR programs do not list environmental fees in their

regulations; there, the producers are responsible for managing the end-of-life (EOL) programs for

designated materials, including determining how to fund the programs. Some provinces require that

the Minister or Minister’s designate approve any proposed environmental fees or fee changes. Others

do not require government approval of environmental fees, but do require producers to provide

annual audited financial statements outlining how much money was collected and how it was spent.

Still others require environmental fees to be incorporated into the price of the product rather than

added on at the till, although stores can still inform their customers that a fee is being charged.

2.2 Proposed Change

2.2.1 Remove environmental fees from regulation while still ensuring consumer

protection

As illustrated in Figure 2, a large majority of respondents indicated being in support of removal of

environmental fees from regulation (44 per cent strongly support, 21 per cent somewhat support),

several respondents indicated being impartial (10 per cent neutral), while some respondents opposed

the change (13 per cent strongly oppose, 13 per cent somewhat oppose).


Page 25

FIGURE 2 - REMOVAL OF ENVIRONMENTAL FEES FROM REGULATION (N=194)


Levels of support varied by sector (see Table 3) whereby the strongest support originated from the

DAO sector (100 per cent strongly support), followed by the industry association sector (69 per cent

strongly support). While most respondents across all sectors indicated support for the proposed

change, around one-third of respondents from the municipal government, business/industry,

government agency/board/commission, non-government/non-profit organization and general public

sectors reported opposition (strongly or somewhat opposed).

TABLE 3 - REMOVAL OF ENVIRONMENTAL FEES FROM REGULATION WHILE STILL ENSURING CONSUMER PROTECTION

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support

Municipal government 31 19% 19% 7% 16% 39%

Business/ industry 73 14% 18% 11% 12% 45%



Government agency/ board/ commission 9 33% 44% 22%

Non-government/ non-profit organization 12 8% 25% 17% 33% 17%

General public 18 17% 17% 6% 33% 28%

Other 5 20% 40% 40%

13 1310

21

44

0

10

20

30

40

50


Pe

r ce

nt


Page 26

2.2.3 Supporting Changes

Respondents were asked to indicate the degree to which they oppose or support the following

requirements if environmental fees are removed from regulation but charged to consumers:

1. Require specific criteria to be followed when setting environmental fees and provide

evidence of doing so in stewardship plans;

2. Require director approval of environmental fees as part of the overall stewardship program

plan, as well as any subsequent environmental fee increases;

3. Require annual reports to include audited financial statements on program revenues and

expenditures.

Most participants support all three requirements, with between 69 per cent and 89 per cent of

respondents supporting the indicated changes (see Figure 3).

FIGURE 3 – SUPPORTING CHANGES FOR REMOVING ENVIRONMENTAL FEES FROM REGULATION

2.2.4 Require specific criteria to be followed when setting environmental fees and

provide evidence of doing so in stewardship plans

As illustrated in Figure 3, a large majority of respondents indicated support for this change (64 per

cent strongly support, 21 per cent somewhat support) and viewed it as being necessary to ensure

6 3 6

21

64

139 10

27

42

3 3 5

14

75

0

10

20

30

40

50

60

70

80

Strongly oppose Somewhatoppose

Neutral Somewhatsupport

Strongly support

Per c

en

t

Require specific criteria to be followed when setting environmental fees and provide evidence of doing soin stewardship program plans (n=186)

Require director approval of environmental fees as part of the overall stewardship program plan, as wellas, any subsequent environmental fee increases (n=187)

Require annual reports to include audited financial statements on program revenues and expenditures(n=187)


Page 27

comprehensive criteria for fairness, transparency, accountability and program success. A few

respondents were neutral to the change (six per cent), while a few indicated being opposed (six per

cent strongly oppose, three per cent somewhat oppose) to the change.


While the level of support for requiring criteria to be followed when setting environmental fees varied

by sector (see Table 4), overall support was strong across all sectors, with a minimum of 74 per cent of

respondents in any one sector indicating they strongly or somewhat support the removal of

environmental fees from regulation. The strongest opposition was reported from the industry

association (15 per cent strongly oppose) and the business/industry sector (seven per cent strongly

oppose).

TABLE 4 - SPECIFIC CRITERIA TO BE FOLLOWED WHEN SETTING ENVIRONMENTAL FEES AND PROVIDE EVIDENCE OF DOING SO IN

STEWARDSHIP PROGRAM PLANS

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support

Municipal government 30 3% 3% 17% 77%


Industry association 27 15% 4% 7% 30% 44%


Government agency/ board/ commission 9 11% 89%

Non-government/ non-profit organization 12 25% 75%

General public 18 22% 78%

Other 4 25% 75%

2.2.6 Require director approval of environmental fees as part of the overall

stewardship program plan, as well as any subsequent environmental fee

increases

As illustrated in Figure 3, the majority of respondents indicated support for this change (42 per cent

strongly support, 27 per cent somewhat support), some were neutral (10 per cent neutral), and some

expressed opposition (strongly oppose 13 per cent, nine per cent somewhat oppose). Although

respondents mainly supported this change, concern was raised that requiring a director could lead to

delays in fee adjustments due to lengthy review processes. Some disagreed that a director would be

required as the view is that individual or collective programs should have the authority to make

change.


Page 28


The level of support for requiring director approval of environmental fees varied considerably across

sector (see Table 5), with strongest overall support originating from the DAO (100 per cent strongly

support), government agency/board/commission (100 per cent strongly or somewhat support) and

municipal government (90 per cent strongly or somewhat support) sectors. Conversely, strongest

opposition was reported from the business/industry (35 per cent strongly or somewhat oppose),

industry association (36 strongly or somewhat oppose) and other (40 per cent strongly or somewhat

oppose) sectors.

TABLE 5 - DIRECTOR APPROVAL OF ENVIRONMENTAL FEES AS PART OF THE OVERALL STEWARDSHIP PROGRAM PLAN, AS WELL AS, ANY

SUBSEQUENT ENVIRONMENTAL FEE INCREASES

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support






Non-government/ non-profit organization 11 27% 27% 46%


Other 5 20% 20% 40% 20%

2.2.8 Require annual reports to include audited financial statements on program

revenues and expenditures

As illustrated in Figure 3, the vast majority of respondents supported the change (75 per cent strongly

support, 14 per cent somewhat support) and stated that including audited financial statements on

program revenues and expenditures would ensure fees are being spent appropriately and fairly, as

well as ensuring that a profit is not being made at the expense of the consumer. A few respondents

were neutral to the change (five per cent), while a few indicated being opposed (three per cent

strongly oppose, three per cent somewhat oppose) to the change.


Support was strong for requiring annual reports to include audited financial statements across all

sectors (see Table 6), with a minimum of three quarters of respondents in any one sector indicating

they strongly support the proposed regulatory change.


Page 29

TABLE 6 - ANNUAL REPORTS TO INCLUDE AUDITED FINANCIAL STATEMENTS ON PROGRAM REVENUES AND EXPENDITURE

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 25% 75%

2.3 Comments










There were two open-ended questions related to environmental fees in the workbook.

� Do you have any additional comments or suggestions regarding the removal of environmental

fees from regulation in Alberta?

� Do you have any specific suggestions for additions or changes to criteria for setting

environmental fees?

2.3.1 Do you have any additional comments or suggestions regarding the removal

of environmental fees from regulation in Alberta?

In total, 73 respondents provided comments to this question. A large majority of the participants who

responded supported the removal of environmental fees from regulation. Many viewed the removal

as being beneficial, as it would allow stewardship programs to alter environmental fees due to

fluctuating costs and changing market conditions, without unnecessary delays. The importance of

having ‘fee visibility’ was conveyed by respondents for both establishing consumer awareness and

avoiding the creation of a cost disadvantage of Alberta retailers/businesses. Some respondents


Page 30

expressed concern regarding the lack of government accountability that could occur, the potential

increase in cost to the consumer, and price disparity concerns when comparing similar products

outside Alberta’s borders.

Benefits associated with removing environmental fees from regulation

� Improved consumer education and awareness of programs resulting from fee visibility will lead

to more successful programs overall.

� Avoids the creation of any cost disadvantage for Alberta retailers/businesses for designated

products when compared to similar products beyond Alberta’s borders.

� Allow stewardship programs to respond to fluctuating costs and changing market conditions.

� Avoids unnecessary delays for adjusting fees.

Concerns regarding removing environmental fees from regulation

� Removal of environmental fees from regulation could have negative consequences for small

businesses.

� Government accountability is lost whereby environmental fees could increase at a rate that is

not in line with inflation, increasing cost of living and doing business in Alberta.

� Questions regarding how an industry program will support itself; who will control and ensure

rates are adjusted fairly; how will fees be dispersed; who will pay if there is a deficit?

Suggestions regarding the removal environmental fees from regulation

� Industry-run stewardship organizations should be accountable for the transparency of costs

associated with managing the diversion programs.

� An independent third party should act as a watchdog and report annually on performance, and

validate annual reports.

� Producers should be responsible for determining fees.

� GoA needs to remain involved.

� Clear criteria required for fee setting.

2.3.2 Do you have any specific suggestions for additions or changes to criteria for

setting environmental fees?

In total, 82 respondents provided comments to this question. Respondents’ comments focused on the

importance of comprehensive fee criteria for program success. Program autonomy was also deemed

important for setting fees appropriately and timely, allowing for adjustments in line with market costs.

The need for further stakeholder engagement, consumer education and transparency regarding fees

were also discussed. In the following section, respondents’ comments are summarized by key themes

and presented in order of frequency of mention.


Page 31

Comprehensive fee criteria required

� Need for criteria to be comprehensive to ensure fairness, transparency, accountability and

program success; fees should cover only a reasonable cost of running the stewardship

program.

� Need for criteria to determine how to deal with surpluses if they occur while also prohibiting a

surplus from occurring.

Importance of program autonomy and flexibility

� Stewards or representative organizations should have the responsibly and autonomy to design

the collection system and set fees without government interference; autonomy needed to set

fees appropriately and in response to fluctuating market costs.

� Concern that removal of regulatory requirements could lead to systemic abuse of the program;

programs should be financially self-sustaining.

� Standards should be set and enforced by government.

� Producers should be responsible for ensuring their products are recyclable and use less

packaging.

� Adding a level of Director Approval is unnecessary as it is too much power for one individual

and could also lead to delays in fee adjustments due to lengthy review processes.

Importance of stakeholder engagement and consultation

� Require stakeholder engagement that takes into account multiple interests

� Information should be transparent, clear, and communicated to Albertans.

� Producer/manufacturer should determine how to best manage the cost for end of life

management on their products.

Importance of transparency

� Important for fees to be visible on sales receipts – no hidden fees.

� Importance of audited financial statements and annual reviews.


Page 32

3 ELECTRONICS RECYCLING PROGRAM EXPANSION

3.1 Background

Alberta’s electronics recycling program began in 2004 and was developed to ensure old or unwanted

electronic products are managed in an environmentally appropriate manner. The Alberta Recycling

Management Authority (Alberta Recycling) is the DAO designated to manage the program. To date,

more than 5.5 million units -- or about 100,000 tonnes of electronic material has been recycled. There

are approximately 330 electronics collection sites across the province; most are managed by

municipalities. The program presently only includes computer equipment and televisions.

Electronic waste or e-waste is one of the fastest growing waste streams in the country. There has been

ongoing demand from municipalities and the public to include more products in Alberta’s program.

Several other provinces have already expanded their electronics recycling programs. Expanding the

program will increase Alberta’s recycling rate, reduce municipal costs, lead to greater harmonization

with other provinces, and provide a level of service the public expects.

3.2 Proposed Change

3.2.1 Expansion of Alberta’s electronics recycling program to include: audiovisual

equipment; telecommunications equipment; small household appliances;

power tools

A large majority of respondents indicated they support expansion of Alberta’s electronics recycling

program to include the proposed types of electronics, with 82 per cent or more strongly or somewhat

supporting the inclusion of all four proposed categories of electronics.

As illustrated in Figure 4, overall respondent support was strongest (90 per cent) for expanding the

recycling program to include telecommunications equipment (78 per cent strongly support, 12 per

cent somewhat support), followed by audiovisual equipment at 89 per cent (78 per cent strongly

support, 11 per cent somewhat support). Expanding to include small household appliances was

supported by 85 per cent of respondents (73 per cent strongly support, 12 per cent somewhat

support), followed by power tools at 82 per cent (70 per cent strongly support, 12 per cent somewhat

support). A few respondents (between one per cent and five per cent across all four categories) were

opposed to the proposed expansion. Between seven per cent and 11 per cent of respondents

indicated they were neutral on whether to expand the recycling program to include the four

categories of electronics.


Page 33

FIGURE 4 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE AUDIOVISUAL EQUIPMENT,

TELECOMMUNICATIONS EQUIPMENT, SMALL HOUSEHOLD APPLIANCES, AND POWER TOOLS (N=182)


Tables 7, 8, 9 and 10 provide detailed results of degree of opposition or support for the four

categories of electronics, and are summarized below by sector.

Support was strong overall in almost all sectors for adding all four types of electronics to an expanded

recycling program, with more than 75 per cent to 100 per cent of all respondents supporting the

proposed additions. Further, a consistent pattern of support was observed across all sectors, with

each sector reporting similar degrees of support or opposition across categories of electronics.

One moderate exception to the generally strong support was observed. Support by the industry

association sector fell below two-thirds of respondents for small household appliances and power

tools, with a few (ranging between nine per cent and 13 per cent) reporting they were opposed and

between 19 per cent and 30 per cent reporting they were neutral on the addition of these two

categories (see Tables 9 and 10).

1 38

11

78

1 37

12

78

3 2

10 12

73

2 511 12

70

0

10

20

30

40

50

60

70

80

90


Per c

en

t

Audiovisual equipment Telecommunications equipment Small household appliances Power tools


Page 34

TABLE 7 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE AUDIOVISUAL EQUIPMENT

Sector/ Organization

Base

size

(n=)

Strongl

y

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support

Municipal government 31 7% 94%

Business/industry 69 6% 12% 16% 66%



Government agency/board/commission 9 100%

Non-government/non-profit organization 12 8% 92%


Other 4 100%

TABLE 8 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE TELECOMMUNICATIONS EQUIPMENT


Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support


Business/industry 69 4% 13% 15% 68%






Other 4 100%

TABLE 9 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE SMALL HOUSEHOLD APPLIANCES


Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support






Non-government/non-profit

organization 12 17% 8% 75%


Other 4 25% 75%


Page 35

TABLE 10 - EXPANSION OF ALBERTA’S ELECTRONICS RECYCLING PROGRAM TO INCLUDE POWER TOOLS


Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support







General public 21 5% 5% 5% 85%

Other 4 50% 25% 25%

3.3 Supporting Changes


regulation changes that would support an expanded electronics program:

1. Proposed environmental fees on the expanded list of electronic products;

2. Alberta Recycling to continue management of the expanded electronics program.

As illustrated in Figure 5, respondents overall indicated strong support (76 per cent strongly or

somewhat support) for both the proposed environmental fees on the expanded list of electronic

products, as well as for Alberta Recycling to continue management of the expanded electronics

program.

FIGURE 5 - PROPOSED ENVIRONMENTAL FEES ON THE EXPANDED LIST OF ELECTRONIC PRODUCTS, AND THAT ALBERTA RECYCLING

CONTINUE MANAGEMENT OF THE EXPANDED ELECTRONICS PROGRAM (N=172)

4 4

1622

54

4 713

17

59

0

10

20

30

40

50

60

70


Per c

en

t

Proposed environmental fees (under $5 per unit, with many fees $1 or less per unit) on the expanded list ofelectronic products.Alberta Recycling to continue management of the expanded electronics program.


Page 36

3.3.1 Proposed environmental fees on the expanded list of electronic products

As illustrated in Figure 5, 76 per cent of respondents indicated support for the proposed

environmental fees (54 per cent strongly support, 22 per cent somewhat support), 16 per cent were

neutral and a few expressed opposition (four per cent strongly oppose, four per cent somewhat

oppose).


With regard to the proposed environmental fees on the expanded list of electronic products (see

Table 11), the majority of respondents supported the proposed regulation, with 71 per cent or more

respondents in all but one sector supporting the proposed fees. All respondents in the government

agency/board/commission and DAO sectors strongly supported the proposed fees. Almost all

respondents in the municipal government sector (97 per cent) supposed the proposed fees (84 per

cent strongly support, 13 per cent somewhat support).

Most of the non-government/non-profit organization sector (84 per cent) supported the proposed

fees (51 per cent strongly support, 33 per cent somewhat support), with a few (eight per cent)

reporting they were strongly opposed and a few (eight per cent) reporting they were neutral. Eighty

per cent of general public respondents supported the proposed fees (70 per cent strongly support, 10

per cent somewhat support), with a few (five per cent) being somewhat opposed and a few (15 per

cent) reporting they were neutral.

The business/industry and industry association sectors reported lower support overall. Just under

three-quarters of the business/industry sector (71 per cent) supported the proposed fees (39 per cent

strongly support, 32 per cent somewhat support). Within this sector, 14 per cent were opposed and

15 per cent were neutral. Less than half of industry association respondents (43 per cent) supported

the proposed fees (17 per cent strongly support, 26 per cent somewhat support). Within this sector, a

few (nine per cent) were strongly opposed and just less than one-half (48 per cent) were neutral,

representing the lowest support level across all sectors.


Page 37

TABLE 11 - PROPOSED ENVIRONMENTAL FEES


Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support






Non-government/non-profit organization 12 8% 8% 33% 51%


Other 4 25% 25% 50%

3.3.3 Alberta Recycling to continue management of the expanded electronics

program

As illustrated in Figure 5, just over three-quarters of respondents (78 per cent) supported the

regulation for continued management by Alberta Recycling (59 per cent strongly support, 17 per cent

somewhat support), some were neutral (13 per cent) and a few expressed opposition (four per cent

strongly oppose, seven per cent somewhat oppose).


With regard to the continued management of the expanded electronics program by Alberta Recycling

(see Table 12), the majority of respondents in most sectors supported the proposed regulation, with

82 per cent or more respondents in all but two sectors supporting the proposal. These results are

similar to those reported for the proposed environmental fees. All respondents in the DAO and

government agency/board/commission sectors strongly supported regulation enabling Alberta

Recycling to continue management of the expanded electronics program. Almost all respondents in

the municipal government sector (97 per cent) supposed the proposal (90 per cent strongly support,

seven per cent somewhat support), while a few (three per cent) were neutral. Almost all (95 per cent)

of general public respondents supported the proposal (84 per cent strongly support, 11 per cent

somewhat support), with five per cent being somewhat opposed.

Most of the non-government/non-profit organization sector (82 per cent) supported the proposal (50

per cent strongly support, 32 per cent somewhat support), with a few (eight per cent) reporting they

were somewhat opposed and a similar number (eight per cent) indicating they were neutral.

The business/industry and industry association sectors reported lower support for the proposal. About

two-thirds of the business/industry sector (65 per cent) supported continued management by Alberta

Recycling (40 per cent strongly support, 25 per cent somewhat support). Within this sector, 19 per


Page 38

cent were opposed (6 per cent strongly opposed, 13 per cent somewhat opposed), while a few (16 per

cent) were neutral. Less than half of industry association respondents (46 per cent) supported

continued management by Alberta Recycling (23 per cent strongly support, 23 per cent somewhat

support). Within this sector, 19 per cent were opposed (14 per cent strongly oppose, five per cent

somewhat oppose), while about one-third (35 per cent) were neutral. As with the proposed

environmental fees, the industry association sector represented the lowest overall support level

across all sectors.

TABLE 12 - CONTINUED MANAGEMENT OF THE EXPANDED ELECTRONICS PROGRAM BY ALBERTA RECYCLING


Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support





Government agency/ board/ commission 9 100%

Non-government/ non-profit organization 12 8% 8% 32% 50%


Other 4 25% 75%

3.4 Comments










3.4.1 Do you have any additional comments or suggestions regarding electronics

recycling in Alberta?

A total of 89 respondents answered this question, addressing a range of topics encompassing how

best to structure the mechanisms of the designated materials list and fees, and highlighting benefits of

different entities providing oversight for an expanded electronics program. Comments focussed also

on embedding strong environmental protection standards into the program, and clarifying operational


Page 39

factors such as ensuring sufficient system capacity, quality assurance, reporting, auditing and sharing

of information, research and development, funding, and minimizing administrative costs. Keeping the

program clear and simple for both operators and the public, and including stakeholder input, were

identified as being essential to successfully achieving program participation by producers, operators

and the public.

In the following section, respondents’ comments are summarized by key themes and presented in

order of frequency of mention.

Determine the purpose and scope of the designated materials list

� Phasing in some electronics now, and others at a later date, will add confusion and complexity

for the public and for operators. Expand the program to include “anything with a plug”;

further, some organizations are already collecting and processing the proposed products

including cellular phones if not already included in an EPR program, gaming equipment, electric

lawnmowers, routers and other IT equipment.

� Alternately, an approach of gradually phasing in additional products, to be harmonized with

neighbouring jurisdictions such as Saskatchewan and others across Canada, is appropriate to

achieve consistency and desired flexibility in managing the system.

� Conversely, the program should not be so broad as to incorporate “anything with a plug” but

rather should specifically exclude products such as integrated automobile electronics and

audiovisual equipment which are neither consumer disposables nor portable, but are designed

to last the lifetime of the vehicle, and are managed and recycled with the entire vehicle at the

end of its life.

� There is, and should continue to be, a role for retrofitting electronics since large volumes of

them are already being restored after being turned in for recycling, an activity that could be

expanded to provide an additional revenue stream within the system; there is also an existing

role for small business in restoring vintage audio and pre-recorded media, record players,

amplifiers, CD players, telephones and radios that should be protected and encouraged.

� Lack of support expansion of the program for items such as power tools due to the liability

incurred in relation to their batteries, nor for small appliances due to their relatively long life

spans and a lack of data explaining the impact of these items entering the recycling stream.

There are existing recycling programs for power tools and small appliances, and it may not

make sense to bundle these with electronics in the same recycling program because they do

not contain the same hazardous materials as electronics, and so do not require the same

specialized skills in handling.

Clarify the oversight model

� Alberta Recycling is the appropriate entity to manage an expanded electronics program, based

on its experience and existing solid relationships with producers and collectors.


Page 40

� Challenges to Alberta Recycling having an oversight role at all, since in neighbouring

jurisdictions this type of recycling is handled through existing relationships with producers by

the Electronic Products Recycling Association (EPRA); that having two oversight entities could

lead to duplication, inconsistencies, confusion and inefficiencies; and that the basis for

proposing the bundling of products as EPR or under the Alberta Recycling model was unclear.

� Questions about the appropriateness of using Alberta Recycling as the oversight entity since it

does not allow for collectives that enable stewards to work together to propose plans, product

lists and fees which should be best left to producers, and that it should not be the purview of

the government to set fees.

� While Alberta Recycling may be the appropriate entity to manage a transition to a broader

electronics recycling program, in the long term the system should evolve into a full EPR model

whereby industry takes full responsibility for managing and paying for product to end of life,

adding that either the producer or retailer of a product must provide an easy option for

consumers to return their product to point of purchase for recycling.

� Producers must be encouraged to enhance quality standards for products entering the market

to reduce the volume of easily disposable items.

Establish strong environmental protection guidelines, and require monitoring and best practices to

ensure accountability across jurisdictions

� There is a need to ensure accountability and recycling best practice in meeting environmental

standards to achieve net gain for the environment, including those situations where electronic

components are shipped off-shore for processing in jurisdictions where environmental

regulation may be weak or unclear.

� The guiding principle behind electronics recycling was and should remain the removal of

harmful material from waste disposal systems.

Clarify aspects of the operational framework for a full life-cycle program

� There is a need to clarify several aspects of program operation prior to expansion, including

establishing environmental standards, determining oversight of materials processing and

tracking, streamlining the collection site registration process to a single entity (e.g., the

Province vs. municipalities), establishing targets, ensuring consistent reporting requirements

including how results will be shared, incorporating independent auditing, and administering

and funding program operation.

� Sufficient processing capacity will need to be added to handle any expanded program, and that

research and development is needed now before proceeding to expand the system so that

market factors, facility capacity, quality assurance and operational issues are understood and

implemented appropriately as a foundation of success – simply adding cost for consumers is

not a guarantee that products will be recycled appropriately.


Page 41

� It is unclear whether there is sufficient capacity in the current system to handle additional

electronics and, if not, how the additional capacity would be provided and paid for.

Determine who sets fees

� Environmental fee schedules should be removed from regulation altogether, so that producers

and stewards have the flexibility to identify relevant items and establish fees in response to

fluctuating costs and market conditions.

� Fees should be established in regulation, but in such a way that items are classified in a

general, or high-level, manner, to prevent undue restriction as products evolve.

� An option for structuring fees is to tie them to weight or volume rather than class of product.

Minimize the administrative and staff cost burden

� Administrative effort for collectors, including municipalities, must be kept to a minimum in any

expanded program; it was recognized that duplicate effort already exists (and must not be

exacerbated with expansion). For example, collectors are paid by weight, but must report

products collected by count - tracking both measures adds to workload but does not provide

any demonstrated benefit.

� Collection of fees by small businesses handling specific types of electronics turns those

businesses into levy-collectors for the government, placing an administrative burden on the

businesses. In addition, expanding the electronics recycling program will lead to greater staff

costs for small businesses that could be eased through a grant program.

Keep it simple

� Any electronics recycling program must address the public’s expectation that these products

will be recycled and by extension will be accepted at collection sites; the program must

minimize consumer confusion about “what is eligible” to encourage participation by the public:

“people want to do the right thing”.

Consult meaningfully with product-specific stakeholders

� The GoA must consult with each industry sector through meaningful and appropriate dialogue

to understand the nuances and specifics of that sector’s recycling stewardship practices.

� The agricultural sector uses many of these products, including power tools, and may have input

to offer which is different than other consumers.


Page 42

4 USED OIL MATERIALS RECYCLING PROGRAM: ENVIRONMENTAL

FEE & EXPANSION

4.1 Background

Alberta’s used oil materials recycling program began in 1997 and was developed to ensure that used

oil, oil containers, and filters are managed in an environmentally appropriate manner and recycled

into useful products. The Alberta Used Oil Management Association (AUOMA) is the DAO designated

to manage the program. To date, the program has recycled over 1.2 billion litres of used oil, 98 million

filters, and 24,000 tonnes of plastic containers. For more information on the program please see

http://usedoilrecyclingab.com/.

British Columbia, Saskatchewan, Manitoba, and Quebec all operate similar recycling programs for

used oil materials.

4.2 Proposed Changes


regulation changes:

1. Increasing the environmental fee for used oil containers to 10-cents per litre of container size;

2. Adding automotive antifreeze/coolant containers to the program;

3. Adding windshield washer containers to the program;

4. Adding diesel exhaust fluid containers to the program.

4.2.1 Increasing the environmental fee for used oil containers to 10 cents per litre

of container size

As illustrated in Figure 6, 75 per cent of respondents overall indicated support for increasing the

environmental fee for used oil containers (54 per cent strongly support, 21 per cent somewhat

support). A few (nine per cent) were opposed to the proposed increase (three per cent strongly

oppose, six per cent somewhat oppose), with the remainder (16 per cent) reporting they were neutral

about the proposed increase.


Page 43

FIGURE 6 - INCREASING THE ENVIRONMENTAL FEE FOR USED OIL CONTAINERS TO 10 CENTS PER LITRE OF CONTAINER SIZE (N=161)


With regard to increasing the environmental fee for used oil containers to 10-cents per litre of

container size, levels of support varied by sector (see Table 13), with relatively strong support in all

sectors other than the business/industry and industry association sectors. All of the respondents in

the government agency/board/commission sector and the DAO sector strongly supported the

increase. The increase was also supported by all respondents who identified themselves in the ‘other’

category (75 per cent strongly support, 25 per cent somewhat support).

Almost all non-government/non-profit organization respondents (92 per cent) supported the increase

(50 per cent strongly support, 42 per cent somewhat support), with eight per cent of these

respondents being neutral. Eighty-nine per cent of municipal government respondents supported the

increase (71 per cent strongly support, 18 per cent somewhat support), six per cent were opposed (3

per cent strongly opposed, 3 per cent somewhat opposed) and three per cent were neutral. Support

was also solid at 85 per cent of general public respondents (65 per cent strongly support, 20 per cent

somewhat support), with 15 per cent being opposed (10 per cent strongly opposed, 5 per cent

somewhat opposed).

The increase found less support among business/industry sector respondents, with less than two-

thirds (62 per cent) in favour of the proposal (46 per cent strongly support, 16 per cent somewhat

support). A few of these respondents (13 per cent) were opposed (four per cent strongly opposed,

nine per cent somewhat opposed), while more than one-quarter (26 per cent) were neutral. Among

industry association respondents, just over half (52 per cent) supported the proposed increase (24 per

cent strongly support, 29 per cent somewhat support). A few (10 per cent) were opposed (five per

cent strongly oppose, five per cent somewhat oppose), while more than one-third (38 per cent) were

neutral.

3 6

1621

54

0

10

20

30

40

50

60

Strongly oppose Somewhat

oppose

Neutral Somewhat

support

Strongly support

Pe

r ce

nt


Page 44

TABLE 13 - INCREASING THE ENVIRONMENTAL FEE FOR USED OIL CONTAINERS TO 10 CENTS PER LITRE OF CONTAINER SIZE

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 25% 75%

4.2.3 Adding automotive (antifreeze/coolant, windshield washer, diesel exhaust

fluid) containers to the program

Figure 7 illustrates overall support for adding automotive antifreeze/coolant containers, windshield

washer containers, and diesel exhaust fluid containers to the program, in a pattern similar to that

reported for increasing the environmental fee for used oil containers. More than three-quarters of

respondents supported the addition of each container type.

Overall, adding antifreeze/coolant containers was supported by most (86 per cent) respondents (67

per cent strongly support, 19 per cent somewhat support), followed by adding diesel exhaust fluid

containers (82 per cent strongly or somewhat support). Over three-quarters of respondents (76 per

cent) also supported the addition of windshield washer containers (61 per cent strongly support, 15

per cent somewhat support) to the program.

A few respondents opposed adding the three container types, ranging from 14 per cent for windshield

washer containers to five per cent for diesel exhaust fluid containers, and four per cent for

antifreeze/coolant containers. A few respondents reported they were neutral, ranging from 12 per

cent for diesel exhaust fluid containers to 11 per cent for antifreeze/coolant containers, and 10 per

cent for windshield washer containers.


Page 45

FIGURE 7 - ADDING AUTOMOTIVE ANTIFREEZE, DIESEL EXHAUST FLUID, AND WINDSHIELD WASHER FLUID CONTAINERS TO THE PROGRAM


A breakdown of responses by sector and organization is shown in tables 14 through 16 below. In a

pattern similar to that reported for support for expanding Alberta’s electronics recycling program,

support was strong overall for adding all three types of containers to an expanded recycling program,

with approximately 75 per cent to 100 per cent of all respondents in almost all sectors supporting the

proposed additions. Further, a consistent pattern of support was observed across sectors, with each

sector reporting similar degrees of support or opposition across container types.

Two moderate exceptions to the generally strong support were observed. Support by the

business/industry and industry association sectors fell close to or below two-thirds of respondents for

adding the three container types, with some (ranging between five5 per cent and 19 per cent)

reporting they were opposed and between 13 per cent and 36 per cent reporting they were neutral.

TABLE 14 - ADDING AUTOMOTIVE ANTIFREEZE / COOLANT CONTAINERS TO THE PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 25% 75%

2 2

11

19

67

8 610

15

61

2 3

1216

67

0

10

20

30

40

50

60

70

80

Stronglyoppose

Somewhatoppose


Stronglysupport

Per c

en

t

Adding automotiveantifreeze/coolantcontainers to theprogram (n=173)

Adding windshieldwasher containers to theprogram (n=173)

Adding diesel exhaustfluid containers to theprogram (n=168)


Page 46

TABLE 15 - ADDING WINDSHIELD WASHER CONTAINERS TO THE PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 25% 25% 50%

TABLE 16 - ADDING DIESEL EXHAUST FLUID CONTAINERS TO THE PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 3 33% 67%

4.3 Supporting Change

4.3.1 Proposed environmental fee of 10-cents per litre of container size on

expanded list of containers

As illustrated in Figure 8, 75 per cent of respondents indicated support for the proposed fee of 10-

cents per litre of container size on the expanded list of containers (54 per cent strongly support, 21

per cent somewhat support). A few (11 per cent) were opposed to the proposed fee (four per cent

strongly oppose, seven per cent somewhat oppose), with the remainder (14 per cent) reporting they

were neutral about the proposed fee.


Page 47

FIGURE 8 – PROPOSED ENVIRONMENTAL FEE OF 10-CENTS PER LITRE OF CONTAINER SIZE ON EXPANDED LIST OF CONTAINERS


Support was strong for the proposed environmental fee from all sectors other than the

business/industry and industry association sectors (see Table 17), in a pattern similar to that reported

for the addition of the proposed container types. All respondents in the DAO and strongly supported

the proposed fee. The fee was also supported by all of government agency/board/commission sector

respondents (78 per cent strongly support, 22 per cent somewhat support) and all respondents

identifying themselves within the ‘other’ category (67 per cent strongly support, 33 per cent

somewhat support).

About two-thirds of business/industry respondents (64 per cent) supported the fee (43 per cent

strongly support, 21 per cent somewhat support), 16 per cent were opposed (three per cent strongly

opposed, 11 per cent somewhat opposed), and 20 per cent were neutral. Support for the proposed

fee found even less support among industry association respondents, with only half (50 per cent) in

favour of the proposal (32 per cent strongly support, 18 per cent somewhat support). Fourteen per

cent were opposed (five per cent strongly oppose, 11 per cent somewhat oppose), with more than

one-third (36 per cent) reporting they were neutral.

47

14

21

54

0

10

20

30

40

50

60


Pe

r ce

nt


Page 48

TABLE 17 - PROPOSED ENVIRONMENTAL FEE OF 10 CENTS PER LITRE OF CONTAINER SIZE ON EXPANDED LIST OF CONTAINERS

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support







General public 20 5% 5% 5% 15% 70%

Other 3 33% 67%

4.4 Comments










4.4.1 Do you have any additional comments or suggestions regarding used oil

material recycling in Alberta?

A total of 81 respondents answered this question, articulating a number of planning areas that require

additional effort and clarification. In particular, concerns were raised about the scope of an expanded

fluid container program, with many respondents promoting a single comprehensive program that

accepts all automotive fluid containers so that the public can easily understand and adopt the desired

recycling practices. Conversely, some respondents articulated numerous practical matters associated

with adding just the three proposed container types, stressing that confusion will arise due to

crossover programming that will confuse the public and increase inefficiencies for operators. Still

others indicated that a strong business case should be presented before decisions can or should be

made about system capacity and fee structuring to better understand cost recovery, especially for

small businesses that recycle but who are not fully compensated for their activities. A deposit-refund

model was also suggested for automotive fluid containers, similar to that already in place for beverage

containers. Respondents also highlighted the option of moving to a full EPR model involving all steps in


Page 49

the supply chain, such that producers/retailers have control and flexibility over product disposition

and fees, with government stepping away from specific regulations. Harmonization with neighbouring

jurisdictions and consultation with product-specific stakeholders was also recommended.

In the following section, respondents’ comments are summarized by key themes and presented in

order of frequency of mention.

Expand the types of automotive fluid containers accepted to create one simple, comprehensive

program

� Numerous types of automotive fluid containers not proposed for regulation could be recycled,

with large volumes currently being discarded unnecessarily for lack of recycling options,

including brake fluid, glycol, fuel filters, transmission fluid, gas line antifreeze, and so on;

having a one comprehensive Automotive Fluids Program could help avoid the confusion that

arose when the electronics recycling plan was initiated but only a few product types were

accepted.

� Strong public education and communications efforts are needed to promote the expanded

program, overcome insufficient awareness at this time, and to encourage participation.

Clarify rationale for adding windshield washer fluid and diesel exhaust fluid containers

� Questions about why windshield washer fluid and diesel exhaust fluid containers have been

proposed for addition to the used oil recycling program, citing that public confusion will arise,

in particular about containers that:

o are already recycled by existing or planned programs (e.g., plastics recycling programs

accepting opaque high-density polyethylene (HDPE) plastics or the packaging plan)

and/or;

o contain residual hazardous contents (i.e., could be better handled by household

hazardous waste initiatives and not be subject to container-specific fees) and/or;

o have contents that are considered consumable, leaving little residue when empty (i.e.,

could be better handled by existing plastics recycling programs) and/or;

o will not be harmonized with programs in neighbouring jurisdictions.

Clarify mechanisms for dealing with containers and contents that cross programs

� Building an automotive fluids program that is not quickly and easily understood will create

confusion for the public and reduce program participation accordingly, for example, if an

antifreeze container must be returned at a different site than its residual contents.

� Planning for crossover programs must be done now; programs should be easily explainable to

the public; and, any associated administrative costs should to be kept to a minimum.


Page 50

� The crossover issue, along with other complex product-specific issues, requires meaningful

consultation with product stakeholders.

Research and present the business case for fees

� Any fee structure should be based on clearly understood costs of recovery of the relevant

containers including all points along the supply and recovery chain; concern was expressed that

not only is there insufficient information available to make this type of determination, but it is

unclear whether there is sufficient room in the marketplace and current facilities to handle the

addition of the proposed container types.

� Fees should be applied only to new products and not those that are part of a recycling and/or

reuse stream.

� Concern that the proposed per litre fee is somewhat arbitrary and may be insufficient once

programs are up and running, leading to an unplanned, second increase in fees.

� A pre-set fee may lead to cutting corners on environmental standards, the antithesis of

program objectives.

� A fee increase seems unjustified without more information about program performance.

� An alternate method for fees is to base the charge on the concentration of active ingredient in

the product rather than product volume.

Consider adopting a deposit-refund model on automotive fluid containers

� A deposit-refund model should be applied as an added incentive to recycle automotive fluid

containers (i.e., similar to that in place for beverage containers); facilities could be located at

bottle depots and/or service stations. Further, this model would help eliminate used

automotive containers from entering and contaminating the valuable plastics recycling stream.

Harmonize the program with neighbouring jurisdictions

� Importance of harmonizing any recycling program in Alberta with those in neighbouring

provinces.

Move to a full EPR model

� Now is the time to implement a full EPR model involving all elements of the supply chain,

articulating that it is producer and retailer responsibility to act as the standard-bearer by giving

the consumer the opportunity to return the product to point of purchase for disposal; this

requires that the full cost be borne by the supply chain.

� As part of this model, flexibility to manage reclamation and disposal must rest with the

producer/retailer as long as standards and goals set by the regulator are met.


Page 51

� Program funds should be used to promote infrastructure at locations such as service stations,

providing clearly marked bins to recycle containers for fluids bought on site such as windshield

washer, oil and antifreeze.

Ensure appropriate cost recovery

� Ensure that generated revenues flow back to those providing the costs of service, for example,

community recycling programs; the purpose of fees should also be clearly stated.

� While small businesses incur costs to collect and recycle all types of automotive fluid

containers at this time, they are reimbursed only for used oil filters, a prohibitive situation for

business profitability and a deterrent to participation.

� Rather than a cost-per-litre model, fees should be reduced on larger containers to encourage

their use, resulting in less waste per litre.


Page 52

5 ENABLING OF EXTENDED PRODUCER RESPONSIBILITY

5.1 Background

Extended producer responsibility (EPR) is a form of product stewardship that establishes producers’

responsibility for the end-of-life management of their products or packaging. Producers are typically

the manufacturers, brand owners, importers, or first sellers of a product into a province. Extended

Producer Responsibility shifts the physical and/or financial responsibility for recycling away from the

general taxpayer to producers and consumers. This approach is being applied to an increasing array of

products and materials across the country and around the world, either voluntarily by producers or in

response to regulation.

In Alberta, EPR is occurring in some voluntary industry managed stewardship programs, such as the

cell phone recycling program, the pesticide container recycling program, and the plastic bag reduction

program. There is currently no regulated stewardship program in Alberta managed under an EPR

framework.

Alberta’s five existing provincially regulated recycling programs are managed by delegated

administrative organizations, which are led by multi-stakeholder boards. Alberta’s DAOs are supported

by legislation, operate at arm’s-length from government, and are required to report annually to the

Minister on progress and financial status. No changes are being proposed to the management or

management framework of the existing programs.

Enabling EPR in Alberta is in line with the Canadian Council of Ministers of the Environment’s 2009

Canada-wide Action Plan for Extended Producer Responsibility, which provinces and territories

endorsed.

Many Canadian provinces have extended producer responsibility programs in place for packaging and

printed paper, electronics, household hazardous waste, and other products. Under an EPR framework,

producers have the option to meet their regulatory obligations individually or join a collective that has

received approval from government to manage the designated material on behalf of its member

producers. To date most producers of designated materials in other provinces have chosen to join

collectives. Such collectives are generally governed by an industry-based board of directors, rather

than a multi-stakeholder board.

5.2 Proposed Change

5.2.1 Enable extended producer responsibility

The large majority of respondents were supportive of enabling producer responsibility in regulation

(55 per cent strongly support, 30 per cent somewhat support). A few respondents (11 per cent) were


Page 53

opposed to the proposal (eight per cent strongly oppose, three per cent somewhat oppose), and five

per cent were neutral.

FIGURE 9 – ENABLING EXTENDED PRODUCER RESPONSIBILITY IN REGULATION (N=186)


Looking at support or opposition to the proposal by sector (see Table 18), most or all respondents in

all sectors supported the proposal, with least support (73 per cent) reported by the industry

association sector (42 per cent strongly support, 31 per cent somewhat support). Seventeen per cent

of industry association respondents opposed the proposal (14 per cent strongly opposed, three per

cent somewhat opposed) and 10 per cent were neutral. All respondents supported the proposal in the

government agency/board/commission sector (78 per cent strongly support, 22 per cent somewhat

support) and the DAO sector (50 per cent strongly support, 50 somewhat support).

Almost all of municipal government respondents (97 per cent) supported EPR in regulation (62 per

cent strongly support, 35 per cent somewhat support), with a few (three per cent) being neutral.

Similarly, almost all of non-government/non-profit organization respondents (91 per cent) supported

the proposal (73 per cent strongly support, 18 per cent somewhat support), with nine per cent of

these respondents being neutral.

8

35

30

55

0

10

20

30

40

50

60


Pe

r ce

nt


Page 54

TABLE 18 – ENABLING PRODUCER RESPONSIBILITY IN REGULATION

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support




Delegated administrative organization 2 50% 50%

Government agency/ board/commission 9 22% 78%



Other 4 50% 50%



regulation changes that support enabling EPR in Alberta:

1. Allowing producers to meet their regulatory obligations individually or by joining a collective;

2. The regulatory requirements of stewardship program plans;

3. Annual reporting requirements on program performance.

As illustrated in Figure 10, support was strong overall for the all three of the proposed regulatory

changes, with 85 per cent or more respondents supporting all three changes.

FIGURE 10 - ALLOWING PRODUCERS TO MEET THEIR REGULATORY OBLIGATIONS INDIVIDUALLY OR BY JOINING A COLLECTIVE; THE

REGULATORY REQUIREMENTS OF STEWARDSHIP PROGRAM PLANS; AND ANNUAL REPORTING REQUIREMENTS ON PROGRAM

PERFORMANCE

6 3 6

27

58

7 4 5

29

56

4 3 4

21

68

0

10

20

30

40

50

60

70

80


Per c

en

t

Allowing producers to meet their regulatory obligations individually or by joining a collective (n=189)

The regulatory requirements of stewardship program plans (n=193)

Annual reporting requirements on program performance (n=190)


Page 55

5.3.1 Allowing producers to meet their regulatory obligations individually or by

joining a collective

As illustrated in Figure 10, most respondents (85 per cent) supported allowing producers to meet

regulatory obligations individually or by joining a collective (56 per cent strongly support, 29 per cent

somewhat support). A few respondents (nine per cent) were opposed to the regulatory change (six

per cent strongly oppose, three per cent somewhat oppose), with the remainder (six per cent)

reporting they were neutral.

5.3.2 The regulatory requirements of stewardship program plans

Similarly, most respondents (85 per cent) supported the regulatory requirements for stewardship

program plans (58 per cent strongly support, 27 per cent somewhat support). A few (11 per cent)

were opposed to the proposed change (seven per cent strongly oppose, four per cent somewhat

oppose), with the remainder (five per cent) reporting they were neutral (see Figure 10).

5.3.3 Annual reporting requirements on program performance

As illustrated in Figure 10, respondent support was highest (89 per cent strongly or somewhat

support) for annual reporting requirements (68 per cent strongly support, 21 per cent somewhat

support). A few (seven per cent) also opposed the annual reporting requirements on program

performance (four per cent strongly oppose, three per cent somewhat oppose) and four per cent were

neutral.


Tables 19 through 21 provide detailed results of degree of opposition or support for the three

supporting changes enabling producer responsibility, and are summarized below by sector. Support

was strong overall across sectors for adding to regulation all three supporting changes enabling

extended producer responsibility. Between three-quarters to 100 per cent of all respondents in all

sectors supported the proposals. A minor exception was noted for the delegated/administrative

organization sector (n=2), with 50 per cent support, 50 per cent oppose.


Page 56

TABLE 19 - ALLOWING PRODUCERS TO MEET THEIR REGULATORY OBLIGATIONS INDIVIDUALLY OR BY JOINING A COLLECTIVE

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 50% 50%

TABLE 20 – REGULATORY REQUIREMENTS OF STEWARDSHIP PROGRAM PLANS

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 5 40% 60%

TABLE 21 - ANNUAL REPORTING REQUIREMENTS ON PROGRAM PERFORMANCE

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support







General public 20 10% 10% 20% 60%

Other 5 20% 80%


Page 57

5.4 Comments










There were two open-ended questions related to EPR in the workbook.

� Do you have any suggestions for changes or additions to the regulatory requirements for

stewardship program plans?

� Do you have any additional comments or suggestions on enabling extended producer

responsibility, including comments related to governance of extended producer responsibility

programs and government oversight?

5.4.1 Do you have any suggestions for changes or additions to the regulatory

requirements for stewardship programs?

A total of 74 respondents commented on the proposed regulatory requirements of stewardship

program plans.

Comments from those in support of the proposal (n=60) primarily addressed how to improve the

proposed program overall, including suggestions that elements such as the removal of DAOs as part of

a move to a full EPR model that provides producers with full flexibility on program design and

governance/decision-making. Regardless, decisions on product designation and targets must be based

on, and consistent with, science, existing product regulations, and accurate data.

Other comments related to the need for clarity, consistency, fairness (for producers, operators,

consumers and workers), and transparency, including in the determination and disposition of fees.

Enforcement and capacity to enforce were considered essential to program success, as was a strong

consumer education program. Additional consultation is required to determine industry-specific

requirements; clarify the role of municipalities; identify appropriate incentives and alternate tools to

reduce waste; and to clarify the process for setting targets. Respondents indicated in particular that

target setting is one area in which a one-size-fits-all solution is not suitable.


Page 58

Comments from respondents who opposed the proposal (n=14) reflected that the program as

proposed is not desirable because similar efforts in other jurisdictions do not work; that the proposal

is not a true EPR program nor is it a fully outcomes-based approach; that some program elements are

not completely defined or clear as set out in the workbook; and that the current model of programs is

working satisfactorily and does not require change.

The following section summarizes respondents’ comments and are summarized by key themes and

presented in order of frequency of mention.

Ensure transparency and fairness

� Performance must be measured both individually and collectively so that weak performers

cannot hide behind top performers; there is a role for government to ensure free-rider

behaviour does not occur and that volatility in commodity prices does not act as an excuse for

not meeting requirements.

� Conversely, others feel it is not appropriate to prescribe some of the proposed reporting

elements in regulation, for example, consultation with affected parties is important for an

effective program, but design should be left to the producer; consideration of free market

competition is important but prescribing it could hamper free market competition; and details

of dispute resolution and fee setting are better handled by an equitable, timely and robust

mechanism and provision of transparent fee setting criteria.

� Confidential business information must be protected; prescribing reporting of targets and

outcomes for certain categories of materials that have small competitive markets put this

confidentiality at risk.

� Regulation should apply to all programs for equity; voluntary programs should also be required

to report their activities publicly to ensure fairness to all sectors.

� A simple and transparent model and reporting mechanism are required, in which the role of

municipalities is clearly evident, and where an advisory panel including all stakeholders is

required.

Expand the toolbox, including incentives

� Preferential treatment should be allowed (e.g., lower fees) for products with better

environmental performance.

� Landfill bans should be allowed; they would to act as a market signal about product end of life

value and encourage green investment in Alberta.

� Consider levying fees based on a whether a product is “single-use” or “multi-use”, to reduce

the overall load of recycling in the province (e.g., disposable wipes get levied while reusable

wipes would not).


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� Recognize that landfills are part of the solution rather than an entirely negative option, the

latter view tends to hamper innovation; effort is needed to enhance landfill landscapes for uses

such as parks.

� Move from a voluntary to a mandatory plastic bag program.

Clarity utilization/disposition of fees

� Consideration should be given to mandating producers to pay a defined amount per product

into a pool for distribution to municipalities to help support existing programs and limit their

disruption, and to offset costs for collecting products on behalf of other programs that

generate little or no revenue for the municipality.

� Need for a more fair and equitable system of revenue sharing; revenues generated should

return to community service providers (i.e., bottle depots, other collectors) who bear the

operating costs.

� "Double-dipping" must not be allowed (i.e., fees must not be paid into more than one program,

or as part of both municipal taxes and producer fees).

� Greater clarity on diversion metrics is required, for example they should consider the unique

circumstances of certain designated material; be categorized by the 3Rs, with outcomes for

consumable products, such as windshield wiper fluid, having distinctly different options than

heavy fluids, such as motor oil, which require further processing; methodologies for developing

metrics should be based on accurate data and be shared with all stewards.

One size does not fit all for targets

� Collection targets are not necessarily universally applicable; stewards have little control over

how consumers dispose of their products, for example, many collect electronic products to

finance charity programs and these items do not enter recovery programs.

� Targets are better set once programs are in operation so that they can be based on sound and

accurate data.

� Targets must distinguish between consumables such as newspapers and beverage containers,

and those with longer lifecycles such as vehicles and machinery.

� Stakeholders must be involved in the target-setting exercise, including developing realistic

metrics and diversion goals.

� Enable multiple stakeholders (specifically, producers of all sizes) to be involved in decision-

making, setting of criteria, and setting regulatory requirements so that their interests and

expertise are accounted for.


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Provide greater clarity and assurance; best practices review and more consultation is required

before regulation

� It is important that the program overall, provide producers with clarity, certainty and

predictability for their sector, and as such additional consultation is required with all subject

matter experts prior to the development of detailed regulation.

� Learnings from programs in other jurisdictions should be applied as part of the process,

including challenges associated with time delays in implementation and harmonization.

� Consultation will help inform policy regarding the importance of protecting confidential

business information, especially for producers with relatively few competitors.

� Concern regarding what Alberta proposes to do differently from other provinces with similar

programs -- the proposed reporting requirements are invasive and arduous, and it is difficult to

assess costs associated with them, especially for small industries; further, experience suggests

that some producers have been forced, rather than given the option, to join a collective, but do

not have a voice in the collective.

� No improvement in packaging design has occurred in other jurisdictions where programs

similar to the one proposed are in operation; there is no evidence that recycling rates have

increased; and the proposed approach removes programs from the communities who have

developed and nurtured them and driven their results; and there is a risk that handing full

responsibility to producers will focus delivery of programs at the lowest cost without

consideration for convenience, quality and service, all of which promote recycling.

Move to a full EPR system

� Existing stewardship programs should be included in the EPR system in addition to the

proposed new programs or, at a minimum; a timeline for doing so should be identified.

� Paint and coatings stewardship plan should be run on a fully EPR basis.

� The current DAOs should be dissolved to prevent confusion and ensure a level playing field for

stewards.

� The imposition of including social targets in EPR will create extraneous costs that are unrelated

to producer obligations.

� Any proposed program should not be overly prescriptive but enable flexibility for producers.

� Producers should be assigned all responsibility for product end of life within a full EPR model.

Fees should not be prescribed

� The European Union offers a practical model in which cost recovery is not prescribed but

where producers are encouraged to seek stewardship compliance services at the most

competitive price, facilitating the existence of competition between EPR compliance schemes,

and allowing for producers to discharge their obligations either individually, by sector or

collectively.


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� Concern that requiring stewardship plans to establish environmental fee criteria will

discourage commercial enterprises from operating stewardship programs for PPP; requirement

to establish environmental fee criteria should be limited to only those EPR schemes that

require such fees be approved by government.

Provide consistency

� All regulation-enabled stewardship programs, including EPR, should meet the same set of

requirements, criteria and standards, which should be specific, comprehensive and formally

incorporated into all program stewardship documents.

� Producers should not be allowed to set up separate or individual programs distinct from a

provincial program; this can result in coverage gaps, multiplicity of effort; confusion;

fragmented services to the public; inconsistency in fees to the public; and variation in quality of

service and procedures.

� Programs should be consistent across the province.

Use science and existing standards for determining designations and for product review

� Designation of pesticide products should be clear and unambiguous; existing pest control

regulations should act as the basis for judging products.

� Determining whether a product requires diversion or is available for diversion must also be

science-based, and include a detailed cost-benefit analysis.

� Product evolution and new technologies require science-based review to determine

appropriateness for program inclusion.

� Use Canadian Standards Association Standard as the basis for regulating product

inclusion/exclusion.

Communicate with consumers

� Consumer education is key. Partnering with existing corporations or community education

resources will serve to enhance communication efforts as well as strengthen reputations and

relationships with customers.

� Government must be at the forefront of program launch and explain the consumer role in

recycling, including the cost-benefit.

Ensure enforcement, including capacity to enforce

� Enforcement, and the ability to carry it out at all levels of government, is fundamental to

program success.

� A stakeholder committee could play a role in enforcement.

� EPR program to ensure compliance amongst large manufacturers; guard against large

manufacturers taking a “heavy-handed” approach (i.e. through legal challenges).


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Inclusion of other sectors

� The IC&I sector and the agriculture sector should be included in proposed regulations.

Focus on reduction first

� It is as important or more important to encourage reduction at source compared to recycling;

an emphasis on reducing packaging is required.

Clarify terminology

� Additional clarity is required for terms such as producer; "first importer or distributor" may be

more accurate because manufacturers or producers may not be responsible for placing the

product into the Alberta marketplace.

The current model works

� Current DAOs should remain in place; they are working well and balance the interests of public

and the producers need for profitability and environmental obligations.

5.4.2 Do you have any additional comments or suggestions on enabling extended

producer responsibility, including comments related to governance of

extended producer responsibility programs and government oversight?

A total of 82 respondents commented on extending producer responsibility. Comments from

respondents who supported or were neutral (n=72) about extended producer responsibility suggested

that there was slightly more support for a multi-stakeholder stewardship approach, including multi-

stewardship governance, than for a full EPR model in which the producer takes full responsibility for

the physical and financial product end of life as well as all decision-making associated with how

programs will be managed.

Overall, respondents sought clarity over and above the information offered in the consultation

workbook with regard to the extent to which an EPR model could be implemented, as well as

governance and board structuring. Many requested the opportunity to participate in additional and

detailed consultation, expressing a desire that this occur prior to decisions being made about Alberta's

proposed plan. These stakeholders want to provide their unique and informed input to program

characteristics that will contribute to its success, based on their experience within and outside of

Alberta.

Further, the role of municipalities requires clarification, given their current expertise and investment

in waste recycling services and infrastructure, with respondents suggesting that municipalities should


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maintain a central role while others indicated that municipalities must be treated like any other

service provider in an open market system. Lastly, support for EPR depended on several additional

details, including that reporting administration not be onerous; that the model include rigorous

enforcement and standards; that it be phased in over a practical timeline; that it provide a level

marketplace playing field for producers; and that public education be provided for the consumer to

explain cost recovery as well as their recycling options.

Comments from those who opposed (n=10) enabling EPR reflected concern that the government

should play a limited role in defining how producers should manage product end of life; that the

government should never require any reporting other than diversion rates; that non-prescriptive

programs are effective and hence regulation is not required; that profit will be placed ahead of

environmental objectives should producers be given the flexibility associated with an EPR approach;

and that a lack of accountability will prevail. Other respondents indicated that the proposed approach

does not go far enough in recommending a true EPR model. Comments also suggested that

respondents were concerned about creating an uneven playing field in the marketplace for producers,

and that the proposed expansion does not account for operators who are not appropriately

experienced and invested in the field.

The following section summarizes respondents’ comments by key themes and presented in order of

frequency of mention.

A multi-stakeholder stewardship approach provides a balance

� Support for some form of multi-stakeholder/shared responsibility system ("shared EPR")

because it can be impartial; ensures public involvement through government; enables

engagement with government, communities, consumers, stewardship organizations and

industry; reduces program duplication/reporting (i.e., due to existing successful programs e.g. ,

milk containers); and continues to involve long-standing investment in programs and

infrastructure. Further, it ensures local expertise, jobs and practices for local/regional recycling

activity rather than being driven by external (national or multi-national) priorities.

� EPR should not be considered to be the one and only solution; it is one of a number of options

available for diversion as evidenced by many successful programs already in operation in

Alberta.

� While producers have a responsibility for product end of life, moving to a 100 per cent EPR

model is an incorrect incentive, since consumers as well as policies of municipal and provincial

governments influence use and management of products; accordingly, all parties have a

responsibility and all parties can share in the success of the system; principals should apply

equally to municipalities, collectors, transporters, recyclers and processors.

� Potential risks associated with allowing producers to determine the best way to meet

environmental objectives to include: limiting reporting requirements, placing cost savings

ahead of environmental mandates; ignoring public feedback on programs (as observed in other


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jurisdictions); and creating a lack of accountability that can and should be appropriately

covered by independent third party auditing such as that provided by DAOs.

� Some respondents indicated that voluntary and existing producer programs are established

and are working well in the absence of regulation; it is unnecessary to be more prescriptive.

A full EPR system is preferred

� A full EPR system is an effective framework, putting the onus on producers to ensure realistic

targets are both set and met; cost-internalization of stewardship costs drives efficiency

improvements because the profit motive requires constant improvement of the product's

margin.

� Municipalities should not have their collection and cost recovery role enshrined in legislation,

but rather should be treated as any other service provider.

� Reporting to government on anything other than diversion rates is inappropriate if the

program is not government funded or government run; the proposed reporting requirements

are invasive.

The degree to which EPR will expand is unclear; further detailed consultation and research is

required

� Further detailed consultation is required to obtain input from specific industry sectors so that

their knowledge and unique circumstances can be considered appropriately in the

development of any program, prior to final decisions being made.

� Consideration should be made for including packaging suppliers in the design of recovery

systems due to their technical expertise.

� The state of the current business climate should be assessed carefully before imposing EPR,

including a robust cost/benefit analysis and economic competitiveness assessment.

� Support by industry for the proposed approach will be dependent on additional information

and consultation about the cost-sharing model; the specifics of regulation for packaging and

household hazardous wastes; the process for designating and defining waste and product

categories, especially for those that are highly complex in composition and require significant

scientific and technical knowledge; the proposed review mechanism for reassessment of

designated products; assurance that products not needing to be diverted are not diverted; and

confirmation that empty packages will not be subject to fees from more than one program.

� Further clarification is needed regarding the handling of materials entering the province from

other jurisdictions (e.g., magazines).

� Under an EPR approach, full control over collection and processing of their end of life

materials, and related priorities, rests with the producer, so it is unclear why this does not

appear to be clearly embedded in the proposed approach.


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Governance including board make-up needs clarification

� Board structure needs clarification and suggested that the board should include key

stakeholders from industry but not be exclusive to industry, and should not be prescribed but

should allow producers/stewards to design their governance and oversight in a way that allows

them to best meet their obligations.

� Regulation should focus on prescribing governance outcomes such as reporting requirements

and verification standards.

� Governance must be strong to prevent big companies prioritizing profit over environmental

priorities.

Recognize and build on municipal strengths

� Important to build on the strong connection between municipalities and their customers; they

are familiar with the needs and expectations of the local community and hence the municipal

role in any proposed enhanced system needs to be clearly defined.

� Municipalities have developed and maintained significant collection and recycling services, and

deliver those services successfully; they should have right-of-first-refusal to provide services.

� Municipalities have strong relationships with communities and with industry; there is a great

opportunity to continue to build these partnerships.

Ensure reporting administration is not onerous

� Important to keep reporting effort at a reasonable level; for example, build on existing

successes such as the Manitoba program that employs a specified procedures reporting

template. Conversely, British Columbia's third party reasonable assurance reporting model was

strongly criticized since it has doubled administrative load without offering any program or

environmental benefit.

� Reporting should be free from political agendas and be shared with the Official Opposition.

Embed strong enforcement and performance standards

� Support for the proposed program expansion, and program success, is dependent on including

enforceable targets.

� Performance standards need to address reduction and design-for-environment.

� Best practices should be captured from existing stewardship programs (e.g., multi-stakeholder

governance).

Implement on a practical timeline

� Program success will be greater if sufficient time (perhaps more than 18 months) is allowed to

implement programs for products that may require infrastructure or market development.


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� An expanded program involving many new and different products will run more smoothly if it

is phased in over time (i.e., second and third tier products) so that there is an opportunity to

learn from opportunities and evaluate successes, gradually allowing consumers and retailers to

participate accurately and effectively.

Clarify exclusions and limits

� An expanded program will not be supported if it permits collection of items that do not need to

be diverted; if it subjects an item to more than one fee (i.e., is affected by more than one

program stream); and if it does not provide product management for products that will

become obsolete.

� De minimus rates for some products may be appropriate.

Include the consumer

� Program success requires engaging the consumer to understand the implications and options

they have to make a difference, suggesting a communications/public education strategy is

needed; and that using tools already familiar to consumers such as a refund-deposit model will

enhance participation.

Clarify definitions

� The workbook document is confusing in terms of how taxpayers, producers and consumers are

defined; this lack of clarity opens the risk of free-riding.

� Only local processors in Alberta with demonstrated investment in processing collected

recyclables should be allowed to process, to eliminate the many "fly-by-night" operations that

process recyclables without any governance or “watchdogging”.

Continuity and consistency provided by the current system are essential

� Municipalities are at the core of waste management services for Albertans and will be required

to handle these materials regardless of the external programs in place. Industry programs, such

as those for milk containers and electronics (with respect to cell phones) have not been

effective and have not resulted in cost recovery; further, some programs are subject to

restrictions that limit performance due to existing agreements. It does not appear that these

realities will change under the proposed approach. The Alberta Recycling stewardship model

collects funding on a user pay basis and provides collection site funding to offset the cost of

operations, while industry commitments and funding will rise and fall with their stock price.

Municipalities and waste infrastructure are in place and will continue to be, so the current

arrangement with proven programs should be supported.


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Ensure a level free market playing field

� Newspapers should not be included in the proposed EPR regime, since the current recycling

system is efficient and delivers a high diversion rate for newsprint; adding cost to small rural

newspapers for example could be very detrimental to their businesses without adding

environmental benefit.

� Additional information is required to clarify the participation of volunteer and non-profit

recycling organizations that already provide end of life management for most recyclables and

depend on fiber recyclables for operating revenue.

� Paper products entering from outside the province could be taxed so that local producers are

not put at a disadvantage in a free market.


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6 DESIGNATION OF PACKAGING AND PRINTED PAPER

6.1 Background

Packaging and printed paper (PPP) makes up a significant portion of the waste generated in Alberta.

Managing this waste stream entails substantial costs for municipalities and, by extension, taxpayers.

Alberta’s Too Good to Waste Strategy and CCME Canada-wide Action Plan for Extended Producer

Responsibility include commitments to implement a provincially regulated stewardship program for

PPP.

The CCME has carried out work to address packaging and printed paper waste. The Canada-wide

Strategy for Sustainable Packaging builds on the Canada-wide Action Plan for Extended Producer

Responsibility to reduce packaging waste in Canada and promote more sustainable packaging choices.

In addition, Ministers announced an industry-driven approach to reduce packaging in Canada, where

industry committed to initiatives that will reduce the amount of packaging destined for landfills,

reduce greenhouse gas emissions, and increase recycled content in packaging.

Regulated stewardship programs for PPP have already been implemented in Manitoba, Ontario and

Quebec, and are currently being developed in British Columbia and Saskatchewan.


Details on the specific designation of PPP include:

I. Packaging means any package or container, or any part of a package or container that is

comprised of glass, metal, paper, boxboard, cardboard, paper fiber or plastic, or any

combination of any of those materials and includes, but is not limited to, service packaging.

II. Service Packaging means packaging that is filled or applied at the point of sale to enable or

facilitate the delivery of goods by a retail seller or a food service industry or other service

industry outlet.

III. Printed Paper means paper that is not packaging, but is printed with text or graphics as a

medium for communicating information, and includes flyers, brochures, booklets, catalogues,

newspapers, magazines, paper fiber, telephone directories, and paper used for copying,

writing or any other general use, but does not include other types of bound reference books,

bound literary books, or bound text books.

The designation would exclude:

� Containers included in existing provincial recycling programs (paint containers, used oil

containers, beverage containers).


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� Agricultural plastics, including: baling twine; net wrap; silage pit, pile covers, bags or tubes;

grain bags or tubes; bale wrap, tubes or bags.


regulation changes:

1. Designation of packaging for a provincial stewardship program;

2. Designation of service packaging provincial stewardship program;

3. Designation of printed paper for a provincial stewardship program;

4. Managing packaging and printed paper under an EPR program.

6.2.1 Designation of packaging, service packaging and printed paper for a

provincial stewardship program.

As illustrated in Figure 11, approximately half of survey participants strongly support the designation

of PPP as defined in the workbook. In total, 81 per cent strongly or somewhat support the designation

of packaging as defined for a provincial stewardship program, 80 per cent strongly or somewhat

support the designation of printed paper and 75 per cent strongly or somewhat support the

designation of service packaging.

FIGURE 11 - DESIGNATION OF PACKAGING, SERVICE PACKAGING AND PRINTED PAPER MATERIALS


A breakdown of responses by sector and organization is shown in tables 22 through 24 below. Most

respondents across all sectors indicated support for each of the designated materials, reporting levels

of overall support ranging from 56 per cent to 100 per cent. The industry association and

4 3

12

28

53

84

13

26

49

82

10

27

53

0

10

20

30

40

50

60


Per c

en

t

Designation of packaging as defined for a provincial stewardship program (n=184)

Designation of service packaging as defined for a provincial stewardship program (n=183)

Designation of printed paper as defined for a provincial stewardship program (n=181)


Page 70

business/industry sectors reported the weakest levels of support for each of the designated materials.

For each of the designated materials there is a minority indicating strong opposition within

business/industry, industry associations, non-government/ non-profit organizations and the public.

TABLE 22 - DESIGNATION OF PACKAGING AS DEFINED FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 5 20% 20% 60%

TABLE 23 - DESIGNATION OF SERVICE PACKAGING AS DEFINED FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 5 20% 20% 60%


Page 71

TABLE 24 - DESIGNATION OF PRINTED PAPER AS DEFINED FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 25% 25% 50%

6.2.3 Managing Packaging and Printed Paper under an Extended Producer

Responsibility Program

Figure 12 illustrates the majority of participants support managing PPP under an EPR program. Almost

80 per cent of participants support placing PPP under an EPR program, while 15 per cent oppose (nine

per cent strongly oppose, six per cent somewhat oppose). Nine per cent indicated a neutral response.

FIGURE 12 - MANAGING PACKAGING AND PRINTED PAPER UNDER AN EXTENDED PRODUCER RESPONSIBILITY PROGRAM (N=177)

The percentage of respondents indicating support or opposition for managing PPP under an EPR

program is broken down by sector and organization in Table 25. Again, most respondents across all

sectors indicated support for managing PPP under an EPR program, with the exception of the DAO

sector, where 50 per cent support and 50 per cent oppose. There is a minority indicating strong

opposition within business/industry, industry associations, non-government/ non-profit organizations

96

9

21

56

0

10

20

30

40

50

60


Pe

r ce

nt


Page 72

and the public. Overall, industry associations indicated the least support for an EPR to manage PPP (36

per cent strongly support).

TABLE 25 - MANAGING PACKAGING AND PRINTED PAPER UNDER AN EXTENDED PRODUCER RESPONSIBILITY PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 5 20% 80%


Participants were asked to rate their level of opposition or support for the following regulation

changes, which support the designation of packaging and printed material under an EPR program:

1. The proposed timeline of 12 months for submitting a stewardship program plan for packaging

and printed paper;

2. The proposed timeline of 18 months (from the time a program stewardship plan is approved)

for implementing a packaging and printed paper program;

3. Excluding agricultural plastics as a designated material under a packaging and printed paper

program.

As illustrated in Figure 13, support varied across the three supporting changes for designating PPP to

be managed under an EPR program. Overall, support for the proposed regulatory changes relating to

timelines was strongest and support for excluding agricultural plastics as a designated material under

a PPP program was weakest.


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FIGURE 13 - SUPPORTING CHANGES FOR DESIGNATING PPP TO BE MANAGED UNDER AN EPR PROGRAM


plan for packaging and printed paper

As illustrated in Figure 13, the majority of participants supported (63 per cent strongly or somewhat

supported) submitting a stewardship program within the 12 month period and generally cited the

need not to delay the changes since PPP is a major waste stream. There were also comments from

supporters saying many of the mechanisms are already in place through municipal collection systems.

However, there was also strong opposition to the timelines, mainly from industry associations and

business/industry. They indicated their experience in other jurisdictions has proven the move to an

EPR paper and packaging program is very complex and time consuming.

In provinces where the EPR PPP program was rushed there have been many changes and a great deal

of frustration. It was also felt that without adequate harmonization it will be very difficult for industry

to respond to yet another provincial EPR program while several are still in the implementation stage.

There was also considerable commentary suggesting the need for further consultation and a better

understanding of municipal roles under an EPR program.

14

9

15

28

35

13

7

21

26

34

28

1720

12

24

0

5

10

15

20

25

30

35

40

Strongly oppose Somewhatoppose


Strongly support

Per c

en

t

The proposed timeline of 12 months for submitting a stewardship program plan for packaging and printedpaper (n=178)

The proposed timeline of 18 months (from the time a program stewardship plan is approved) forimplementing a packaging and printed paper program (n=176)

Excluding agricultural plastics as a designated material under a packaging and printed paper program(n=176)


Page 74


Levels of support varied considerably by sector (see Table 26) with the strongest overall support

originating from the government agency/board/commission sector (89 per cent strongly or somewhat

support) and the weakest support originating from the industry association sector (44 per cent

strongly or somewhat support).

TABLE 26 - THE PROPOSED TIMELINE OF 12 MONTHS FOR SUBMITTING A STEWARDSHIP PROGRAM PLAN FOR PACKAGING AND PRINTED

PAPER

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support







General public 20 15% 15% 20% 50%

Other 4 25% 25% 50%


plan is approved) for implementing a packaging and printed paper program.

As illustrated in Figure 13, the majority of participants supported (60 per cent strongly or somewhat

supported) the proposed 18 month timeline for implementing a PPP program. Several

business/industry sector respondents operating in the global marketplace indicated the timeline was

not realistic since packaging decisions are not made for a provincial market, rather are made for a

global market.


With regard to the proposed timeline of 18 months for implementing a PPP program (see Table 27)

levels of support varied across sectors, with the strongest overall support originating from the

municipal government sector (86 per cent strongly or somewhat support) and the weakest support

originating from industry association sector (37 per cent strongly or somewhat support).


Page 75

TABLE 27 - THE PROPOSED TIMELINE OF 18 MONTHS (FROM THE TIME A PROGRAM STEWARDSHIP PLAN IS APPROVED) FOR

IMPLEMENTING A PACKAGING AND PRINTED PAPER PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support







General public 20 15% 15% 25% 45%

Other 5 20% 80%

6.3.5 Excluding agricultural plastics as a designated material under a packaging

and printed paper program

Excluding agricultural plastics received more opposition than support. As illustrated in Figure 13, 45

per cent of participants oppose leaving agricultural plastics out of the regulation. Those in favour of

leaving agricultural plastics out cited the need to ensure there is a mechanism to deal with plastics

before setting up a program to collect them.

Those who feel agricultural plastics should be included indicated it is a major problem within the

province because many farmers and ranchers are simply burning these products as there is no

appropriate means of dealing with them. Some respondents feel that agricultural plastics make up a

major component of the waste stream within rural municipalities, and is therefore a significant

concern .


Levels of support and opposition to excluding agricultural plastics as a designated material under a

PPP program vary considerably across sectors (see Table 28). Strongest support originated from the

DAO sector (100 per cent somewhat support). Strongest opposition originated from the

government/agency/commission sector (63 per cent strongly oppose), followed by the general public

(45 per cent strongly oppose).


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TABLE 28 - EXCLUDING AGRICULTURAL PLASTICS AS A DESIGNATED MATERIAL UNDER A PACKAGING AND PRINTED PAPER PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support






Non-government/ non-profit organization 11 27% 9% 9% 18% 36%

General public 20 45% 5% 5% 15% 30%

Other 5 40% 20% 20% 20%

6.4 Comments










There were three open-ended questions relating to PPP in the workbook.

� Do you have any comments regarding materials from the non-residential sector?

� What role do you see municipalities playing in a packaging and printed paper program?

� Do you have any additional comments or suggestions regarding packaging and printed paper in

Alberta?

6.4.1 Comments regarding materials from the non-residential sector

Participants were first asked whether or not they thought material from the non-residential sector

(industrial, commercial, institutional) should be included in a packaging and printed paper program?

Most participants (75 per cent) felt the Industrial, Commercial and Institutional (IC&I) sector should be

part of a PPP program.


Page 77

FIGURE 14 - DO YOU THINK MATERIAL FROM THE NON-RESIDENTIAL SECTOR (INDUSTRIAL, COMMERCIAL, INSTITUTIONAL) SHOULD BE

INCLUDED IN A PACKAGING AND PRINTED PAPER PROGRAM? (N=179)

While participants overall indicated material from the IC&I sector should be part of a PPP program,

there were major differences in the opinions within the business/industry sector and among industry

associations (see Table 29).

TABLE 29 - MATERIAL FROM THE NON-RESIDENTIAL SECTOR (INDUSTRIAL, COMMERCIAL, INSTITUTIONAL) SHOULD/SHOULD NOT BE

INCLUDED IN A PACKAGING AND PRINTED PAPER PROGRAM BY SECTOR/BUSINESS

Sector/Organization N= Yes No


Business/ industry 65 65% 35%

Industry association 27 52% 48%


Government agency/ board/ commission 8 100%



Other 4 100%

Respondents were asked if they had any comments regarding materials from the non-residential

sector. In total, 107 respondents provided comments. Seventy-seven respondents provided comments

in support of inclusion of materials from the non-residential sector. Respondents felt that because the

IC&I sector was the largest contributor to waste, it would be shortsighted not to include this in the

proposed program. They indicated that the intent of any stewardship program should be to get at the

material stream generating the greatest environmental impact. They felt that while residential waste

is the low hanging fruit and will be easier to deal with, it will reap fewer rewards in terms of overall

waste reduction.

Thirty-six respondents provided comments in opposition of non-residential waste being included in

the proposed program. Respondents felt that the IC& I waste stream is completely different than the

residential waste stream in terms of composition, and therefore requires a completely different

system to handle collection, processing and recycling. Some respondents indicated opposition to

Yes75%

No25%


Page 78

paying diversion fees for the IC&I sector, as they felt it is a cost of doing business for this sector and

offered the example of commercial leases often including the cost of managing IC&I waste. Other

reasons provided by respondents pointed to the pre-existing and viable competitive private sector

already service this space; adding IC&I waste to existing programs was felt to be unnecessary and

potentially confusing. It was also mentioned by some that the inclusion of IC&I waste would not be

consistent with other provinces. Some felt that there was not enough time being allocated to consider

the IC&I waste stream in addition to residential stream.

It should be noted that those respondents within the agricultural sector in particular, feel additional

and specific consultation is needed. These respondents feel that current voluntary programs, such as

empty commercial pesticide and fertilizer container programs are working, and as such, it would be

prudent not to interfere with these programs. They feel that agricultural plastics should be managed

through its own program because the collection infrastructure will vary significantly from that needed

for other PPP materials.

6.4.2 What role do you see municipalities playing in packaging and printed paper

program?

In total, 103 respondents provided comments. The role municipalities should play in a PPP program

tended to differ depending on the respondents sector or organization. Most respondents from the

municipal government sector indicated the role should be in terms of waste collection and public

education. These respondents felt funding would come from the EPR program, rather than taxes.

Respondents from the business/industry and industry associations sector indicated that municipalities

would be a service provider to the stewardship program. Some felt they should be given first right of

refusal to bid on services given their experience and extant infrastructure and programs.

Most within business/industry and industry associations indicated that in order for the stewardship

program to be effective, the stewards must be free to choose the lowest cost approach while meeting

the guideline set out in the program. It is felt that producers under the regulation will have the legal

obligation to track and account for diversion according to standards set by the province and therefore

must have the ability to set contractual terms with municipalities and other service providers.

Several respondents across sectors identified the need to clarify the municipal roles in an EPR program

at the outset as not doing so in other jurisdictions has created a lot of frustration and confusion.


Page 79

6.4.3 Do you have any additional comments or suggestions regarding packaging

and printed paper in Alberta?

In total, 89 respondents provided comments related to PPP in Alberta. The most frequent comment

themes related to the timeframes being too short, the need for harmonization with other provinces,

the need for clarity around how the program will be administered, and discussion around both the

pro’s and con’s of including IC&I waste within the program. There were also lengthy submissions

independent to the workbook outlining reasons for exemptions related to magazines and reusable

containers (i.e., storage bags and containers washed and reused by consumers multiple times before

disposal). Several industry associations and businesses raised concerns about products ending up

under the umbrella of two programs.

Several industry associations and business/industry participants provided very detailed accounts of

how the process should work, and experiences encountered in other provinces. There were also

concerns expressed by several participants that an EPR program will actually cause an increase in the

cost to consumers since other jurisdictions have not realized any offsetting reduction in taxes due to

EPR program being in place. Further, some participants feel the existing system is effective and

efficient making the move to EPR unnecessary.

Several large corporations and industry associations provided lengthy discussion of how the GoA

should implement the EPR program and would like to meet face to face to explain how it should be

done; they have experienced the challenges, successes and failures with EPR program implementation

in other jurisdictions.

Additional clarification and consultation required

� Clarity required on who is responsible for the packaging, is it the product producer, or the

package maker? For example is it the package maker or the electronics manufacturer who pays

for the package used to package that product?

� Concerns regarding how certain HHW containers are dealt with in an EPR program, since

certain containers may fall under both the HHW program and the PPP program, depending on

whether they are empty or not; concerns about the potential for being charged within both

programs, as well as the potential confusion this will create to the public when they are looking

to recycle these containers.

� Clarity required on the reporting requirements, as experiences with reporting in other

jurisdictions have been very onerous.

� Further consultation desired; need to know the details of the regulations.

� Concerns whether capacity is available to handle the new materials being designated.

� Desire for more detailed analysis, specifically a benefit cost analysis; respondents indicate that

evidence from other jurisdictions suggests the EPR model does not improve upon existing


Page 80

systems and that there has been no offsetting reduction in municipal taxation (therefore

consumers effectively are paying more for recycling).

Suggestions regarding program inclusions and exclusions

� Fees should differentiate between renewable and non-renewable packaging; fiber should be

treated differently than non-fiber.

� Exemption of fees through an EPR program for products that are retained by consumers and

do not enter the waste stream (e.g., magazines and photo paper).

� Split views on the inclusion/exclusion of agricultural plastics and IC&I.

� Exclusion of “durable packaging” (i.e., containers and packaging designed to be, or sold as,

“single-use” products) desired.

� Inclusion of polystyrene (e.g., StyrofoamTM) desired, with some suggestion that it be banned

from landfills.

Importance of program harmonization

� Review of best-practices and programs in other jurisdictions should be examined in terms of

their failures and successes.

� Concerns related to the EPR programs being introduced simultaneously in several provinces

and the significant challenges they cause if not harmonized across jurisdictions.

� Packaging from global companies is seldom designed for a single market, therefore it is

unrealistic to expect producers to design packaging for individual recycling streams.

� Consider using the calculator that was used in Manitoba, Ontario and British Columbia for the

portion of producer contribution to the designated material program.


Page 81

7 DESIGNATION OF HOUSEHOLD HAZARDOUS WASTE

7.1 Background

Alberta’s current Household Hazardous Waste (HHW) Program has been operating since 1988. It

ensures that unused household wastes that are corrosive, toxic, flammable or reactive are managed in

a manner that protects human health and Alberta’s environment. In 2011/12, over 100 communities

participated in the program, collecting about 750 tonnes of HHW. The amount of material collected

under the program increases each year.

The program is voluntary and is paid for by municipal and provincial tax dollars. Participating

municipalities pay for the collection of HHW from their residents and pay registered brokers to

remove the material. The Government of Alberta pays for program administration, material

consolidation, transportation from the brokers’ sites to the Swan Hills Treatment Centre, and material

destruction. The HHW program is currently managed by Alberta Recycling under contract with the

Government of Alberta.

Paint and paint containers have been managed under a provincially regulated stewardship program

since 2008. The program is managed by Alberta Recycling. There are linkages between the collection

and management of materials under the regulated paint program and the existing household

hazardous waste program.

All fluorescent lamps contain small quantities of mercury. Improper disposal or landfilling can cause

the mercury to be released into the atmosphere or leached into the surrounding soil or groundwater.

Implementing an EPR program for HHW and mercury containing lamps was identified as a 2015 target

in the Canadian Council of Ministers of the Environment’s 2009 Canada-wide Action Plan for Extended

Producer Responsibility, which all provinces and territories endorsed. British Columbia and Manitoba

have regulated EPR programs for HHW.



regulation changes:

1. Designating flammable liquids for a provincial stewardship program;

2. Designating pesticides for a provincial stewardship program;

3. Designating toxics for a provincial stewardship program;

4. Designating corrosives for a provincial stewardship program;

5. Designating physically hazardous products for a provincial stewardship program;


Page 82

6. Designating compact fluorescent lights and fluorescent tubes for a provincial stewardship

program;

7. Managing household hazardous waste through an extended producer responsibility program.

Details on the specific designation of household hazardous waste materials include:

a. Flammable Liquids: Products that display the flammable symbol and are liquids or aerosols.

Examples include methanol, mineral spirits, paint thinners and strippers, camping fuel and

kerosene.

b. Pesticides: Consumer pesticides that have the poison symbol, a Pest Control Product number

and the word “Domestic” on the label.

c. Toxics: Products that display the poison symbol and are a liquid or aerosol. Examples include

furniture stripper, automotive additives and tar and bug remover.

d. Corrosives: Products that display the corrosive symbol and are in a liquid, solid or aerosol

form. Examples include rust remover, grout or masonry cleaners, and pool and hot tub

cleaners.

e. Physically hazardous (non-refillable fuel gas cylinders): Products that display both the

flammable symbol and explosive symbol. Examples include camping cylinders (such as one-

pound propane cylinders) and butane cylinders.

f. Compact fluorescent lights (CFLs) – fluorescent light bulbs that are typically used to replace

traditional incandescent light bulbs.

g. Fluorescent tubes of different lengths (up to eight feet) or may also be in curved or circular

shapes.


Page 83

7.2.1 Designate flammable liquids, pesticides, toxics, corrosives, physically

hazardous cylinders, compact fluorescent lights and fluorescent tubes.

As illustrated in Figure 15, support was strong for inclusion of all types of HHW products, with more

than 80 per cent of respondents indicating they support the inclusion of these products.

FIGURE 15 - INCLUSION OF SPECIFIC HAZARDOUS PRODUCTS IN A PROVINCIAL A STEWARDSHIP PROGRAM


Tables 31 through 36 provide the sector and organization levels of support and opposition associated

with each type of hazardous material considered in the workbook. The patterns by sector and

organization are consistent across all the products. For example, more than 90 per cent of municipal

governments provided a ‘strongly support’ rating. Business and industry association results were more

dispersed.

4 59

19

64

2 410

16

67

4 48

16

69

3 410

18

66

2 410

17

67

2 510

20

64

0

20

40

60

80


Per c

en

t

Flammable liquids (n=174)Pesticides (n=174)Toxics (n=172)Corrosives (n=172)Physically hazardous products (n=170)Compact fluorescent lights/ fluorescent tubes (n=174)


Page 84

TABLE 30 - DESIGNATING FLAMMABLE LIQUIDS FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 75% 25%

TABLE 31 - DESIGNATING PESTICIDES FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 25% 75%

TABLE 32 - DESIGNATING TOXICS FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 25% 75%


Page 85

TABLE 33 - DESIGNATING CORROSIVES FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 50% 50%

TABLE 34 - DESIGNATING PHYSICALLY HAZARDOUS PRODUCTS FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 3 100%

TABLE 35 - DESIGNATING COMPACT FLUORESCENT LIGHTS AND FLUORESCENT TUBES FOR A PROVINCIAL STEWARDSHIP PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support








Other 4 25% 25% 50%


Page 86

7.2.3 Manage household hazardous wastes under an extended producer

responsibility program.

A large majority of respondents (81 per cent) indicated they support managing HHW through an EPR

program, with 57 per cent strongly supporting and 24 per cent somewhat supporting this program.

FIGURE 16 - MANAGING HOUSEHOLD HAZARDOUS WASTE THROUGH AN EXTENDED PRODUCER RESPONSIBILITY PROGRAM (N=171)


Table 30 shows the differences in support for an EPR program to manage HHW by sector or

organization. The strongest support is from government agencies, boards and commissions (78 per

cent strongly support), followed by the general public (74 per cent strongly support) and municipal

governments (68 per cent strongly support). There was mixed support from delegated administrative

organization sector.

TABLE 36 - MANAGING HOUSEHOLD HAZARDOUS WASTE THROUGH AN EXTENDED PRODUCER RESPONSIBILITY PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support







General public 19 5% 5% 5% 11% 74%

Other 4 25% 50% 25%

46

10

24

57

0

10

20

30

40

50

60


Pe

r ce

nt


Page 87


Respondents were asked to rate their degree of opposition or support to several regulatory changes

which are in support of designating HHW under an EPR program:

1. The proposed timeline of 12 months for submitting a stewardship program plan for household

hazardous waste;

2. The proposed timeline of 12 months (from the time a program stewardship plan is approved)

for implementing a household hazardous waste program.


plan for household hazardous waste

As illustrated in Figure 17, about two-thirds (67 per cent) of respondents support a proposed timeline

of 12 months for submitting a stewardship program plan for HHW (39 per cent strongly support, 28

per cent somewhat support), while 22 per cent are neutral and 11 per cent are opposed (six per cent

strongly opposed, five per cent somewhat opposed).


plan is approved) for implementing a household hazardous waste program

A similar breakdown occurred for the proposed timeline of 12 months for implementing a household

hazardous waste program (see Figure 17). About two-thirds (64 per cent) support the proposed

timeline (36 per cent strongly support, 28 per cent somewhat support), 22 per cent are neutral and 14

per cent are opposed (seven per cent strongly opposed, seven per cent somewhat opposed).

FIGURE 17 - SUPPORTING CHANGES

6 5

2228

39

7 7

2228

36

0

10

20

30

40

50


Per c

en

t

The proposed timeline of 12 months for submitting a stewardship program plan for household hazardous waste(n=172)The proposed timeline of 12 months (from the time a program stewardship plan is approved) for implementing ahousehold hazardous waste program (n=168)


Page 88

7.3.3 Sector/Organization findings

Tables 37 and 38 show the breakdown of responses by sector or organization. Industry associations

had the highest percentage of neutral or opposed responses to the proposed dates for both

statements. Municipal governments, government agencies, boards and commissions, as well as the

general public had the highest percentage indicating they strongly supported the proposed dates.

TABLE 37 - THE PROPOSED TIMELINE OF 12 MONTHS FOR SUBMITTING A STEWARDSHIP PROGRAM PLAN FOR HOUSEHOLD HAZARDOUS

WASTE

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support







General public 20 10% 15% 15% 60%

Other 4 25% 75%

TABLE 38 - THE PROPOSED TIMELINE OF 12 MONTHS (FROM THE TIME A PROGRAM STEWARDSHIP PLAN IS APPROVED) FOR

IMPLEMENTING A HOUSEHOLD HAZARDOUS WASTE PROGRAM

Sector/Organization

Base

size

(n=)

Strongly

oppose

Somewhat

oppose Neutral

Somewhat

support

Strongly

support







General public 20 10% 5% 15% 15% 55%

Other 3 33% 67%


Page 89

7.4 Comments










There were two open-ended questions related to HHW in the workbook.

� What role do you see municipalities playing in a household hazardous waste program?

� Do you have any additional comments or suggestions on household hazardous waste

management in Alberta?

7.4.1 What role do you see municipalities playing in a household hazardous waste

program?

A total of 89 respondents answered the first discussion question. Most comments indicated

municipalities are best positioned to perform the roles of collection, distribution to recycling centres

and public education. The main argument being that they currently perform these roles now. There

was also the view held that municipalities need to be an integral part of any strategy development

with regard to household hazardous waste. Simplicity for the public to access household hazardous

waste collection and not adding to the cost are seen as essential to ensure hazardous items are not

discarded in an inappropriate manner.

Within the business sector there were mixed views on the roles of municipalities. Some felt

municipalities should carry on with collection, distribution and education; while others felt

municipalities would not carry out the collection and distribution tasks as efficiently as the private or

not for profit sectors. Business and industry associations felt very strongly that there needs to be

accountability and open financial reporting of performance.

Some respondents felt that an EPR stakeholder body would regard municipalities as a potential

contractor for collection, distribution and public education and would only be used when they are the

most cost effective provider of these services.


Page 90

Continuing the municipal role of collection, storage and transporting

� Municipalities should continue to perform their current role since they are already set up for

collection and transporting.

� Changes could include curb side pickup, better storage facilities, inclusion of a wider range of

HHW products and more consistency across municipalities.

� Regardless of which entity is responsible for collection, storage and transporting, there is a

need for clear accountability, including financial audits.

Collection, storage and transporting led by industry stewards

� Suggestions for a model in which the HHW collection details are laid out in a comprehensive

plan, led by industry stewards who are responsible for meeting the requirements of the

regulation. This could involve municipalities as partners maintaining the collection points.

� Collection, storage and transport should be industry led to improve efficiency. A counter-point

to this suggested by several respondents is that industry should not be placed in charge of

HHW collection as they cannot be trusted to serve the best interests of the public. There was

concern around enforcement of guidelines if HHW is managed by industry.

� Within the structure of an EPR program, municipal roles and their ability to recover costs

should be commensurate with their share of the program responsibility. Therefore accounting

for program costs will be important.

Harmonization of programs is important

� Harmonization across all Canadian jurisdictions is important to industry association

respondents to ensure the greatest economies of scale, efficiencies and convenience for

consumers. This would include harmonization of programs, materials collected, roles and

responsibilities and definitions.

Make it easy and let people know about the programs

� Need to ensure access is easy, and at no extra cost to the public. If access is not easy and

cheap, hazardous items may not get disposed of properly.

� Public education is a major role of municipalities. This includes making people aware of the

consequences of inappropriate disposal, as well as the opportunities for disposal of HHW

products.

� Educate the public regarding alternative, less hazardous products.


Page 91

7.4.2 Do you have any additional comments or suggestions on household

hazardous waste management in Alberta?

A total of 65 respondents answered this question. Many of the respondents repeated or expanded on

what was said in the previous question.

While most of the support is for municipalities to continue with collection and transporting of HHW,

there were also those who felt that the program should be managed under an EPR program whereby

producers, brand managers and first importers take responsibility of the end-of-life management.

There was a great deal of discussion in the commentary related to what should and should not be

included. Some felt that programs in Manitoba and British Columbia should be used as the basis for

the definitions as these are founded on a science-based standard (CSA Standard). There were very

strong views expressed by associations indicating that 12 months is not enough time based on their

experience in other jurisdictions.

12 months is not enough time to implement the program

� Associations currently involved in implementing HHW programs in other jurisdictions were

adamant that 12 months is not enough time for implementation.

Items for inclusion and definitions of household hazardous waste is key to success

� Need to include batteries, compressed gas cylinders, carbon monoxide detectors, and high

pressure sodium bulbs.

� ‘Down the drain’ products should not be included since these products are meant to go down

the drain and completely used by the consumer; empty containers in general should not be

included.

� Mixed opinions on the need to include IC&I products; several commented they should be

included and several were opposed.

� Mixed views on whether ‘product categories’ should be used to define what the province is

including, rather than ‘specific products’; some felt the definitions should be very specific,

other felt this would be limiting.

� Need for more consultation on which products should be included.

Need for harmonization across jurisdictions

� Consider British Columbia and Manitoba programs as basis for HHW definition; use of science-

based standards (CSA Standard).


Page 92

Current system is working, not confident producers will do an effective job

� New EPR system should not increase the administrative burden on municipalities; current HHW

program is working without administrative burden.

� Need to ensure there is no added cost to the consumer or the program will not be successful.

� Implement review of program changes to ensure they have been effective; importance of

ongoing monitoring and evaluation.

Combine paint and HHW

� Existing paint and HHW programs could be combined in one program.

Education

� Need for large scale education campaign once program is implemented; build awareness of

options for managing HHW products.


Page 93

8 FINAL THOUGHTS

Section 8 in the consultation workbook consisted of an open-ended question to capture any additional

feedback. There was also an assessment of the workbook and consultation process.

8.1 Feedback on the Consultation Process

Eighty-two per cent of participants agreed (34 per cent strongly agreed, 48 per cent somewhat

agreed) that the document provided sufficient information to allow them to respond to the questions,

and 80 per cent agreed (44 per cent strongly agreed, 35 per cent somewhat agreed) they were

comfortable with the process for gathering input.

FIGURE 18 - ASSESSMENT OF WORKBOOK AND PROCESS


As seen in Table 39, industry associations show the greatest variation in levels of agreement that the

document provided sufficient information to allow response to the questions (although the majority

did still agree there were fewer who strongly agreed and more neutral).

37 7

48

34

37

10

35

44

0

10

20

30

40

50

60

Strongly disagree Somewhat disagree Neutral Somewhat agree Strongly agree

Per c

en

t

This document provided sufficient information to allow you to respond to the questions (n=189)

You were comfortable with the process for gathering your input (n=189)


Page 94

TABLE 39 - THIS DOCUMENT PROVIDED SUFFICIENT INFORMATION TO ALLOW YOU TO RESPOND TO THE QUESTIONS

Sector/Organization

Base

size

(n=)

Strongly

disagree

Somewhat

disagree Neutral

Somewhat

agree

Strongly

agree








Other 5 40% 60%

The process for gathering input (on-line workbook) received similar ratings as the content question.

Industry associations were again least in agreement with the process, although the majority did still

agree that the process was a comfortable method for gathering input (see Table 40).

TABLE 40 - YOU WERE COMFORTABLE WITH THE PROCESS FOR GATHERING YOUR INPUT

Sector/Organization

Base

size

(n=)

Strongly

disagree

Somewhat

disagree Neutral

Somewhat

agree

Strongly

agree








Other 4 25% 75%

8.2 Comments











Page 95

There were two open-ended questions requesting respondents’ feedback at the end of the workbook.

� Do you have any further input you would like to provide on the proposed Designated Material

Recycling Regulation?

� Do you have any suggestions for improving the (consultation) process?

8.2.1 Do you have any further input you would like to provide on the proposed

Designated Material Recycling Regulation?

There was a great deal of support for the GoA undertaking the Designated Material Recycling

Regulation initiative. While some encourage the government to keep moving this forward, others

mainly in the business and industry association sectors advocated the need for further consultation, in

particular once draft regulations are available. A major issue with municipalities relates to the need to

include IC&I and construction and demolition (C&D) within the regulation. Disposal of agricultural

plastics are a major issue within rural areas. Again, many respondents indicated the need to examine

what other provinces have done and ensure there is harmonization across jurisdictions. There were a

few participants concerned about moving to an EPR program claiming the existing system is working.

However, most comments did support the move to an EPR program. Many of the comments in this

section simply reiterated earlier comments, such as timelines being too short, the need for monitoring

and evaluation, and overall support for the changes.

Support shift from tax dollars to EPR

� Industry (stewards, retailers, manufacturers, importers) should decide how programs and

products are managed.

� EPR should be implemented in all proposed and current programs under the proposed

regulation; running different programs under different philosophical notions will confuse and

unnecessarily burden stewards.

� Producers should be given the freedom to decide whether to work individually or collectively

The need to include C&D and IC&I in the regulation

� Strong support to include IC&I and C&D within the regulation changes.

� A lot of industrial waste is not covered under the proposed changes. The GoA should be

putting in place measures to make the IC&I sector more accountable for the waste they

produce.

Impact on industry, business and consumers

� Concern that EPR program will place risks on the businesses they represent, creating added

cost to consumers, confusion and complexity.

� Need to address the costs industry will have to assume under an EPR program.


Page 96

� Concern that “burying” EOL fees may make Alberta products non-competitive; visible fees

enable cross-border competition in jurisdictions where end-of-life (EOL) fees are not levied.

� Concern regarding increased costs to consumers; no evidence of off-setting of municipal taxes

in other jurisdictions where EPR programs have been implemented, effectively causing an

increase in cost to the consumer.

� Concern over a lack of baseline data; needed to effectively monitor program success and

effectiveness.

Timelines are too short

� Concern that inadequate timelines could result in numerous changes being required after

implementation resulting in confusion and added cost (as experienced in other jurisdictions).

More consultation needed

� Concern that draft regulations were not part of the consultation.

� Desire for face to face meetings in medium sized groups to discuss the experiences and

challenges learned from other EPR programs.

More details on how programs will work together

� Need for consistency of funding rules.

� Need to specify how an EPR program will impact the role of municipalities and already

established programs; municipalities have invested in infrastructure to handle waste materials

and want to see that the infrastructure is put to good use.

� Need to consider how these different programs will work together and what will make most

sense from the point of view of the program user and the program administrator (e.g., if anti-

freeze containers fall under the used oil program, and left over anti-freeze under the

household hazardous waste program, will residents have to visit two separate collection sites?;

will collection sites have to deal with two different program stewardship programs?)

8.2.2 Do you have any suggestions for improving the consultation process?

Only 14 participants had comments related to improving the process. The majority identified that the

workbook generated additional questions for them, especially around the logistics of implementation

and how programs will work together.

Several respondents indicated they had a great deal of experience in EPRs in other jurisdictions and

would appreciate a face-to-face meeting with the GoA to discuss what they have learned.

One association indicated that their members would be significantly disadvantaged and made an

extensive argument for why they should be exempt.


Page 97

There were also several participants who felt it would be beneficial for them to be able to print out

the content of their workbook submission.


Page 98

9 APPENDIX 1

9.1 Invitation to Stakeholders

October 16, 2013

TO: Stakeholders

FROM: Shannon Flint, Assistant Deputy Minister, Policy Division, Alberta Environment and Sustainable

Resource Development.

SUBJECT: Consultation Notice for Proposed Designated Materials Recycling Regulation

Alberta Environment and Sustainable Resource Development is requesting your input on proposed

updates to the province’s regulatory framework for recycling designated materials. The proposed

changes are intended to reduce municipal solid waste in Alberta, streamline Alberta’s regulatory

framework, and provide options to shift end-of-life management costs from taxpayers to producers

and product users. The changes will advance initiatives in Alberta’s Too Good to Waste strategy.

We would like to hear your thoughts on the proposed changes. Consultation is open to everyone so

feel free to share this notice with others. No decisions have been made and your input will be a

valuable piece of the decision-making process.

More information on the proposed changes and the consultation process is available at

http://esrd.alberta.ca/waste/default.aspx. The consultation will run from October 16 until December

13, 2013. During this time, an online workbook will be available at this webpage for your review and

input. This workbook will be our primary avenue for gathering feedback from stakeholders.

Department staff are available to respond to questions and to schedule meetings upon request. They

can be reached by email at [email protected] or by phone at 780-644-5091 (for

toll free access anywhere in Alberta, first dial 310-0000).

Thank you,

Shannon Flint


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10 APPENDIX 2

10.1 Summary of Written Submissions

Nine individual written submissions were received as part of the consultation process on the proposed

Designated Materials Recycling Regulation. Of these submissions, seven were from the industry,

business and industry association sectors, one represented municipal government, and one was from

a non-government/non-profit organization.

The key points from each stakeholder’s submission are provided here, by workbook area. Each bullet

point represents a key point from a submission.

10.1.1 Consolidation of Existing Regulation

Avoid unnecessary costs, confusion and complexity

� Enabling producer responsibility in a consolidated regulation in the manner proposed, by being

locked arbitrarily to relationships with DAOs in which producers have little influence, is at odds

with producers having the necessary autonomy, flexibility and decision-making authority to

effectively and efficiently manage an end-of-life stewardship program. Discharging obligations

individually or through a collective will have the added advantage of enhancing opportunities

for innovation.

Harmonize and align requirements under a national program

� Consolidating the existing regulations is a step in the right direction, but a national approach to

address recycling designated materials would assist with alleviating business challenges with

monitoring a number of programs for the same material with slightly different nuances and

requirements, including reporting. The GoA should advocate for this harmonized approach.

� While it is important to harmonize programs and principles, it is equally important to consider

and adopt best practices in programs in place in the various jurisdictions that actually result in

efficient program operation.

Recognize and support sector-specific management plans

� It is important to recognize other proactive environmental management systems dealing with

durable goods with high value, such as the End of Life Vehicle Management System, and to

work with applicable groups to move initiatives of this type forward.


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Product lists should be flexible rather than prescriptive

� Materials and products are constantly evolving. To ensure that products continue to enter the

recycling stream, regulated lists should not be overly prescriptive.

10.1.2 Electronics Recycling Program Expansion

The decision to add small appliances is premature

� There is insufficient information as to current small appliance recycling rates in Alberta and

other jurisdictions to warrant a decision to add these appliances to the program and,

accordingly, it is unclear how program impact could be measured. Given the program goal of

increasing diversion of products away from landfills, and the very low current rates of these

appliances entering landfills (about half of one per cent), it is not clear why small appliances

have been proposed for an enhanced program.

Harmonize the product list with neighbouring jurisdictions

� Dealing with a variety of materials can be very challenging when their definitions and inclusion

status are not clear, so harmonization efforts are needed in PPP programs.

Clearly identify products that should be excluded

� Factory-installed and dealer-installed automotive electronic components should be excluded

from this program expansion because there is already a long-standing recycling infrastructure

that captures these from a vehicle at its end of life.

Set per unit fees on cost

� Pre-setting fees at $5 or less per unit does not reflect the cost of managing and recycling the

material. In Ontario, for example, keeping costs artificially low has resulted in financial

instability and large deficits.

10.1.3 Enabling of Extended Producer Responsibility

Provide greater clarity on governance to ensure a level playing field which leads to better outcomes

� The workbook does not state clearly enough what is being proposed in terms of whether any

collective will be separate from a DAO, nor which stakeholders will make up the boards that

decide who is consulted, who is represented and who makes decisions. Both human and

financial capital is invested in the existing infrastructure and must be protected, and any

funding formulas must be transparent so that there is a level playing field for all parties.


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� Transferring both physical and financial responsibility to producers, along with clear

accountability, will identify opportunities for cost reduction, collaborative education

campaigns, regional solutions, and innovation.

� The level of control that producers have over program design and operation must be

proportionate to the level of funding provided by industry.

� Mandating a producer to join any specific organization is contrary to the notion of EPR; it

should be the producer’s responsibility to decide how best to take responsibility for their

materials, and doing so may be provide similar but better results than with another established

program.

� Producers should be able to meet their regulatory obligations in a manner that makes best

sense for them where they can fine-tune their programs to provide benefits to both

government and to consumers, rather than being obligated to join a program that will lead to

duplicate effort; the key requirement should be the producer’s ability to meet the regulatory

requirements.

EPR is one of many management tools and should not be the default approach

� The Province should consult with each affected industry to determine the most appropriate

and cost effective approach for managing materials; concern was expressed that the Province

is focusing on a move to EPR only for future program development.

� The proposals made by government should be limited to key elements focused on outcomes of

running a program.

� Many of the proposed requirements should be optional or applicable in certain circumstances

only; further, the proposed regulatory requirements are too comprehensive and will

discourage the development of individual EPR programs in favour of joining large cooperatives.

Programs should be multi-stakeholder

� Governance by multi-stakeholders rather than solely industry-based boards will help ensure

needs of the environment, municipalities and consumers are met effectively.

The Province should obtain benchmark data to ensure balance in the waste/recycling framework

� The Province’s role should be to set the framework across a wide range of waste streams but

to recognize that “one size does not fit all”. It is not necessary for the Province to micro-

manage programs (“enable EPR, don’t run it”).

� The Province needs good data about the source and disposition of many types of materials;

then it will be possible to set actions and diversion targets within an EPR arrangement.


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Include enforcement

� EPR programs must include enforceable environment and service quality standards to ensure

targets for waste reduction are met.

Reporting requirements should be standardized

� Expecting producers to submit program plans outlining how they will meet requirements is

reasonable; the program requirements should be harmonized across jurisdictions to reduce

administrative load for reports by producers running programs across several provinces or

Canada-wide.

Include affected parties in consultation

� Organizations such as recycling mills, converters and MRF operators, while not stewards as

such, are affected by programs and should be consulted.

Include small and remote communities

� EPR programs must be accessible to all communities.

10.1.4 Designation of Household Hazardous Waste

Align with proposed or existing plans in other provinces

� Avoid unique requirements that add administrative burden and cost by aligning Alberta’s

definitions and exclusions with those of other provinces.

10.1.5 Environmental Fees

Fees should be set by producers and should be visible across the supply chain; consumer education

about fees is required

� Environmental fees should be removed from regulation and be the purview of stewardship

organizations. For producers to effectively manage ongoing program costs, the stewardship

organization must be able to set product fees without requiring Director approval. Flexibility is

essential in order to respond to changing market conditions and fluctuating costs (i.e.,

transportation, processing, materials, product type and composition).

� Transparency of fees for end of life management was stated as an important tool in educating

the public about stewardship. Visible fees enable businesses to compete across provincial and

state borders; hidden fees create disparity between jurisdictions and can require distributors

to create separate sets of stock-piling units, an expensive but non-productive business practice.


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Hidden fees were viewed as effectively increasing product cost and creating a new hidden tax.

Consumers and all parties in the supply chain will better understand product fees and

stewardship goals if fees are visible.

� It is important to be able to identify specific costs in each province at the business to business

level, especially when stewardship costs are not aligned between provinces. Adding costs at

each point in the supply chain may lead to additional margins at each of these points, leading

to higher retail prices. The Province should support open communication and consumer

education to consumers on the costs of recycling included in the product price.

� Environmental fees should include an environmental cost accounting for human health,

environmental services provided by natural areas lost to industrial growth, and

intergenerational costs for wasting non-renewable resources.

Keep environmental fees; use them to offset uncertainty costs, public awareness education, and best

practice incentives

� There is a rationale for retaining environmental fees even under a full EPR model, to offset

free-rider behaviours, pricing risks due to volatility in commodity prices, and costs for

government oversight of the process, auditing, and dispute management.

� Fees could also be directed to local industries as incentives for processing recycled materials,

and for education and awareness efforts.

� Provide incentives for municipal governments to embrace best practices in waste reduction

and management (e.g., regional recovery facilities).

Fee methodology requires consultation

� Consultation on fee structuring must occur prior to program approval; fees must be

transparent and be reviewed regularly by all stakeholders.

10.1.6 Used Oil Materials Recycling Program: Environmental Fees and Expansion

Base the per unit fees on cost

� The proposed fee increase to 10-cents per litre of container size is appropriate only if it reflects

the costs of managing and recycling.

The rationale for adding windshield washer containers is unfounded

� Windshield washer containers should remain part of curbside recycling; adding them to the

expanded program will create an unnecessary misalignment with other jurisdictions where

they are not included; further consultation on this proposal is needed.

� Only antifreeze containers should be added at this time.


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10.1.7 Designation of Packaging and Printed Paper

Consider multiple diversion tools while keeping the focus on residential paper and packaging

� The focus of an EPR program should be on residentially-generated product. A number of tools

to support diversion in the IC&I sector can be quite effective, such as landfill bans, surcharges,

and tracking of generator waste data (rather than waste hauler data from Statistics Canada-

WMIS). Accordingly, two policies are considered appropriate.

� Other tools recommended for Alberta included imposing an immediate ban on paper grocery

bags and developing composting infrastructure.

Clarify and communicate cost realities with respect to municipal activities and tax use

� A broader philosophical question was raised querying whether it should be the role of

municipalities to participate in what can be viewed as an industrial activity, and accordingly

whether they should build, maintain and operate the infrastructure associated with, in

particular, residential PPP recycling. To do so, it was suggested that municipalities compete on

the same terms as private sector service providers. The British Columbia program was cited as

a good model for those participating in collecting and processing.

� Consistent and clear commercial arrangements with municipalities will provide predictability

for producers and overcome limited progress to date in recycling rates.

� The program must be transparent and competitive to ensure that fair and accurate costs are

passed on in product pricing.

� The designation of PPP to an EPR framework must be defined and communicated as a cost-

shifting exercise, namely that it simply moves the cost for the consumer to point of purchase

from their municipal tax payment. Concern was expressed that municipal taxpayers will not see

a reduction in their waste collection fees as a result of this cost-shifting (i.e., it is not cost-

neutral).

Consult on and define program principles

� It was noted that without an actual regulation on which to comment, there is now an

opportunity to develop principles for an expanded program. Examples were given relating to

leveraging competitive markets, defining producers and the role of municipalities,

distinguishing between residential and IC&I programs, dealing with durable goods, preventing

cross-subsidization across products, harmonizing material programs across the province, and

the necessary monitoring and enforcement role by the GoA.

� A flexible and broad definition of “diversion” is required that focuses on outcomes rather than

a prescribed process. Systems thinking is evolving as it pertains to packaging design (e.g., food)

and waste diversion. Factors over and above the “3Rs” can and should be considered, including


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design, materials, consumer use, contamination levels, distances and volumes, and whether a

rural or urban community is involved.

� A comprehensive diversion hierarchy that also includes composting and energy recovery

should be allowed so as to reduce environmental impact and return net environmental benefit.

Distinguish IC&I and residential waste policies; further consultation on alternatives is requested

� Consider excluding IC&I materials as designated materials under a PPP program since the

marketplace, collection sites, and overall waste streams are substantially different. Waste

generators have the ability to reduce waste through purchasing policies and on-site waste

diversion on an individual basis, working outside of municipal infrastructure. These generators

also have an incentive to reduce costs through waste reduction, which should inform policy for

the IC&I sector. The GoA should undertake a data gathering process to understand diversion

performance across the IC&I sector.

� Exclusion of IC&I wastes will prevent duplication of costs already borne by consumers and

industry.

� Consider excluding agricultural paper if agricultural plastics are being excluded.

Distinguish policies and regulation pertaining to paper that is itself the product vs. paper that is

packaging

� Magazines are products that often have shelf lives of many years (i.e., they have a high “kept

rate”; unlike packaging, magazines are not discarded instantly.) These unique characteristics

require specific regulatory treatment and program design to address the following: protection

of magazines as per the Canadian Charter of Rights and Freedoms such that editorial voice is

not silenced; ownership of indigenous tonnage vs. tonnage moving into Alberta must be clear

such that the small provincial industry is not placed at a competitive disadvantage; provision by

the Province for fee discounts on magazines printed on environmentally friendly paper; a dual-

stream collection system that will prevent contamination of high quality printed paper from

magazines; embedding of a true EPR system that does not require arduous and time-

consuming reporting and administration that will create an undue imposition; provision for

board representation from the printed paper sector; and creation of an industry advisory

committee.

Align definitions and sector calculators across provinces

� To reduce administrative burden, allow the use of tools such as the auto blue box calculator

already approved for reporting materials in Ontario, Quebec, Manitoba and British Columbia.

Clarify terminology

� It is not necessary to specify “cardboard”; “paper” should be considered sufficient.


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� Expand the definition of “service packaging” to refer to “packaging applied at the point of sale

for delivery of goods by the consumer”.

Do not pursue measures to increase recycled content

� This effort is not recommended since most boxes and cartons made in Canada are already 100

per cent recycled content.


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11 APPENDIX 3

11.1 Sector/Organization Breakdown of Workbook Responses

Sector/Organization

Total Workbooks

Received

Municipal Government 31

Federal or Provincial Government 0

Business/ Industry 75

Industry Associations 29

Delegated Administrative Organizations 3

Government Agency/ Board/ Commission 8

Non-Government/ Non-Profit Organizations 12

General public 21

Other (e.g., Education, Consultant) 8

Unspecified 15

Total 202

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