The RCA has developed positions and sent the following recent letters in an effort to promote waste reduction.

1) EPR Should Drive Design–for–Environment
EPR should encourage Design for Environment by sending the appropriate economic signals to the producer. Ideally, the product should bear its full life-cycle environmental costs.
Issues / Comments

• Flow-through or retail fees download costs onto the consumer, rather than encouraging redesign, and should therefore be avoided.
• Advanced Disposal Fees must vary by product/material based on actual management costs in order to send accurate price signal.
• Producer Responsibility Organizations may be practical and effective management organizations, but tend to remove competition through uniform fees.

2) EPR Programs Must be Environmentally Sound
Programs should encourage environmentally-preferable products and management options.
Issues / Comments

• Although the least environmental impact is the desired outcome, in absence of definitive research, the 3 Rs hierarchy is assumed to be valid.
• Environmentally-sound decision-making can be encouraged by having an environmental conscience on the Producer Responsibility Organization.
• Program reviews should include environmental performance.

3) EPR Programs Need to be Designed to be Financially Sustainable
Financial sustainability must be inherent in any EPR program to provide long–term stability.
Issues / Comments

• It is critical that the responsibility and cost is borne by the generator and user, not the taxpayer.
• It is difficult to accurately predict funds required to deliver program up–front, which presents challenge in Advanced Disposal Fee (ADF) schemes. To account for this, the ADF must be adjustable, and based on the program’s current operating budget.
• Producer-pay programs provide the most elegant solution to financial sustainability, i.e., cost of program = payment from producer
• Sharing costs between the producer and other players leads to a distortion of the price signal. Some of industry’s desire to share costs comes from a confusion over respective roles in shared responsibility.
• However, industry rightly has a fear of escalating cost if they do not control the program’s management and infrastructure. It is important that producers be involved in program decisions in a meaningful way.

4) EPR Programming Must Provide a Level Playing Field
All producers must participate in an EPR program to provide equity.
Issues / Comments

• Level playing field can be effectively managed through backdrop legislation.
• Level playing field does not imply everyone pays the same, but rather that everyone participates, i.e., no free riders.
• Harmonization is important as is relates to level playing field, but not a goal in itself.
• Harmonization is more a priority for industry than government, as they are more affected by lack of harmonization. For this reason, any move towards harmonization must be driven by industry.
• Harmonization will never succeed as a desire to drive programs to the lowest common denominator. It also must never be an excuse for inaction.

5) Cross-Subsidization Should be Minimized in EPR Programs
To deliver accurate price signals, products need to bear their full environmental costs, but not support other products.
Issues / Comments

• Products and materials need to be separately tracked and accounted.
• Producers can work together on common collection/processing systems to produce efficiencies while maintaining product independence.
• Separate accounting can still be accomplished through composition surveys and material handling research.

6) An EPR Program Should Strive to be Socially Responsible
Community issues and local economy should be considered in programming decisions.
Issues / Comments

• Cost factors may conflict with social issues.
• Political involvement and monitoring is important to managing this element of EPR programs, as these are societal issues.

7) The Program Must be Performance Driven
Goals or mandates should be set by government in consultation with stakeholders.
Issues / Comments

• Public reporting requirements should include financial and environmental information, and all reported data must be transparent and verifiable.
• Performance standards must apply to voluntary as well as mandated programs, allowing for industry to implement effective voluntary programs, but preventing ineffective voluntary programs from being introduced as avoidance mechanisms.
• In order for performance standards to be effective, there need to be serious consequences for non–performance.

8) All EPR Programs Need to be Transparent and Inclusive
There should be full public access to program reporting. Multi-stakeholder input needs to be incorporated into program decision–making.
Issues / Comments

• Composition of the Producer Responsibility Organization (PRO) is an important element of this principle. PRO Boards should be multi–stakeholder, and allow for no balance of power, i.e., one representative from each stakeholder group.
• PRO composition should include Environmental Non–Government Organization and public seats.
• The PRO, and the funds it collects, should be arms–length from government to provide autonomy. This seems to be important to public confidence, and counters the impression of fees being “taxes”.
• The PRO should promote ongoing communications with stakeholders and the public. It also needs to be seen as responsive to issues.

Single-use bags of any type represent wasteful resource use. Recycling of plastic and paper bags is environmentally preferable to disposal, but is less preferable than reduction and reuse options. The Recycling Council of Alberta supports programs that encourage the use of durable, reusable options rather than single-use shopping bags. Examples of these programs include financial incentives / disincentives and supporting education campaigns.