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The EPR Trilogy The EPR Trilogy ©2012 Nancy Gorrell Together At Last: Extended Producer Responsibility (EPR) and Total Recycling Total Recovery for Reuse, Recycling, and Composting: How to Make It So Extended Producer Responsibility in British Columbia – A Work at Risk These articles were written individually for publication elsewhere and are collected here pre-publication for distribution to attendees at the Northern California Recycling Association’s Recycling Update XVII, March 27, 2012. They are presented in the order written. The EPR Trilogy, Urban Ore, for NCRA’s Recycling Update March 27, 2012 1 ©2012 Nancy Gorrell©2012 The authors and artist retain their copyrights. Booklet ©2012 Urban Ore, Inc. 900 Murray St., Berkeley, CA 94710 http://urbanore.com No part of this publication may be reproduced without written permission from the appropriate copyright owner. 2 The EPR Trilogy, Urban Ore, for NCRA’s Recycling Update March 27, 2012 Together At Last: Extended Producer Responsibility (EPR) and Total Recycling Daniel Knapp, Ph.D. years ago developed a rhetoric that The CPSC Webinar focused on just assumed recycling was in the way one commodity type: batteries. The and had to be set aside for EPR to speakers were actually part of the EPR versus Total Recycling. work. This rhetoric often resorted to battery reclamation supply chain in Sometime in the cold wet spring sloganeering: recycling was “so last various parts of California. My big of 2011, NCRA President Arthur century,” recycling “enables wasting.” takeaway from a day of listening: Boone set up what he hoped would They said EPR, pursued correctly, as EPR ideas are being tested and be a stirring and member-pleasing made recycling outmoded and refined in actual practice, reality is debate between opponents on the unnecessary, because products would forcing EPR and total recycling back EPR issue. He allotted one hour simply go back to their makers. together. They are complementary, of NCRA’s agenda to thrashing out not opposed. Both are necessary. the differences. He invited me to to But as we came closer to the May 19 represent the Total Recycling side. meeting date, the issues morphed or No one could be found to represent evaporated. the “purist” EPR position at our I started by reviewing my files and meeting. catching up on the sometimes One event brought matters to a head sizzling online debate over EPR. for me: I attended an all-day Webinar With no opponent to debate and The audience online was the more sponsored by the California Product the deadline approaching, I decided than 1,000 participants in a listserve Stewardship Council (CPSC). Heidi to lay out the experiential basis for operated by the GrassRoots Recycling Sanborn was the very able master reconciliation and agreement on next Network, or GRRN. The listserve is of ceremonies for the nine or so steps. GreenYes.com. Although I support speakers that gave us a grounded and and believe strongly in producer factual picture of how EPR is actually I came up with six arguments to responsibility, I’ve argued strenuously working. support the happy conclusion that for Total Recycling in a lot of these Total Recycling and EPR are essential arguments, which can go on for days. And how it is working is not like the and complimentary approaches to EPR Framework says it should be attaining Zero Waste to landfill and I’m for EPR, always have been. But working. It needs recycling facilities to incineration. Here they are, somewhat the people who grabbed the EPR succeed at all. revised in the ensuing months: brand and ran with it about ten 1. FORMER OPPONENTS ARE Daniel Knapp is President of Urban Ore, Inc. This report was originally prepared for presentation to the Northern California Recycling Association GETTING TOGETHER. meeting May 19, 2011, by Daniel Knapp, Ph.D. and CEO, Urban Ore, Inc. This version was published in NCRA News, the organization’s online newsletter. It Helen Spiegelman of the Product was revised slightly a few days later and distributed to an invitation-only EPR/ Policy Institute and I have debated Total Recycling Planning Group meeting, which took place June 4 and 5, 2011, both sides of the EPR issue for years at Avrom Systems’ conference center just outside Springfield, Illinois on the GreenYes listserve. Others Illustrations by Nancy Gorrell. This version of the article ©2012 Daniel Knapp. often joined in. These discussions The EPR Trilogy, Urban Ore, for NCRA’s Recycling Update March 27, 2012 3 erupted spontaneously, usually stimulated by some event or other that we could use as a launching point. They could be contentious, but more recently, Helen and I have been emailing back and forth in tones of reconciliation and mutual respect. Helen seems as dismayed as I am about some of the ways EPR is being implemented. Besides writing some very kind words about Urban Ore as a reuse business, in one of her responses Helen praised the Institute for Local Self-Reliance (ILSR) and Urban Ore for defending EPR from ©2012 Nancy Gorrell©2012 the “Giants of Garbage” who want to “highjack” EPR commodities to feed new publicly-owned transfer facility. This finding also validates the landfills and incinerators. A faxed spreadsheet from Tedd design approach used by Gary Liss shows the top three contributors to and Associates, Rick Anthony and 2. EPR NEEDS A NEW this sudden jump in collection. The Associates, the Institute for Local Self- GENERATION OF TOTAL transfer station accounts for 3,065 Reliance, Urban Ore Development RECYCLING FACILITIES WITH pounds in 2009, more than nine Associates, and county staff when PURPOSE-BUILT SPACES FOR times the contribution of the next together we created the Del Norte HANDLING EPR-COLLECTED two collectors, large stores that sell conceptual site plan for the engineers COMMODITIES. the batteries. The Product Policy and builders to follow. Urban Ore’s Institute’s Framework for EPR would design practice for more than a Batteries are one commodity whose lead one to expect the reverse, as in decade has been to provide for final disposal just about all EPR reverse logistics, which it champions. a substantial area and at least programs are designed to control. But that is not what is happening. one purpose-built building on the transfer station site dedicated to A very important speaker was Tedd Incidentally, the in-store takeback handling any and all regulated Ward, who with Kevin Hendrick (VP program was funded by a grant materials. of CPSC) manages the regional from CalRecycles, the new agency recycling and waste transfer station that in 2009 replaced the California 3. THE LIST OF MATERIALS in Del Norte County, California. This Integrated Waste Management Board. HANDLED BY A VERY is a rural county six hours by road Since the county population is small, COMPREHENSIVE EPR PROGRAM from San Francisco, so it is distant the retailer takeback program has IN CANADA IS ABOUT THE SAME from export markets. Nevertheless, achieved very high participation by AS THE LIST OF MATERIALS the county has has great success in businesses selling batteries, so it is HANDLED BY ZERO-WASTE waste reduction, having exceeded the a good case study of the emerging TRANSFER STATIONS IN statewide 50% “diversion” mandate a industry. CALIFORNIA DESIGNED WITH A couple of years ago. SUBSTANTIAL PURPOSE-BUILT This finding verifies that a new REGULATED-MATERIALS AREA . Tedd Stated that the Del Norte generation of transfer stations is Transfer Station is the largest needed even with full EPR at the On May 16, 2011, Bill Sheehan of source of EPR-collected batteries retailer level. The reason a new Product Policy Institute forwarded a in Del Norte County, California, generation of transfer stations is summary written by Monica Kozmak despite the fact that most if not all needed is that the old ones built in of the regulated materials covered retailers in the county now have the 1980s to replace closing landfills by Vancouver, British Columbia’s take-back systems. He presented a are wearing out and were usually not actual EPR program, with commodity- graphic that shows battery reclamation designed to fit today’s best practices specific links. This list is a fairly at very low levels until 2008, when in reuse, recycling, and composting. complete snapshot of the universe they jumped tenfold. The increase Many lack a designated area where of EPR commodities circa 2011. Mr. roughly coincided with the opening of regulated materials may be collected, Sheehan endorsed British Columbia’s the “regulated materials area” at the sorted, and shipped to producers or program as “the most comprehensive, end-users. industry-supported Extended 4 The EPR Trilogy, Urban Ore, for NCRA’s Recycling Update March 27, 2012 Producer Responsibility approach in I believe that all of the above REQUIREMENTS, AND Canada”. Here is Ms. Kozmak’s list: commodities are currently SORTATION FUNDING ARE handled by and within the Del CRITICAL PROBLEMS THAT ARE “British Columbia also has takeback Norte Transfer Station regulated CURRENTLY HOLDING BACK programs for materials area. Some are dropped EPR’S FURTHER DEVELOPMENT. electronics http://www.env.gov. off at or near the purpose-built bc.ca/epd/recycling/electronics/ “household hazardous materials” Controlling the collection of targeted index.htm (like computers, TVs, building on the site, some are materials with mandates is just the first audio-visual equipment, cell phones, salvaged from the wasting area tip step. Next comes processing. In the batteries), floor and brought there for processing. EPR webinar I heard again and again paint, http://www.env.gov.bc.ca/ Customers pay a disposal service fee from different speakers representing epd/recycling/paint/index.htm , to enter the facility, and may also pay all levels of the battery supply chain pesticides, solvents, gasoline http:// additional commodity-specific fees that the space and funding to www.env.gov.bc.ca/epd/recycling/ in order to drop off certain regulated do the labor- and skill-intensive liquid/index.htm, items.
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