This report is a response to MN 19-18 and MN19-6, which requested that:
1. City Administration bring to Council, by the end of the first quarter of 2020, a report outlining the environmental impact for Regina of the use of single-use plastics and without limiting the generality of the foregoing, of the use of plastic check-out bags, plastic straws and polystyrene drinking cups, food take-out containers and micro beads;
2. In preparation of the said report, City Administration consider measures being taken by other jurisdictions and consult with Regina residents and interested stakeholder [sic] with respect to this issue; and
3. That said report set out options for limiting the use of single-use plastics in the City, together with the City Administration’s recommendations.
In consideration of this issue, Administration conducted thorough jurisdictional scans, research, academic literature review and extensive engagement with interested stakeholders, including approximately 10,000 residents and businesses as well as industry experts. Further information is provided in appendices A-1, B-1, B-2, C-1, D-1, D-2 and D-3. Several options were reviewed and considered against the following objectives:
Objective 1: Maximize environmental benefit considering the net decrease in plastic waste and also considering the impacts associated with potential replacement products.
Objective 2: Maximize return on investment by ensuring that any financial investment in an option targets the greatest environmental return for the investment.
Objective 3: Minimize duplication of efforts between levels of government.
Objective 4: Minimize inconvenience and disruption to residents and businesses.
Objective 5: Respond to public concerns about single-use plastic pollution.
Financial Impact
There are no financial implications for the recommended option, Option 1, which focuses on delivering the initiatives outlined in Waste Plan Regina (WPR). Funding for these initiatives is considered in existing budgets and will be funded through the Solid Waste Reserve.
Environmental Impact
Overall, single-use plastics account for about one per cent of the residential waste in Regina. Approximately five per cent of all the recyclables collected through the City of Regina’s recycling programs are plastic.
Studies confirm that plastic checkout bags are commonly reused as garbage bags and for pet waste. Vancouver’s recent study shows that 63 per cent of checkout bags are reused in this way. Research also suggests that a checkout bag ban is typically accompanied by a significant increase in consumer purchases of pre-packaged plastic bags (i.e. garbage bags). Following California’s plastic bag ban, for example, consumer purchases of small, medium and large garbage bags rose by 120 per cent, 64 per cent and six per cent respectively. Since these pre-packaged plastic bags may contain more plastic than the thin checkout bags they are replacing, net reduction in plastic waste is very small.
Through continued focus on implementation of WPR (Option 1), the City can work toward reduction of all disposable products, including plastics. The initiatives in WPR are expected to move Regina closer to Council’s goal of 65 per cent diversion of residential waste. Moreover, WPR’s planned initiatives, such as the implementation of a residential food and yard waste program and development of reduction strategies for industrial, commercial, institutional, construction and demolition waste streams, will have a broader environmental impact since results will not be confined to reduction or elimination of only one product or type of product. The City of Regina’s considerable public outreach and education programming has already shifted towards prioritizing waste prevention and reduction over disposal solutions.
Policy/Strategic Impact
Advancing waste reduction initiatives aligns with the goals outlined in Waste Plan Regina. Additionally, the City of Regina is committed to priorities outlined in Design Regina: The Official Community Plan to promote conservation, environmental stewardship and sustainability through the adoption of leading practices in waste management.
Option 2: Mandatory bag fees. Introduce a bylaw which requires retailers and other businesses to charge a fee for bags (or other single-use items). Across Canada, retailer bag fees have been driven primarily by the private sector, and evidence suggests they are effective at curtailing customer demand for checkout bags. Large retailers, who have voluntarily instituted bag fees as a reduction strategy, report substantial reductions in checkout bag usage. This option would enforce a fee for bags. Bag fee bylaws are exceptionally rare in Canada (see Appendix D-2).
Evaluation against Objectives
Objective 1: This option would be expected to provide a more immediate improvement in reduction of single-use plastics entering the City’s waste stream but would not eliminate plastic bags in the landfill because the Fleet Street Landfill serves much of southern Saskatchewan. Since voluntary bag fees are already in place in many major retailers in Regina, moving from widespread voluntary bag fees to mandatory bag fees would offer minimal environmental benefit.
Objective 2: A checkout bag fee bylaw would result in costs to manage and enforce the fee while potentially offering little to no environmental return on investment. This option would require initial funding for an implementation phase, including communication and education for retailers and residents, and the development of regulatory and administrative processes to manage enforcement. Ongoing annual funding would be required for enforcement.
Objective 3: The provincial government is in the best position to legislate a bag fee that works for consumers and businesses. Deposit programs and eco fee programs are legislated by the provincial government through Extended Producer Responsibility/product stewardship legislation. Such programs have been demonstrated to work effectively (e.g. SARCAN beverage container deposit program). See Appendix A-1. In addition, a bag fee may be rendered redundant by federal restrictions in 2021.
Objective 4: A bag fee imposes an additional expense on residents, who may not understand where the revenue goes. This may appear to residents to be a “money grab”. It also results in an administrative burden for both the City of Regina and retailers. Mandatory fees can create administrative barriers, especially for small businesses. See Appendix C-1.
Objective 5: This option would take specific action to reduce single-use plastic pollution but would have less impact that a direct ban.
Option 3: Ban plastic checkout bags in Regina at the municipal level via a municipal bylaw with provisions for enforcement. A few larger municipalities and a number of smaller ones have implemented single-use plastic bans, largely targeted at checkout bags, with a smaller number focused on other single-use plastics such as straws. Recently, some larger retailers, such as Sobeys Inc., have eliminated the option of plastic checkout bags, encouraging reusable bags and offering paper bags for a fee as an alternative. This option would institute a ban on plastic check-out bags for retailers within the City of Regina, allowing for typical exemptions, largely for reasons of hygiene.
Evaluation against Objectives
Objective 1: As with Option 2, this option would provide a more immediate improvement in reduction of single-use plastics entering the City’s waste stream but would not eliminate plastic bags in the landfill because the Fleet Street Landfill serves much of southern Saskatchewan. Since voluntary bag bans are now being implemented by some large retailers, the benefits of a ban would be more limited than in the past. A ban may result in an environmentally undesirable switch from plastic checkout bags to paper bags, which may be more environmentally harmful when considered over their full life cycle.
Objective 2: This option would result in costs to manage and enforce a ban while potentially offering little to no environmental return on investment. This option would require initial funding for an implementation phase, including communication and education for retailers and residents and the development of regulatory and administrative processes to manage enforcement. Ongoing annual funding would be required for enforcement.
Objective 3: The federal government is in the best position to legislate a single-use plastic ban that works for consumers and businesses. The federal government has indicated its intention of implementing a national ban on harmful single-use plastics as early as 2021, potentially rendering a municipal ban redundant.
Objective 4: Bans implemented by individual municipalities can result in a patchwork of regulations that are challenging and costly for retailers to manage. Standardization of legislation across the country/province would prevent the development of an uncoordinated patchwork of different municipal bans spread around the province, each with its own definitions, rules, and exemptions. This can be confusing to customers and onerous for retailers that operate in multiple jurisdictions. (See Appendix C-1.)
In addition, a checkout bag ban may create economic barriers for small businesses by imposing the requirement to find acceptable alternatives. This additional cost and effort must be absorbed by the small business and/or passed on to the customer, whereas large businesses can more easily source low cost alternatives.
Objective 5: This option directly responds to the public concerns about single-use plastic pollution by directly addressing one source. 77 per cent of respondents in the City’s online survey support a ban on checkout bags. (See Appendices B-1 and B-2.)
Administration will develop a communications and engagement strategy to inform and educate citizens and support the implementation of any regulations resulting from the recommendations of this report.
Definitions
There is no general agreement on a definition of “single-use plastic”. For the purposes of this report, Administration has focused on plastic checkout bags, plastic straws, polystyrene drinking cups, food take-out containers and micro-beads. A number of other common plastic items that meet the basic definition of “single-use plastics” are not generally the focus of reduction efforts, such as syringes, balloons or cigarette filters. At a basic level, however, almost all plastics in Canada are “single-use plastics” because Canada recycles only nine per cent of its plastics. The other 91 per cent are used and then landfilled, incinerated or littered. The vast majority of plastics are thus rendered single-use plastics, whether they are recyclable or not.
Ongoing Federal/Provincial Work on Single-Use Plastics
The federal government, through the Canada-wide Action Plan on Zero Plastic Waste, has confirmed its commitment to ban harmful single-use plastics. The federal government is working to have new regulations in place as early as 2021, where supported by scientific evidence and warranted. The January 31, 2020 release of the Draft Science Assessment of Plastic Pollution reaffirmed this commitment. The Province of Saskatchewan’s recently released Saskatchewan Solid Waste Management Strategy cites this upcoming federal plan as a basis for the provincial strategy. Additionally, the Province could coordinate efforts to reduce plastic use and/or introduce legislation to make the producers and first sellers of these items responsible stewards. (See Appendix A-1.)
Recommended Option
Option 1: Continue to focus on delivering the initiatives outlined in WPR. This suite of projects and services is intended to advance the City’s overall waste management, including reduction of single-use plastics.
Evaluation against Objectives
Objective 1: This option does not provide an immediate improvement in the reduction of single-use plastics entering the City’s waste stream. Instead, it focuses on a holistic approach to waste management, working to educate and inform residents to reduce their total waste generation.
A distinction between single-use plastics and single-use items made from other materials is not particularly meaningful from an environmental perspective. All disposable items, no matter what material they are made from, have negative environmental impacts. A ban on one product may result in a switch from disposable products made of plastic to disposable products made of wood, paper, metal, glass, or other mixed materials. Such a switch simply means shifting from the negative environmental impacts of plastics to the negative environmental impacts of the other materials such as increased greenhouse gas emissions, deforestation, water waste, etc.
It is useful to consider the problem of single-use plastics in relation to other parts of the waste stream in Regina. Single-use plastics account for approximately one per cent of the residential waste stream and are not easily eliminated by a municipal ban alone. The Fleet Street Landfill serves much of southern Saskatchewan and would continue to receive plastic checkout bags from the region even if Regina moved to ban. By contrast, organic material accounts for approximately 50 per cent of the waste in the average residential garbage cart in Regina. Half the residential waste stream is compostable and easily divertible via a curbside food and yard waste program, which is entering its initial pilot phase in Regina. Similarly, industrial, commercial, institutional, construction and demolition (ICI, C&D) waste account for approximately 70 per cent of total waste entering the Landfill. Waste Plan Regina identifies waste diversion service development for ICI, C&D as a priority for 2020-2023.
Objective 2: This option continues to prioritize the projects and services that provide the best environmental return on investment. By focusing on changing resident habits to reduce total waste, the City has the greatest opportunity to influence behaviour change and minimize the problem of replacing one single-use product with another.
In general, municipalities consider bylaw restrictions on single-use plastics once they have completed work on a number of other larger-scale waste related actions such as introducing curbside collection of food and yard waste, landfill bans on food or recyclables, and mandating diversion for industrial, commercial, institutional, construction and demolition waste. Working on larger-scale waste issues first allows for maximum environmental impact and the best return on investment. For example, while replacing plastics with other single-use products like paper bags is not environmentally desirable, paper bags can be composted, reducing their negative impact. Requiring businesses to provide compostable alternatives is of almost no environmental value until the City of Regina’s Food and Yard Waste program is in place. Full implementation of this program is planned for 2023.
Objective 3: This option provides the best opportunity to maximize environmental benefit by balancing the activities of different levels of government. The federal government is working to have new regulations in place as early as 2021, where supported by scientific evidence and warranted. The January 31, 2020 release of the Draft Science Assessment of Plastic Pollution reaffirmed this commitment.
Regina will continue to implement Council-approved initiatives in Waste Plan Regina. This includes monitoring any changes in the physical and legislative environment and responding to anticipated federal/provincial restrictions.
As indicated in the City’s survey results from October 2019, 72 per cent of respondents feel that all three levels of government (municipal, provincial, federal) should take action to reduce single-use plastics. (See Appendices B-1 and B-2 for the survey results.) Typically, the higher the level of government that responds legislatively to this issue, the better the environmental outcome since the federal government has the ability to control production, import, export, and sale of these items. Similarly, the higher the level of government that responds legislatively to this issue, the less disruption to the supply chain and consumer.
The issue of plastic microbeads provides an example. Microbeads are tiny synthetic polymer particles, which were used in personal care products. Toiletries that rinse off and wash down household drains were especially likely to contribute to plastic pollution in oceans, rivers and lakes. The federal government has already addressed the problem of microbeads under federal regulations, banning their use in toiletries and prohibiting the manufacture, import, and sale of all toiletries containing microbeads. Most consumers are not even aware these single-use plastic products have been successfully eliminated because action by the highest level of government resulted in the best possible environmental outcome with no disruption to the consumer.
Meaningfully addressing the problem of single-use plastics requires systemic change, which can best be achieved by cooperation with higher levels of government.
Objective 4: As identified above, federal restrictions on single-use plastics would minimize disruption to the supply chain and consumers. Banning at the federal level as early as 2021 will allow for minimal disruption to the market and end user and maximum environmental benefit. Meanwhile, focusing Regina’s efforts on advancing the suite of services and initiatives outlined in Waste Plan Regina will allow the City to reduce measurably the use and impact of all waste in Regina, including single-use plastics.
Objective 5: While this option includes reduction of single-use plastics in its overall reduction approach, it does not directly and immediately address the public interest in more aggressively reducing single-use plastic pollution.
Both the ability and willingness for action at the level of the consumer are limited. Although nearly 10,000 people responded to the online survey on single-use plastics and 82 per cent of the residents consider reducing single-use plastics to be “important” or “very important, 53 per cent of the same respondents say that they “rarely” or “never” use a to-go cup when purchasing beverages. This suggests that the behavioural changes required to eliminate single-use plastics are not yet in place among Regina residents. If polystyrene cups and take-out containers are merely replaced with other non-recyclable mixed materials (typically made of paper and plastic), the basic problem is not resolved. These materials often weigh more, cost more, and must also be landfilled in the end. Continued communication and education efforts are required to influence behaviour change.
Continuing the ongoing waste initiatives outlined in WPR can effectively reduce not only plastic waste, but the overall waste footprint of the City of Regina.
This report responds to MN19-6, May 27, 2019 and MN 19-18, October 28, 2019.
Respectfully Submitted, Respectfully Submitted,
{Signature}
Prepared by: Juanita Elford, PhD, Waste Minimization Specialist