The Chamber asserts that there is a growing disconnection between the goals of reducing waste, increasing diversion rates and the cost that independent businesses are being asked to bear. In an effort to increase environmentally sustainable communities, governments at all levels have begun to develop policies aimed at reducing single stream processing centres for garbage and transferring the costs of an integrated waste management programs onto producers of that garbage. The impact of this shift in philosophy is increased cost burden being placed on waste haulers, waste service providers and local businesses, with little or no economic benefit. Because the Chamber believes that these policy restrictions set barriers that limit private enterprise from the ability to afford investment in innovative technologies from entering the solid waste management market.

Because regional governments are moving to impose increased regulatory burdens, we assert that this shift represents an unfair advantage held by the governing bodies. As a result, publicly owned facilities profit at the expense of private sector facilities. In 2013, Metro Vancouver attempted to introduce proposed Bylaw 280—a bylaw that would institute flow control measures that would allow the region to increase tipping fees at will, maintain a feedstock for an incinerator and position the regional government to create a monopoly on solid waste services. Eight other regional districts1 have supported Metro Vancouver’s efforts to institute flow control after an lobbying efforts by Metro Vancouver, making the issue provincial in nature.

  • B.C. Minister of Environment Mary Polak rejected proposed Bylaw 280 in 2014 citing concerns that the regulation would have:
  • the potential to “stifle competition” in the waste management sector;
  • the potential for increased illegal dumping; • possible negative effects on MMBC; and
  • a “destabilizing” effect on private-sector collecting and hauling.2

However, proposed Bylaw 280 is not the only method endorsed by Metro Vancouver to increase diversion that industry has concerns with. Other concerning methods, since the Minister rejected proposed Bylaw 280, include:

  • shifting the tipping fees to be cheaper for large haulers while placing small haulers at a disadvantage
  • refusing to accept specific private industry methods that can be used in tandem with source separation to increase diversion

Unsustainable Financial Model
Metro Vancouver’s waste reduction goals are contradicted by the methods in which Metro Vancouver collects revenue for its waste management programs. The first two goals of the Integrated Solid Waste and Resource Management Plan (ISWRMP)—minimize waste generation and maximize reuse, recycling and material recovery—both reduce the resource from which Metro Vancouver gains its main revenue stream, waste. Metro Vancouver depends on tipping fees for 85% of its revenue according to the Metro

1Capital Regional District, Regional District of Okanagan-Similkameen, Alberni-Clayoquot Regional District, Comox Valley Regional District, Regional District of Nanaimo, Regional District of Central Kootenay, Regional District of North Okanagan, and Cowichan Valley Regional District 2 Ibid.


Vancouver solid waste budget3. Part of that budget goes into efforts to increase waste diversion resulting in smaller and smaller revenue streams. The budget projections between 2015 and 2019 presented at the Zero Waste Committee Meeting on February 5, 2015 state that with the new tipping structure format, there will be a $3 million average deficit every year until 2019. It should also be noted that this budget does not include the expansion of capital expenditures like the proposed $1 billion incinerator. The Chamber asserts that by allowing private enterprise greater access to the waste management market, private industry can add to the achievement of Metro Vancouver’s goals, create a market of opportunity and as a consequence, decreasing government expenditures.

The Role of the Regional District The Chamber’s asserts that a regional district’s main function is to provide regional services where, and only where, it is more cost effective than for municipalities to offer such services on their own, or if there is no other organization to provide services for a given region. In that regard, The Chamber believes that regional governments must be held accountable for seeking the most cost-effective and environmentally prudent means of waste disposal solutions that promote cooperation and competition. Additionally, in the spirit of competition, the Chamber believes that regional or municipal government authority should not extend to the selection of waste diversion methods other than to license facilities by setting up resultsbased operating standards and ensure that facilities are working to achieve the goals of the ISWRMP during their operation.

The ISWMRP states that the diversion of waste from disposal occurs through open and competitive private sector markets. Additionally, we understand that recycling, as defined under the Environmental Management Act, can occur at any point prior to disposal. In other words, there is no prescribed idea of only source separation, but that many methods of recycling can be used to achieve desired diversion goals.

Chamber members have indicated concern regarding the conflict inherent in the role that Metro Vancouver plays as both the licensing body for the waste management industry, but also as an operating player in the market, drawing revenue from the disposal of waste. Without increased separation of the operational and licensing roles that Metro currently performs in relation to the licensing of solid waste and recycling facilities or a third party appeal process of Metro decisions, there is an inherent conflict that does not serve the residents and businesses of the region. Instead, there is a great incentive for Metro Vancouver to make licensing decisions based on what will best suit the region’s capacity to generate revenue and expand its operations as the owner and/or operator of transfer stations or incinerators. Instead, Metro Vancouver can make more cost-effective decisions based on the best value for its member municipalities by promoting innovation in the private sector that allows for more cost-effective methods of waste diversion and waste disposal.

The Chamber understands that regional government has a role in setting waste diversion targets and operational regulations and following through with enforcement. But the Metro Vancouver region is also in direct competition with the private sector by providing services that can be provided by existing private waste businesses in a more efficient and cost-effective manner than government. Making it easier for private industry to invest in the waste management system will reduce cost to those businesses that generate waste.

3 Greater Vancouver Regional District Zero Waste Committee. (2015, February 5). Regular Meeting. 2nd Floor Boardroom, 4330 Kingsway, Burnaby, British Columbia: Metro Vancouver.


Provincial Government Guideline
The Chamber acknowledges the steps that the provincial government is taking in order to address the issues raised by the Chamber. The announcement made on May 21, 2015 of the update to the guideline for the preparation of regional solid waste management plans, which have not been updated since 1994, is a promising opportunity for consultation with the business community. The six guiding principles laid out by MLA Marvin Hunt in his review of solid waste diversion in BC that will be included in an intentions paper in summer 2015 reflect the recommendations made in this policy proposal.


That the Provincial Government work with Regional Districts to:

1. structure or restructure waste management policies in a manner that
a. reduces the expenditures of the regional government on publicly-owned facilities (if they are in direct competition with private industry); and
b. promotes innovation and investment by private enterprise;

2. collaborate with all members of the Commercial Sector to set waste reduction & diversion goals allowing the achievement of those goals through open market processes;

3. create policies and regulations that recognize new and future recycling and waste diversion technologies as secondary processing facilities (i.e. MRFs, Recycling Depots, etc.) and not as final disposal facilities (i.e. landfills, incinerators, etc);

4. reduce, amend, or annul regulation and other systemic factors that support a government monopoly or monopsony of solid waste management; and

5. directs regional governments to develop regulations in a manner that prevents the creation of government monopolies or monopsonies for solid waste management in the multi-family and industrial, commercial and institutional sector.

Submitted by the Tri-Cities, Greater Langley and Nanaimo Chambers of Commerce


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