To: RDN Board Chair, SW Select Committee Members and SW Advisory Committee
RE: RDN Solid Waste Management Stage 2 Report
The Vancouver Island Recycling and Waste Industry Coalition (VIRWIC) supports the world leading waste diversion and recycling objectives proposed in the Regional District of Nanaimo’s Solid Waste Management Stage 2 Report. However, we believe that the RDN can achieve its goals and keep costs low only if it works closely with the industry that will be doing the work. Further, we ask that the RDN create a stable business environment so that our members can invest in infrastructure in the region, which will lead to more tax revenue and local employment. VIRWIC is a newly formed group with a key purpose to work with local governments and other stakeholders to develop fair and effective recycling and waste management policy. We want local government to meet its recycling and solid waste objectives, the public to receive high quality service at a reasonable cost and industry to have a stable investment environment.
Our key policy messages are:
- Local governments should not be in competition with the private sector. The role of Local governments should be to adopt a target setting, education and enforcement role
- Open and fair competition in the sector will create value for residents while keeping costs low. Industry investment in infrastructure can only happen when government sends a clear signal that it will not build competing infrastructure or restrict free trade
VIRWIC would like to provide the following comments on the Regional District’s Solid Waste Management stage 2 Report.
We Support the Target of 109/kg/pp annual disposal rate – The RDN is well positioned to achieve this target with the addition of some critical policy changes that will incent industry to divert more waste from disposal. ‘Industry is ready, willing and able to assist in the design and implementation of these policy changes.’
We Support Sec. 4.7.1 Waste Stream Management Licences – all facilities should be required to follow standards to protect human health and the environment.
We Do Not Support Sec 4.7.2 Regulating “Haulers as Agents”– The RDN proposal to regulate haulers is unnecessary as there is no environmental or human health risk that warrants government action. Further, the proposal is considered a “money grab”, will stifle free enterprise and is a form of Waste Flow Control, which does not have the support of the Provincial Government. Haulers are transporting recyclable material and waste out of the region because the costs of managing this material in the region is too high. If the RDN wants more recyclable material and waste managed in-region then it should work closely with industry to develop policies that will improve the economic conditions in the region – not create more red tape and regulation where it’s not needed.
We Do Not Support RDN Spending $16 Million to build new RDN infrastructure – The RDN can save taxpayers $16M and avoid borrowing costs if it can create a stable investment environment for private sector to invest its capital. VIRWIC members are willing to invest in the RDN to build new recycling and waste management infrastructure if it can be provided the assurance that the RDN will not build competing infrastructure. The RDN should not be using tax payer dollars to compete with taxpayers (commercial). We ask that you reconsider including the provisions above in the Solid Waste Management Plan.
We ask that you work closely with local industry in developing solutions that supports both your objectives and ours.
View Full RDN Letter PDF