I recently had the opportunty to review a draft OECD document entitled, EPR Policies and Product Design: Economic Theory and Selected Case Studies

Prepared for the OECD by Resources For the Future (RFF) in Washington D.C. the document includes a case study of the CPPI designed Used Oil Management Association (UOMA) style used oil material programs that operate in western Canada (and most recently in Quebec).

With fresh references to Environment Canada and cites to officials from the western UOMA programs the document diligently reproduces the received wisdom and glowing reports of the efficiency and effectiveness of UOMA style used oil material programs. The fact that Waste Diversion Ontario (WDO) rejected a UOMA program is given one passing footnote, "In 2004, Ontario voted down a proposal for a similar program in that province." (Say, isn't Ontario Canada's largest province?)

No mention is made of the fact that the WDO's rejection of a UOMA style program was based on long deliberations that resulted in the following determinations.

1. “The program plan does not include economic mechanisms to promote 3Rs, consistent with WDA (Waste Diversion Act) S.1, and to not promote burning, consistent with WDA S.25(2), so that implementation of the Plan would result in more Used Oil Material being directed to 3Rs than burning, all other marketplace influences being equal

3. The quantity of Used Oil Material to be collected through implementation of the Plan is identified in the 5 Year Recovery Objectives outlined in the Plan. The quantity managed through the 3Rs in each year is not identified.”

You would have thought that such a critical assessment of a UOMA program by Canada’s largest jurisdiction (with an extremely effective pre-existing used oil material recovery system) might have been deemed pertinent to the evaluation of the economic effect of UOMA program design. And it might have figured in the RFF work had someone from Canada provided it to the researcher at RFF (I did, but only belatedly after I got a hold of the draft document which I had not known existed before I received it).

Alas, it would seem that Environment Canada did not provide such dissenting information to RFF. Why? Well one can only guess but you might want to read an earlier work on the subject - Environment Canada's 2004 "analysis" of Alberta's UOMA program (again, duly received and published by the unwitting folks at the OECD). One might suspect that it is probably easier to dismiss Ontario's dissent than admit that under all that sugar coating is a rotten lemon (and that you helpd to sell many bushels of those lemons without really checking what it was you were selling).

The full cite of Environment Canada's tribute to the Alberta UOMA program is, Vanderpol, Michael. 2004. “Economic and Environmental Performance of Alberta’s Used Oil Programme,” in Economic Aspects of Extended Producer Responsibility (Paris: OECD).

You might then read my October 2005 crtique of the UOMA Program Review for what it means to dig a little deeper.