That’s the title of my former colleague Ian Harrison’s response to the government’s consultative document on getting rid of (some types of) plastic bags.  The consultation itself closed yesterday, but nobody supposes the consultation itself was remotely serious –  the irrational ban is going to happen anyway.  Having dug fairly deeply into the material used to support/underpin the consultative document, Ian illustrates just how little substance there is to the case.

Here are his key conclusions

Supermarket checkout bags do not materially contribute to littering.  Common sense and overseas evidence tells us that supermarket checkout bags are not littered frequently. There is more littering of very small bags, but mostly they will not be caught by a ban. Supermarket bags possibly contribute only around 0.1-0.2 percent of littered rubbish by weight. The Ministry has neglected to conduct a survey on the actual extent of supermarket bag littering.

Supermarket checkout bags are efficient and cheap.  Checkout bags cost about 2 cents, weigh between 4 and 7 grams, and are generally reused for other purposes. They are best described as ‘double-use’ bags. The amount of plastic in supermarket bags has fallen by 75 percent over the past 20 years. Compliant ‘emergency’ bags weigh around 6 times as much and reusable bags 20 times as much. Research shows that they are typically not reused frequently enough to offset the higher weight, so the use of plastic in shopping bags could actually go up.

Impacts can be perverse.  A shopper cannot be given a cheap lightweight plastic bag that is used to transport goods, and serve as a bin liner. But she can buy a much more expensive lightweight drawstring bin liner, which is used only once.

Supermarket bags likely to have a lower overall environmental impact than many alternatives. Alternatives bags have a much higher environmental impact that is unlikely to be offset by the higher number of times they are used.

Reusable bags are a health risk.   Research shows that reusable bags harbor dangerous bacteria and are not cleaned frequently. Supermarket double-use bags are safe.

A ban is unlikely to materially reduce marine littering.  The reduction in the small amount of plastic entering the marine environment of plastic checkout bags will tend to be offset by increased number of heavier bags littered.

The circular economy approach to environmental and economic management is often irrational.  The circular economy approach to the economy is centered in China and has been part of their 5-year plans. China has one of the worst marine pollution records in the world. The circular economy can be an empty slogan, but if taken seriously it can result in very inefficient decision making because it tends ignores the impact on people and the community when recycling is pursued at all costs.

A ban cannot be imposed by regulation.  Under the Waste Minimisation Act the Minister must be satisfied that the benefits of a ban exceed the costs. As there is no analysis of the cost and benefits in the consultation paper, the Minister cannot be satisfied, unless serious work is done to assess the costs and benefits.

Evaluation methodology rigged to generate the right answer.  The weights and evaluation criteria were set to bolster the score of the preferred option of a ban. The evaluation methodology has many flaws and is not a substitute for a proper cost benefit analysis.

A ban will have an economic cost of more than $75 million per year.  A cost of $75 million a year is our assessment from an illustrative costing model.

A minimum charge is a more efficient response than a ban.  The minimum charge that would reflect the costs of provision and associated environmental and social costs would be about 3 cents per bag.

Many of those points aren’t new in themselves (I made some myself in earlier posts on this issue), although I was interested to learn of the origins of the “circular economy” nonsense that now seems to appear in many government documents and even ministerial speeches.  Nonsense?  Well, here are Ian’s words

It is way of thinking, that comes out of the ‘limits to growth’ perspective (Boulding 1966). The earth is finite, resources are finite, so they must be recycled and not lost to the economy. While this finite resources proposition is literally true in the very, very long run, what the approach tends to downplay or ignore, is the role of the price system in allocating resources. As resources become scarcer, prices increases, resources are allocated to the most valuable uses, and innovation is encouraged that finds new ways of doing things. More natural resources are discovered because they are more valuable. The world economy does not suddenly collapse when the resources suddenly run out.

Prices simply don’t appear at all when the “circular economy” is being discussed.

For anyone interested in looking behind some of the material used to make up the case in support of eliminating supermarket shopping bags, Ian’s paper is useful because he made the effort to read the background papers (those cited and those that should have been), and to work through the logic of the case ministers and MfE are making.   It has its lighter moments, as when he suggests supplementary measures, banning Christmas (all those plastic toys) or

Ban on the sale of pianos.  Littering of pianos on beaches and dumping in the marine environment have been of historical concern in New Zealand (Campion 1993). Piano littering poses a threat to fish and marine mammals, and to human health. The enjoyment of piano playing is a colonial construct and has no place in a modern inclusive multicultural society.

And a much serious side in suggesting that if New Zealand governments really wanted to help make a difference, there are some obvious places to start.

Alternatively we could do something that actually makes a difference.

In 2009 Sustainable Coastlines did a cleanup, with wide community support, on a small Tongan island with a population of 4600. They removed 50 tonnes of rubbish, compared to around 80 tonnes for all their New Zealand opertions spanning seven years.
Below is a table taken from the report (Jambeck 2015) that provided the estimate of 8 million tonnes of plastics going into the oceans each year that has receivedwide spread attention. it shows annual total of mismanaged plastic waste, but this figure appears to be about four times larger than actual flows into oceans. While the individual country figures, the inputs and the methodology may be questionable in some respects, the data provides a reasobable representation of the scope for making improvement in the performance of our Pacific neigbours. Because New Zealand already has a robust refuse collection sytem and a reasonably good antilittering culture, the scope for large cost effective improvements here are limited. As we have demonstrated a plastic bag ban will make almost no difference, but has a large cost.

Our best strategy is to continue to build on voluntary efforts to clean up the coastal environment and to redirect, or supplement, our aid budget, to Pacific countries, where there will a much higher payoff in terms of reduced plastic pollution.

It is the sort of analysis one might do, or commission, if one were serious about looking at costs, benefits, and ways of maximising payoffs, as distinct from the sort of puff and rhetoric government agencies publish under the guise of analysis when they have a solution their masters want regardless and need to try to make some sort of case.