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.
croaking cassandra 
This is a great example of the decline in the analytical ability of our public service and how pathetic our culture has become in attempting to clearly describe issues and fix them, in a mature and methodical way. I am blaming the 4th estate here and their need for everyone to be seen to be ‘doing something’ and their simultaneous shrillness when someone does indeed do something.
Here was an opportunity for government to force the market to more effectively price these items (as described above) and secondly perhaps a potentially bigger opportunity (given how much the current government love the levers of state) to solve the issue of plastic waste that can no longer be sent to China for processing with developing a New Zealand based solution to this issue – think a large processing plant in a region somewhere for someone to cut a ribbon on and talk about subsequent ‘job creation’.
Such a solution could be extended to or developed concurrently with solutions as to how we help our Pacific neighbours. I assume that they likely face the same issue in no longer being able to send plastic waste to China (or elsewhere) for processing – if this was occurring at all. If we developed a solution where we could help reduce our waste and help with some of their waste problems in order to reduce the total amount of plastic waste in the oceans in our region, then surely this would be a classic win-win both diplomatically and environmentally?
Instead, we get limp virtue signalling and the negative effects of an outright ban following no hard-headed analysis and platitudes spun by PR merchants about how the idea came to the PM from the mouth of babes.
What a sorry state of affairs.
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The proposed ban has been partly implemented in Auckland North Shore; I can chose from about 6 supermarkets and they vary from no bags, to purchase bags, bags without asking and bags if you ask. So far it has been a good idea since it is making the public think about waste in general and specifically plastic. Of course the eventual solution will be pay for the bag and a similar penalty for all drink containers would be wise – say a refund of 10c on every bottle.
Your idea that we should be encouraging other countries makes great sense. Certainly PNG has many energetic unemployed willing to collect if and only if they are paid. When I lived there I heard the comment that Port Moresby was the litter capital of the world but I also met a young man in the Southern Highlands who collected empty coke tins, put them on the Highlands highway to be flattened by trucks, stacked the flat result and when the stash was large enough had them taken to Lae about 8 hours drive away just to collect the scrap aluminium value. Managing waste is labour intensive and PNG has plenty of willing workers. Any way NZ can use its aid budget to assist Pacific countries manage waste disposal is tax payers money well spent. However first we have to set an exemplary example.
“”The world economy doesn’t suddenly collapse when the resources suddenly run out””. What about Easter Island when they cut down their last tree (ref Jared Diamond’s ‘Collapse’) or Maori protein sources when they ate the last Moa?
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On the moa example, I presume they used fish and smaller birds – probably gradually as catching moa became harder.
The famous quote is that the Stone Age didn’t end because our ancestors exhausted the stones.
Re setting examples, the numbers in the table suggest we already do (without trying).
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The Moa and the rest of the ecosystem may well have been killed by rats not irrational humans or possibly the ease of catching Moa and eating them caused a population explosion and then starvation and cannibalism. The survivors write the history and the blogs. You and I are both the result of a miraculous chance; neither of us nor any of our direct ancestors died at birth or during childhood yet we know that the odds of that happening are truly astonishing. I see no reason to expect civilisation to continue ever upwards; in fact the more our civilisation becomes complicated the more fragile it becomes.
We do have to appear as if we are trying if we are to lecture or lead or assist Pacific nations with waste disposal. Which is why we need the kind of serious analysis you mention in your last paragraph.
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I have been watching excavations of Easter Island on Youtube and all those Moai heads that we see have long torso and a block stand buried under at least 6m to 7m. of earth does indicate some kind of cataclysmic event in the distant past that buried all these statutes. I do not think the theory of cutting their last tree caused the collapse of the civilisation but it is clear whatever vegetation they had would have been buried when the Moai statutes got buried.
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Reblogged this on Utopia – you are standing in it!.
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Mike, this is just analysis gone mad. Take an alcoholic who decides they want to be sober and stops drinking for a day. Would you then condemn them and say they should just give up and be intoxicated forever because one day makes no difference? Equally, something perhaps closer to your heart, if a new-born Christian on day 1 makes mistakes in the eyes of God, would you tell them to give up and live a life of sin because the goal is too far from their starting point and the very small changes they are making are not statistically significant compared with all the other errors they have and are going to make? Of course not!
Sometimes moving in the right direction, however small, is the right thing to do. Immeasurable, costly, and perhaps frivolous at first. But one step is better than none at all.
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We might have to agree to differ on this one. I expect a higher standard from governments, and especially government agencies than “perhaps frivolous” when they want to use the coercive powers of the state to compel us to act their way. As I noted in the first posts (and as Ian does too I think) I’d have no particular objection to a robustly-analysed case for a bag tax or minimum charge. Within reason, I would choose to pay it, as abolition of plastic bags is going to be really quite inconvenient – and the bags I get don’t become littler (unlike, it seems, we must presume those of Cabinet members and Greeen Party ministers).
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Indeed, it is the small NZ businesses that produce these plastic bags that would be the most hurt by this ban. There has been no talk of compensation for the NZ businesses that had invested heavily into plant and equipment or the employees that would be laid off.
“A plastic manufacturer says people are blaming plastic bags for wrecking the environment, instead of taking responsibility for their own wasteful behaviour. The decision to phase out single-use plastic bags, announced last week, means Kiwi Plastics will close at the end of the year.”
https://www.stuff.co.nz/business/106280557/plastic-bag-makers-say-their-product-isnt-to-blame-for-damaging-the-environment?rm=m
Most of our clothing fibres are now plastic. I think this is the microfibres by the tons that is being flushed down the 9 largest rivers in the world that is contributing to all this plastic bag madness and not the plastic bag itself. The only way plastics are getting into oceans are either through dumping by ships on route to supposedly recycling by non existent factories overseas or through our laundry wash through these 9 largest rivers that dump plastic into the oceans.
No local council or local government in their right minds would put waste disposal dumps close to a river or close to water. Another one of Jacinda Ardern’s waste of time and waste of effort attempts at being Green.
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Reading your post this morning the following comes through loud and clear:
– you appear to have an ideological position that is opposed to government regulation – but only on certain things. Can it be assumed that there would be no opposition to government interventions that are advantageous to you?
– you see a plastic bag ban as trivial; I imagine that it is not trivial at all to the sea creatures that get caught up in them or, as has been documented, end up ingesting them
While not having a plastic bag at your disposal is a very small inconvenience to you i.e. remembering to take a reusable bag with you to
the supermarket. And just because YOUR plastic bag does not end up in the ocean is does not mean that there is not a problem.
– you are right in suggesting that it is not only about plastic bags, but it is a good place to start in alerting the population to the reality that what we do has real world consequences, and we are not the only important species on the planet. Other forms of plastic waste will also need to be urgently addressed as these micro-particles are now finding their way into the food and water chain, and ingesting them is likely to be extremely inconvenient to humans.
– I routinely pull the car over to pick up plastics bags that have deserted their owners and are floating about on the Southern scenic coastal route on its way towards the sea, and if this is happening in one small 20km stretch of the country then, when magnified to encompass the whole of NZ, I think that this proves that there is a problem.
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robyn, given that there are 4 million tourists and also likely plus another couple of million domestic travellers that frequent our Southern scenic coastal route every 12 months, a few plastic bags blowing in the wind does not justify a ban on all plastic bag use. There is no way at all possible that any of my plastic bag usage end up in the south island for you to pick up.
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I’m not sure which sorts of regulation you suggest would benefit me, so it is hard to respond to the generic slur. In general – and this is the main point of commenting on the bag ban – I try to adopt a consistent line of arguing for rigorous analytical (preferably quantifying costs md benefits) evaluation of any regulatory proposals. That sort of evaluation is almost totally lacking here. As I noted to an earlier commenter, there might be such a case to be made, but it hasn’t been. Were it to be made, I’d relatively happily pay a small tax or minimum charge for bags: standard economic analysis tells one that price interventions are typically less distorting and more efficient that outright bans or mandates.
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I have been living on the Sea for 10 years. Not in a marina but out on the water, I have sailed from NZ to Tonga and from Norway to Svalbard and various other places. I have yet to see a plastic bag in the water or on shore. Obviously during this time I would have somewhere but you get the point. Nor do I ever see any other plastic except occasionally on the tide line on ocean beaches, mostly from offshore fishing boats rather than domestic. Further to this there is hysteria over what any of this plastic actually does, how many animals are actually adversely affected and how? Greenpeace posting pictures of a dead fish on a beach next to a coke bottle… I’d like to see a Greenpeace activist stuck on a desert island with only a coke bottle actually kill a fish to eat with the coke bottle.
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