Open Letter to Ocean Conservancy regarding the Report “Stemming the Tide”

Open Letter to Ocean Conservancy regarding the Report “Stemming the Tide” 

October 2, 2015 

We, in the environmental, health, climate, and social-justice movements from the Asia-Pacific region, are deeply concerned about the recent report “Stemming the Tide” commissioned by Ocean Conservancy. 

We are writing this open letter to Ocean Conservancy to state our response to the recommendations and assumptions made in this report, and to offer an initial technical critique of the technologies and solutions put forth here. This critique is available here. Through this letter, we also want to share our heartfelt reactions to the report. 

We are organizations and cities that are working hard to promote local solutions to waste and wasting based on shifting mindsets about how we use our resources, on engaging with communities and governments to create local solutions, and on changing unsustainable systems rooted in an endless cycle of extraction, production, consumption and disposal. We work with our cities and communities to conserve what’s left of our quickly-diminishing natural resources by pushing for proper resource use and management through the reduction of waste and problematic products, redesign, reuse, repair, re-purposing, recycling, composting, and other solutions that make best use of public funds and create opportunities for livelihood and active public engagement. 

And we are deeply dismayed and offended that a report aiming to reduce plastics pollution in oceans seems to have missed fundamental facts to support this goal, and is recommending “solutions” that go strongly against and may well dismantle real solutions being implemented in countries mentioned in the report, which so many have worked so hard to achieve. 

We share the same concerns that the report’s authors state: there is too much plastic pollution in the world today, not just in our oceans but in our schools, communities and cities. We agree that the plastic menace and the improper disposal of plastic and waste in general are causing massive damage to public health, the environment and the climate. We further agree that there is an urgent need to properly manage waste and plastics in a way that will not further harm human health and already-fragile ecosystems, and cause more irreversible damage to the climate. This need cannot be overestimated. 

The report’s foreword states this: We believe this is the best solution to the problem of plastic waste leaking into the ocean—stopping leakage in the first place, rather than treating it after pollution has already occurred. This is puzzling to us, because this statement misses what seems to be glaringly obvious: the best solution to reducing plastics going into oceans is to reduce the generation of so much plastic and disposable products in the first place, and to create systems and implement solutions that work toward that goal, not against it. Consumer goods designed for the dump naturally get dumped, which is why disposable plastics end up in dumpsites, landfills, waterways, and the oceans. 

We agree that the focus should be on land-based solutions to prevent plastics from entering waterways, yet the recommendations in this report do not go far enough into the lifecycle of products. In order to stop the leakage of plastic waste, we must stop plastic waste itself. Real solutions pathways need to include redesigning products, packaging and overarching systems, and preventing the massive growth that the plastics industry currently aspires to achieve. 

The authors of this report are seemingly resigned to the rapid expansion of global plastics production, which is projected to increase from 250 million metric tonnes in 2015 to 380 million MT in 2025, rather than the responsible approach of designing out problematic products in the first place. This mindset will certainly allow for more creation of waste, but we simply refuse to buy into this kind of thinking. This is why many NGOs in the Philippines, Indonesia, India, China and other countries in Asia are working with local government units (LGUs) and national governments to implement policies at the local up to the national level, banning or regulating problematic and disposable products. 

We are also alarmed that the report puts heavy emphasis on using incineration technologies as one of the primary “solutions” to address plastics leakage. It has grossly underestimated how much it would cost to build these incinerators, much less operate them on a daily basis, and it glosses over the health and environmental impacts of burning so much waste. It is alarming that it is recommending to increase incineration rates in the countries mentioned, when citizens of these countries already struggle with so much air pollution in their cities. 

Was it even considered at all in the making of this report that in the countries mentioned, citizens are working hard to promote solutions that do not rely on incineration, and that they may not want polluting and toxic technologies in their communities in the first place? There are hundreds of solutions being implemented in these countries that rely on community-based approaches of decentralized waste separation and collection, increased resource recovery, composting, recycling and waste reduction, that have opened economic opportunities for millions of waste workers and are being sustained at costs that are a fraction of what it would take to build an incinerator. Some of these stories can be found in the report, “On the Road to Zero Waste: Successes and Lessons From Around the World” a collection of case studies documenting places making real progress towards Zero Waste goals. 

To suggest waste-to-energy incineration and refuse-derived fuel as medium-term solutions to plastic pollution also ignores why we need to wean off fossil fuel products such as petroleum and plastics right now. Burning waste and plastic products perpetuates climate changing fossil fuel extraction from rapidly-depleting sources. It is also one of the worst things we can do for our oceans—incineration releases extremely high levels of greenhouse gases, which in turn lead to rising sea levels, increased ocean toxicity, and destruction of coral reefs and other marine life through climate change. 

“This report tries to set back all the hard work and efforts of local groups and frontline communities who have been fighting incinerators and campaigning for genuine upstream solutions to the waste crisis,” said Von Hernandez, Goldman Prize Winner and former Executive Director of Greenpeace Southeast Asia. “Any solution that aggravates a problem is a false solution. Waste-to-energy incinerators and resource-derived fuels sustain the demand for new plastics for every piece that they burn, thus maintaining the current resource-extractive mindset of the industry - and this we must not allow to continue,” he adds. 

In China, where it is suggested to increase burning waste up to 80%, non-government organizations working on waste have documented that 18-30% of incinerators have no capacity to meet environmental regulations. Out of 160 operating MSW incinerators, 40% have incomplete air emissions data available to the public, and among those that have data, 69% have records of violating new environmental air pollution standards. 

“Given the terribly low compliance rates and bad transparency showed above by both government literature and civil society report, the expansion of MSW incineration in China could result in unacceptable increase of pollutant emission, more environmental law violations and higher costs of public health. More importantly, relying on incineration will continuously impede China’s efforts of pursuing sustainable waste management, which is based on prevention, separation and recycling/composting,” states Mao Da, co-founder of the organization Rock Energy and Environment Institute. 

It is also unconscionable that the climate impacts of allowing the increased generation and incineration of plastics materials were all but ignored in this report, when disaster risks brought by climate change have already caused massive damage to human lives, homes, public infrastructure, agriculture and economies especially in countries like the Philippines. 

It is unsurprising, however, that this report asks us to manage an ever-increasing supply of plastics rather than shift the underlying economic problems with our “dig, burn, dump” economy, as the corporations on the Steering Committee of this report (including Dow Chemical, the American Chemistry Council, and Coca Cola) all benefit from our current system. These are not companies that will support the kinds of solutions we really need, and they have a track record of making decisions with disastrous consequences for human rights, public health, and the climate. 

We appreciate the huge undertaking that went into this report, the admirable effort to critically examine how plastics enter our oceans and the effort to offer solutions to address this crucial issue. But let's not trade marine health for children's health -- we know we can have both.