ITEM 1: Delay Recovery…

ITEM 1: Delay Recovery Targets for Select Material Categories

Oxford County has the following concerns with delaying recovery targets for another 5 years and suggests the deferral be reduced to maximum of three years:

• Delaying recovery targets could result in recyclable material ended up in landfills and negatively impacting overall landfill diversion rates.
• With the present landfill capacity shortage, Ontario cannot afford to delay recovery targets.

Producer responsibility discussions began in 2016 with the regulation passed in 2021 giving Producers over five years to plan for these changes, regardless of the current economic climate. The intent of the new producer responsibility program is to incentivise the producers of blue box waste by reducing waste and increasing resource productivity. Recovery targets that incentivise Producers to implement positive changes to make the collection program more efficient, improve product design and processing technologies, and influence market valuate for end-of-life materials should be implemented as soon as practically possible.

ITEM 2: Remove Planned Expansion for Multi Residential Buildings, Schools, and Specified Long-Term Care Homes and Retirement Homes

Oxford County has concerns about the removal of planned expansion for multi-residential buildings, schools, and specified long-term care homes and retirement homes from the regulation.

Producers are responsible for collecting residential generated blue box waste. Blue box materials generated by these building types are generated by residential sources (i.e.: children’s school lunches, family blue box waste from multi-residential units, etc.) and therefore collection from these buildings should remain a requirement under the Blue Box program.

Multi-residential buildings of six or more dwelling units are required under O. Reg. 103/94 to implement a source separated program for waste generated by these buildings. Historical evidence indicates that very few of these buildings implement an independent collection program due to cost and without Ministry enforcement blue box materials from these facilities will end up in the waste stream for landfilling.

ITEM 3: Remove requirement to collect beverage containers “away from home”

County Comments
Oxford County supports removing the requirement to collect beverage containers away from home if there will be active enforcement of O. Reg. 103/94 by the Ministry. Most affected industrial, commercial and institutional properties are either not aware of their obligation under O. Reg. 103/94 or choose not to complete with the regulation. Enforcement of O. Reg. 103/94 is critical to ensuring blue box materials do not end up in landfill.

Oxford County believes a recovery target of 75% is achievable.

ITEM 4: Remove Expansion of Public Space Collection

Oxford County agrees that public space recycling is typically highly contaminated and usually ends up in landfill unless the public space receptables are monitored. Therefore, the County would support not expanding public space recycling at this time, rather focus on servicing existing public space recycling and expansion of the program the program at a later date.

ITEM 5: Reduce and Delay Flexible Plastic Recovery Target

Oxford County has concerns about reducing the recovery target for flexible plastic to 5% and delaying the enforcement of this target to 2031 for the following reasons:

• A 5% recovery target will not incentivise the Producers to fine alternative product design or processing technologies to manage this waste stream.
• Maintaining status quo means that much of the flexible plastic will continue to end up in landfill and continue to have adverse environmental impacts as identified by Environment and Climate Change Canada’s single use plastic study.

The County acknowledges collecting flexible plastics as part of the blue box program can be problematic. However, alternative collection programs can be effective by avoiding contamination and potential impacts to sorting equipment. The County has had considerable success in collecting flexible plastics separately (drop-off depots) and recommend that the producers consider alternative collection programs that would not require advanced technologies.

ITEM 6: Allow energy recovery to count toward diversion targets

Allowing energy recovery to count towards diversion targets does nothing to incentivize Producers to change ‘non-recyclable’ packaging material and is seen simply as an alternative disposal option.

Oxford County supports a 15% cap on energy recovery as an interim measure as long as there is appropriate oversight to ensure that only non-recyclable materials are sent for energy recovery and that every effort be made by the producers to develop recyclable packaging material by an appropriate target date.

The Ministry needs to clearly define what is a non-recyclable material. Producers should be obligate to report their monthly and annual non-recyclable material rates based on audits which can then be audited by the RPRA (random auditing of facilities).

ITEM 7: Consider the best ways to ensure collected materials are sent for processing

The County believes that the “best efforts” requirement will not sufficiently drive diversion and that firm recovery targets are needed and therefore the regulation needs to expedite regulatory recovery targets and in the meantime specify that collected material must be sent to a registered processor to ensure landfill diversion.

ITEM 8: Clarify definition of a facility

Oxford County supports clarification of regulatory requirements; however, using the definition as set out in O. Reg. 103/94 of six or more units may result in townhouses/row housing that have direct curb access from participating in the blue box program and doing so may negatively impact diversion rates. The County recommends that any multi-residential building that is located along a residential curbside collection route and can bring blue box materials to the curb for collection should be allowed to continue to participate in the blue box program.

ITEM 9: Clarify collection requirements for schools

Oxford County supports this proposal and agrees that implementing this change will not have any significant additional cost for producers.

ITEM 10: Maintain depot access for residents in unorganized territories

Oxford County supports providing access to producer-run blue box depots to residents of unorganized territories where they have access to depot garbage services and believes implementation of this initiative will not result in a significant increase in cost for the producers.

ITEM 11: Update Timelines for Providing Blue Box Services

Oxford County supports producers and PROs being required to meet timelines as specified by a RPRA registry procedure and would provide program clarity and consistent service delivery for residents of Ontario, including First Nation Communities.

ITEM 12: Provide More Flexibility on Printed Promotion and Education Materials

Oxford County would support reducing/condensing printed information to identify acceptable materials, collection schedules, and contact information supported by on line information.

ITEM 13: Provide Flexibility on French Language Requirements

Oxford County supports this proposal.