The City of Mississauga has…

The City of Mississauga has reviewed the proposed amendments to the Blue Box Regulation and appreciates the opportunity to provide feedback. The City recognizes the Province’s commitment to make producers responsible for operating blue box programs. While the amendments aim to reduce costs for producers to operate blue box programs, they would instead shift costs to municipalities. The full financial impact of these proposed changes remains unclear; however, should they be adopted in their entirety, the City anticipates increased operational and financial pressures.

The following highlights two core areas of concern:
• the exclusion of public space recycling expansion, and
• the exclusion of new growth areas, such as multi-unit residential buildings, schools, and long-term care or retirement homes.

Both exclusions will create multiple recycling collection systems, which may lead to resident confusion about who is responsible for managing and overseeing recycling.

Please see specific comments related to the amendments outlined below.

Public Space Recycling Expansion Exclusion

The cancellation of public space recycling expansion would remove the requirement for producers to provide and service approximately 2,000 recycling containers in City parks, and additional collection along roadsides. The City currently manages recycling services in our parks, providing recycling containers and deploying sanitation crews and fleet vehicles for collection. The proposed expansion of public space recycling was intended to extend these services to parks. As a result of the proposed amendment removing planned expansion for public space collection, the City would continue to be financially responsible for recycling in parks. Similar impacts would apply to roadside recycling containers in areas such as new Business Improvement Areas, which are not currently serviced under the Regulation. The absence of additional recycling containers along these roadways could result in increased litter and more recyclable materials being disposed of in garbage-only roadside bins, thereby shifting the burden of managing these materials to the City.

New Growth Exclusion

Excluding recycling collection for new growth shifts responsibility and costs to property managers, boards, or potentially the City to provide the recycling collection service. As per provincial requirements to address the housing crisis, the City’s target is approximately 370,000 homes by 2051. Many units would likely be built within multi-unit residential buildings/condos possibly resulting in expenses for recycling services. This raises fairness concerns, as new multi-unit residents might be required to pay for a service others receive at no cost, which may create confusion and inconsistency.

Additional Impacts

The additional amendments and subsequent City impacts include, but are not limited to:
• The removal of “away-from-home” beverage container collection, leading to the City bearing the cost of a possible increase in litter and waste management in public spaces.
• Reduction and delay of recovery targets leading to lower diversion rates and increased landfill use.
• Inclusion of energy recovery (incineration) in diversion metrics raises environmental and operational concerns when this material could be recycled.
• Revised specifications for multi-unit residential buildings, leading to less efficient recycling service.

Clarification

The City would appreciate the opportunity to work more closely with producers to support small businesses regarding the co-mingling of eligible and ineligible recycling collection. There are operational and environmental benefits having the same collection vehicles collecting and sending the material for processing. Additional clarification is required as it is not understood if the cost for recycling collection and processing for these locations would be the responsibility of the municipality or the producers.

Recommendation and Conclusion

The City of Mississauga agrees with the Province to make producers responsible for operating blue box programs. The City strongly urges the Province to maintain its commitment to producer responsibility and avoid reversing critical elements of the Regulation. These amendments risk fragmenting service delivery and undermining environmental progress. We respectfully request the Ministry consider these points when finalizing regulatory updates.