The simplest solution to the…

The simplest solution to the current service challenges seems to be immediately raising the Recovery Target back to 72.25% (85% and 85%) or the 70% that is planned for 2030. The overarching problem with 2025 and 2026 performance under the Regulation appears to be the drop in Recovery Target to 65%. Prior to the 2025 change, all tires were being collected and processed, even though the Producers may have been out of compliance on the Collection Targets. If all tires are being collected and processed, the need to be in compliance on Collection Targets should be eliminated/ignored, RPRA should have some flexibility to assess the need to declare Producers out of compliance.

1. Collection Requirements: The regulation should be written in such a way that all tires must be collected, but it isn’t helpful to the industry to make the requirements too restrictive. If a PRO starts the year with a Collector as part of their network, they should be obligated to service that Collector all year, unless they mutually agree with another PRO to transfer the Collector to the other PRO.

2. Tire Management Timeline: Keep the March 31 processing requirement for processing collected tires. The 3 month timeline within which tires must be processed seems reasonable. This would allow for some accumulation during the Spring and Fall seasonal supply peaks that would be dealt with by the time the next seasonal peak arrives.

EFW should not be allowed as it would reduce the need for the Producers to work collaboratively with the processors. Allowing EFW would reduce the volume of material available to be recycled into value added products that deliver another life cycle to the recovered materials. Allowing EFW would result in lost jobs, reduced capital investment in Ontario and reduced economic benefit to the province of Ontario.

5. Administrative Penalties (AP): If there is no cap on AP’s the door is wide open to market manipulation.

6. Shared PRO Activities:
Approach 1 - If there is no requirement for all PROs to share a collection network or to force them to buy any available credits, there is no point in introducing this language to the regulation.
Approach 2 – we do not support a clearinghouse for collection responsibilities or credit trading.

7. Increase ON Based Recycling:
Placing a higher value on tires processed in Ontario or discounting tires processed outside of Ontario would be beneficial to the long term health of the industry in Ontario. It would encourage Producers to work with Ontario processors, maintaining and strengthening those relationships, which should provide more certainty of supply to the processors. This certainty would promote ongoing investment in processing capacity in Ontario. Ontario should be the processing priority, other Canadian activities should also be preferred over US options.
If EFW were to be allowed as suggested under Item #2, it should have a negative value if processing in Ontario gets 2X value.