My comments on "A proposed…

My comments on "A proposed regulation, and proposed regulatory amendments, to make producers responsible for operating blue box programs" ERO number 019-2579:

- As far as alternative collections systems: targets, I agree that a higher diversion target is necessary, and would propose that that that target be an additional 50% of the the outstanding common collection target (in the case of the cited example, of foam trays that would have a 55% common collection target, I would propose that the alternative collection target be 77.5% (100% - 55% = 45% outstanding * 50% = 22.5% above common collection target + 55% = 77.5%). This both has the incentive of encouraging very effective alternative systems, as well as strongly encouraging participation in the common collection system unless a very effective alternative system is able to be implemented.

- My other comment, is that there is a need in this legislation for two additional provisions:

1 - That consumer retailers be part of the list of collection location requirements along with schools, residences, etc. And that consumers may unpackage and discard packaging of goods sold at the retailer on the retailers' premises. This will incentivize retailers to encourage product producers to reduce excess packaging.

2 - That a provision be made that all consumer retailers, be they resident in the community, resident in Ontario, or online, as a condition of sale, allow product returns (where eligible under normal circumstances) - to mandate that they not require consumers to return goods in the original packaging. This would further encourage producers to reduce the amount and complexity of packaging, as well a incentivize them to move to reusable packaging where possible.