This Regulation is very…

This Regulation is very important to the waste management industry to fix the monopsonistic activities of Stewardship IFOs and ISPs.
Paramount items

You do NOT know the trust I have put into this Reg finally getting it right for the waste industry - the Ministry must really understand these issues the Service Provider sector is highlighting - the investment does not come from the sale of these products but rather by the waste management sector employing and managing these wastes - very few producers remain in the province now except for some distribution warehousing and retail employment

1-100% collected and managed must be funded - targets are necessary and exceeding collection targets require this certainty for Service Providers these will be funded not discouraged or not paid
2-Regulation must acknowledge the Regulation is compliant with the federal Competitions Act - not a Regulatory Defence to unfairly exert market dominance
3- The Authority has 2 Procedural sections - these need to be better defined in a framework of key elements - flexible but a guide of overarching elements - also, the authority should develop these principle details with the Producers and the Service Providers
4-Producers MUST SUBMIT QUARTERLY TO THE AUTHORITY to map out their progress and to ensure that Service Providers are not left managing these responsibilities on the Producers behalf - this WIL HAPPEN without interim submissions - Also awaiting for 18 months for first rep[ort is unacceptable - NO BUSINESS RUNS WITH REPORTING 18 MONTHS AFTER IT BEGAN - Such a manger would be fired - THIS IS DOABLE - THE SERVICE PROVIDERS DO ALL OF THE REPORT PREP ANYWAY - MAKE THEM REPORT IT TO RPRA PLS - I am concerned for our waste management industry if you do not
5- "Circular Economy" needs to be supported with imposed reuse buy producers - mandating and incentivizing reuse of product - eg all paint should need a post consumer content to it just like paper - Producers use ReWork all the time - make them integrate into the product otherwise "Circular" that should look like a circle (ie circular) "O".... only looks like a "C" - circle unclosed -even though it is the beginning letter for "Circular-" its just in the word not in the function - this is DOABLE - I've worked in a paint recycling company - don't let the paint associations say it is not - pls make this missing link happen for paint and any other suitable products (eg antifreeze but not pesticides)
6- What is the Ministry hoping to do to make more competition amongst PROs - no lead time to the Reg- ie July 1 - means that the incumbents WILL DOMINATE this space - they currently also have all of the pricing, customer lists, and rates for EVERYONE- what chance does another PRO have moving into this space - not a level playing field - info should be shared upon request by IFOs and ISPs
7- ECA facilities are key to the HSP program - these are NOT like electronics and tires and blue box and even batteries that can be collected and "piled up in the corner" - We need ECAs to manage these materials and this should NOT be downgraded because it is an EPR program - Producers must be required to file for same ECAs as the rest of the industry for the management of these materials or use the existing network of ECAs - TSDFs. In the past Regulation the IFOs dismissed the Transfer Facilities as "transporters" - these facilities are key ingredient in the properly trained staff and management of these HSP products
8 Other details in my attachment - I implore that you strongly consider these elements

thank you for your consideration - sincerely