As Ontario transitions its…

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Commenting on behalf of

Ontario Waste Management Association (OWMA)

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As Ontario transitions its recycling and waste diversion programs to a full producer responsibility framework, adequate oversight and enforcement must be given heightened importance to ensure economic competitiveness, regulatory compliance and a level playing field among industries and businesses.

Currently, the Resource Productivity and Recovery Authority (RPRA) delivers these functions, effectively, at no cost to taxpayers, and with minimal administrative burden. For example, the Registry has worked well for tires in allowing data to be shared with Producer Responsibility Organizations, with more streamlined data requirements than under the former Ontario Tire Stewardship Program.

Accountability and transparency must be upheld in the province’s administrative authorities. However, independent enforcement authority, such as that provided by RPRA, is also a necessary pillar to ensure business competitiveness and investment confidence.

While some of the proposed amendments to RPRA’s Operating Agreement may help to support accountability and transparency, the Ontario Waste Management Association (OWMA) sees little evidence that amendments to restrict RPRA’s mandate, and change the qualifications for directors on its Board, are needed at this time. RPRA’s activities to-date have shown it to be an effective regulator that is providing value to industry, consumers and municipalities who participate in regulated recycling programs. OWMA opposes some of the proposed amendments, as they may hinder RPRA’s ability to independently fulfill its functions and mandate. Our detailed recommendations are described in the enclosed supporting document.