Lisa Kingsmore…

Lisa Kingsmore
Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Resource Recovery and Policy Branch
40 St. Clair Avenue West
Floor 8
Toronto, Ontario
M4V 1M2

Dear Ms. Kingsmore:

Re:EBR Number 013-1716 - Tire Regulation under the Resource Recovery and Circular Economy Act, 2016

As a member of the Regional Public Works Commissioners of Ontario (RPWCO), the City of Hamilton (City) is supportive of the proposed Tire Regulation under the Resource Recovery and Circular Economy Act, 2016 issued by the Ministry of the Environment and Climate Change (Ministry). The following are the City of Hamilton’s comments regarding the Framework:

1. The City’s Solid Waste Management Master Plan (SWMMP), approved by Hamilton City Council in June 2012, supports actions which encourages waste reduction, optimizes the use of waste diversion facilities, and minimizes residual waste. Used tires are currently accepted for collection at the City’s Community Recycling Centres.

2.The City is supportive of the Ministry’s implementation of the proposed Tire Regulation in order to eliminate the need for the disposal of tires in Ontario by making tire producers accountable for recovering resources and reducing waste associated with tires they supply to the Ontario market. The strategies that reduce the amount of tires requiring disposal must consider environmental responsibility, economic requirements, and convenience for Ontario residents.

3.Municipalities are a major stakeholder with providing waste management services for residents in Ontario, therefore it is imperative that municipalities should continue to be involved with discussions, assessments, program design, implementation, and outcomes of the actions related to tire collection programs affecting Ontario residents. It is recommended that the Ontario Government avoid any additional new costs to be paid by municipalities resulting from the proposed Tire Regulation.

4.The Resource Productivity and Recovery Authority must make certain that there is a smooth transition of the existing tires collection program and develops a new fair Used Tires Program under the Resource Recovery and Circular Economy Act, 2016.

5.The Ministry and the Resource Productivity and Recovery Authority must ensure existing Used Tires Program will continue to be available for the public without disruption until it is transitioned to the new system under the Resource Recovery and Circular Economy Act, 2016.

6.The City supports the Ministry’s proposed actions which require tire producers to implement promotion and education program to provide information on the Used Tires Program.

7.As part of the implementation of the proposed Tires Regulation, the Ministry should ensure there are suitable and sufficient tire processing facilities in Ontario in order to meet the Ontario Government’s goal of supporting a circular economy under the Waste-Free Ontario Act, 2016.

[Original Comment ID: 212174]