Delay recovery targets by 5…

Delay recovery targets
by 5 years
 Recovery targets could be met with the inclusion of curbside
IC&I stops and the continuation of community/landfill depot
programs.
 Concerned that this will put more in the landfills delaying the
targets means reducing or delaying the improved
environmental outcomes
5 Remove planned
expansion for multiresidential buildings,
schools, and specified
long-term care homes
and retirement homes
that are not already
municipally serviced.
 Completely removing new MR buildings from the reg does
not align with the stated goal of focusing on residential
material as these are all residential homes.
 Rural Mennonite Schools could be impacted and removal of
service within the Township as currently being serviced.
 Schools with Daycares should be eligible.
Remove requirement
to collect beverage
containers “away
from home”.
 It’s understood the concerns from Producers to collect from
large industrial and commercial facilities; however small
businesses should be included, as should municipal facility
locations and recreation facilities.
 Excluding these containers from producer obligations in nonresidential settings creates a fragmented system, risks
increasing municipal waste management costs, contributes
to the likelihood of these materials ending up in the waste
stream, and ultimately reduces overall recovery
performance. Beverage containers, regardless of where they
are consumed, constitute a highly recoverable material
stream.
Remove expansion of
public space collection.
 There are challenges to open space collection and
improvements that could be made in this area.
 The overwhelming majority of litter is printed paper and
product packaging
 The regulation represents a missed opportunity to:
o Capture producer-supplied recyclables in high-traffic
areas.
o Reinforce consistent environmental messaging and
public participation in waste diversion and recycling.
 Alleviate the cost burden on municipalities, which will
otherwise remain responsible for collection and disposal.
8 Reduce the target for
flexible packaging to
5% and delay
enforcement until
2031.
 The target for flexible packaging should not be reduced;
instead, higher benchmarks and timelines should be
maintained to prevent regression in packaging design and
material recovery.
Allow energy recovery
to count toward waste
diversion targets (i.e,
up to 15% of the
management target by
material type).
 Energy From Waste has traditionally processed garbage
destined for landfill, not residential recycling streams. If
energy recovery is permitted to contribute toward recycling
diversion targets, the regulation should then include a
receding cap or declining allowance over time. This would
prevent over-reliance on energy recovery as a convenient
alternative and reinforce the need for producers and service
providers to invest in innovation and improve packaging
design and recyclability.
10 Given the government
is removing targets,
consider changes to
ensure materials are
sent to a registered
processor not a
landfill.
 “Best efforts” are not sufficient to drive diversion until 2031
and the regulation should be amended to clarify that all
collected Blue Box material must be sent to a registered
processor and not directly to landfill.