The Township of Strong…

The Township of Strong appreciates the opportunity to provide comments on ERO #025-0536 regarding the proposed amendments to the Resource Recovery and Circular Economy Act, 2016 (RRCEA).

At its regular meeting on March 26, 2024, Council for the Township of Strong discussed non-eligible source materials outlined in O.Reg. 391/21, with particular attention to the impact on small businesses and local recycling services, and sent a letter to Ministry of Environment, Conservation and Parks to highlight these concerns.

The Township of Strong is a single-tier municipality in the District of Parry Sound. We operate two depot locations, one for Blue Box materials, which are also utilized by the Township of Joly and the Village of Sundridge to provide convenient waste and recycling options for their residents. In rural communities such as ours, small businesses have historically relied on municipal depots for recycling due to the absence of private waste transfer and processing facilities.

Under the current Blue Box regulation (O. Reg. 391/21), small businesses are not entitled to collection services and have depended on voluntary arrangements through Producer Responsibility Organizations (PROs). We are concerned that, without intervention, these services will not continue beyond 2025, leading to increased costs for small businesses and potentially lower waste diversion rates.

The Township supports the proposed amendment authorizing the government to require PROs to offer service agreements for small businesses. We believe this is a critical measure to maintain recycling access and prevent additional financial burdens on the local commercial sector. Our small businesses contribute significantly to the vitality of our community, and maintaining equitable access to recycling services is essential for their ongoing success and for environmental sustainability.

Lack of a Definition for "Small Business"
We wish to draw attention to the fact that the proposed amendment does not provide a formal definition of "small business." Without clear criteria, there may be inconsistencies in eligibility and implementation across the province. We strongly recommend that the Province include a clear, practical definition of "small business" — for example, using size thresholds based on employee count, annual revenue, property type, or municipality size (population) — to ensure consistent, fair access to recycling services and to reduce administrative ambiguity for municipalities and PROs.

Recommendations:

Municipal Engagement:
We recommend that the Province require meaningful municipal consultation in designing and implementing any service agreements to ensure they reflect local needs and operational realities.

Cost Fairness:
We encourage the Province to explore mechanisms that mitigate cost impacts on small businesses, such as standardized service fees or provincial funding support, to avoid shifting new costs onto municipal taxpayers or local businesses.

Clear Communication and Definitions:
We urge the Province to provide clear, accessible guidance to municipalities and small businesses outlining their obligations and available options under any new framework, and to include a clear, province-wide definition of "small business" in regulation.

The Township of Strong is committed to supporting our commercial sector while advancing waste diversion goals. We appreciate the Province’s efforts to strengthen the Blue Box system and ensure continuity of service for small businesses in rural and northern communities.
Thank you for your consideration of these comments.