2025-07-21 The Corporation…

2025-07-21

The Corporation of the Town of Petawawa (Town) is pleased to submit comments pertaining to the proposed amendments to the Resource Recovery and Circular Economy Act, ERO # 025-0536.

Upon reviewing the available information, it is understood that the purpose of the proposed amendments is to strengthen Ontario’s blue box program by improving transparency, cost disclosure, and collection of materials by allowing the producer responsibility framework to be more responsive to the needs of businesses and identify savings to help drive blue box costs down.

Item #1: Gathering information to assess system effectiveness and plan future changes, and Item #2: Increasing transparency on costs and system data
It is stated that these proposed amendments are to “…understand the problems and make the right changes, the ministry needs more information on blue box system design, operation, and costs. Currently, much of this information is not available to government under the regulation. Addressing this information gap is critical to being able to assess the effectiveness of the regulation and propose amendments that drive cost containment while maintaining blue box services for residents.”

It was promoted that transition to an extended producer responsibility (EPR) model would be more efficient and cost effective than compared to the former shared model, and now we are learning that the producers are experiencing unanticipated cost increases, as stated in ERO #025-0009. It is surprising to learn that key information on system effectiveness and cost transparency is not currently part of the act and regulation. Therefore, our municipality supports any effort to mandate reporting of key information and data so that there is transparency and accountability to the Ontario government, producers and waste generators, and further to support the decision by the Ontario government to transition the province’s recycling program to an EPR funded model that was promoted to be more efficient and cost-effective and deliver better recovery rates than under the previous shared model.

Item #3: Maintaining collection for small businesses
Firstly, the Ontario government will need to expedite their decision on this proposed amendment to maintain collection for small businesses as municipalities have been very busy planning and preparing for this blue box transition and the impacts it is having on existing municipal waste collection programs, including if a municipality has to de-couple or discontinue any currently provided co-collection service of recyclable materials for eligible and non-eligible sources. This has required a significant level of effort for municipal staff in addition to municipalities needing sufficient time so that they are ready to implement changes to their existing waste collection programs by January 1, 2026, being the start of the new blue box common collection system with a harmonized material list under the new EPR funded model.

Secondly, the proposed amendment to maintain collection service for small businesses is highly supported. Many smaller non-eligible sources such as businesses, community/municipal buildings, daycares, places of worship, private schools, campgrounds, private long-term care and retirement homes, etc. typically generate about the same amount of recycling that an average residential source generates and are typically located along curbside collection routes with little to no difference in the level of effort for curbside collection. It makes no sense as to why smaller non-eligible sources were excluded under the former shared model and continue to be excluded under the new EPR funded model.

Our municipality has been providing a harmonized four (4) stream curbside collection service to both our eligible and smaller non-eligible sources for years which has proven to be an efficient and cost-effective service that is affordable to our residents and businesses. The blue box transition to an EPR funded model will create separated waste collection service for our residents and businesses, and this separation of service will lead to confusion, inefficiencies and increased costs for all.

The Ontario government should be considering amendments to the act and regulation that would see the inclusion of smaller non-eligible sources into the EPR funded model, as opposed to having municipalities and producer responsible organizations (PROs) negotiate commercial agreements with costs borne by municipalities as proposed in this amendment. The goal of the Ontario government should be to divert as much recyclable material from landfills as possible, especially at a time when Ontario landfills are filing up at increasing rates given the population growth in Ontario and further complicated by the fact that developing new or expanding existing landfills in Ontario is near impossible because of Provincial and Federal regulations. Simply put, if the material is recyclable than it should not matter who the waste generator source is.