The Role of the Ministry of…

The Role of the Ministry of Environment, Conservation, and Parks and the Resource Productivity and Recovery Authority

The Waste-Free Ontario Act (WFOA) established the Resource Productivity and Resource Authority (RPRA) with two key functions:

• data collection; and
• management through the establishment of a registrar, and oversight and enforcement of the requirements of WFOA.

The Minister also has the ability to assign RPRA responsibilities under the WFOA or any other act.

There is a strong rationale for transferring data collection, oversight, and enforcement functions to support effective producer responsibility activities from government to a delegated authority as the WFOA has done. Ensuring sufficient and dedicated resources are protected for the purpose of compliance is important for the objectives of the legislation to be achieved, and to ensure level playing field for all those obligated under the WFOA.

Transparency and Accountability

ERO number: 019-0774 and ERO number: 019-0671 both intend to revise and expand RPRA’s role to additional activities beyond those related to producer responsibility related to resource recovery or waste as directed by government.

In doing so, it is essential that clear and distinct roles between RPRA and the government is
established and maintained. Ensuring transparency and accountability of each organization’s activities further strengthens the effectiveness of the systems created under the WFOA. This is particularly true as it relates to the data and other information collected through the registry that could be used to inform compliance, performance, and future policy.

In that regard, we recommend all activities undertaken by government and that are not defined as proprietary in nature be subject to the Environmental Bill of Rights (EBR) and Freedom of Information and Privacy Act.

Furthermore, while the Ministry may post directives and order for RPRA on the EBR, there are no requirements for RPRA to share information on the EBR or to the public. It is our view that affected stakeholders and the public at large should have immediate access to information gathered through activities implemented under the WFOA or any other act that may inform or affect improved future resource management.

Thank you for your consideration, and we are pleased to discuss the contents of this submission at your convenience.