The City of Mississauga has…

The City of Mississauga has reviewed the draft regulations for the blue box program and commend your commitment to make producers responsible for operating blue box programs. We support your interest in providing consistency across all Ontario municipalities which we believe will limit confusion for residents about what can be recycled and will hold producers accountable for the blue box materials they create. We think this will help increase both recycling and waste diversion rates across the province. We also wanted to take this opportunity to thank you for the inclusion of parks and public spaces as eligible sources. With this in mind, we do have a few specific comments related to the draft regulations which are outlined below.

1. Definitions
“Public Spaces”
The City of Mississauga recommends expanding the definition of public spaces to include all public spaces, both indoor (e.g. recreation/community centres, libraries, transit terminals, and public facing municipal facilities) and outdoor public spaces (e.g. all parks, boulevards, public squares, transit terminals, transit shelters and transit stops). Residents currently use recycling receptacles in these locations to place their blue box materials when they travel to and from their home and when they visit public spaces.

In addition, the definition as currently written can be interpreted as declaring only municipal parks, playgrounds or outdoor areas located within a Business Improvement Area as eligible sources. As noted above, it is the City’s recommendation that the eligible sources include all public spaces, indoor and outdoor.

“Parks”
In the draft regulations, “parks” are not defined. The City of Mississauga recommends that a definition of a “park” be included in the list of definitions. For example, Mississauga’s City Parks By-Law 186-05 defines a park as:

““Park” means the land, including any body of water, buildings or structures located therein, that is owned by or made available to the City by lease, agreement, or otherwise, and that is established, dedicated, set apart or made available for use as public open space; but does not include a marina, golf course, or cemetery; (281-11)

“Facility”
The City of Mississauga recommends expanding the definition of a “facility” to include municipal public indoor locations to the list of eligible sources (e.g. recreation/community centres, libraries, transit terminals, public facing municipal facilities). Additionally, the definition of facility should include fire stations as they are typically located along residential collection routes and generate blue box materials consistent with residential areas.

2. Clarification
The City of Mississauga agrees with the requirement for recycling receptacles to be located where garbage containers are provided to encourage the proper placement of waste in the proper waste receptacles and to help increase capture rates. We are seeking clarification regarding Section 25 of the proposed regulation which states “A producer who collects blue box materials from public spaces shall, (a) ensure that blue box receptacles for the storage of blue box material are placed next to every receptacle for garbage at the public space, (b) provide for the collection of blue box material which is in a blue box receptacle located next to a receptacle for garbage”.

We require clarification that dual stream split garbage and recycling containers where both garbage and recycling are collected separately but from a single container apply to the regulations and can be used as the blue box receptacles as outlined in (a) and (b) above rather than removing all of the dual stream containers and replacing them with garbage-only containers.

3. Designated Materials
The City of Mississauga is supportive of the broad range of goods designated that producers will have to collect and manage including paper, metal, glass, plastic, or any combination of these materials. The province’s choice to include these items will align Ontario’s list of materials with those regulated under British Columbia’s producer responsibility program. This is a positive sign of more cross-country harmonization on producer responsibility regulations, consistent with the federal initiatives in this area.

Citing challenges with determining proper management approaches for compostable materials, the new regulation imposes registration and reporting obligations with respect to compostable materials but does not mandate collection or management requirements. The City of Mississauga recommends that the Ministry apply collection and management requirements at the earliest opportunity for compostable materials and packages, especially since producers are likely to introduce more compostable packaging into the market.

The City of Mississauga is willing to work with the Province, producers and other municipalities to make this transition as easy as possible and to ensure our residents have a robust and easy-to-understand new recycling system.