Ontario ERO – 019-6962…

Ontario ERO – 019-6962 Resource Recovery and Circular Economy Act, 2016

Anyone following the waste crisis over the past 50 years will see this amendment as another delay.
If regulations are too complex for producers, their lawyers and corporate lobbyists, then the province must set clear, simple rules that can be easily overseen and enforced by officials.

Until all levels of government develop a cooperative strategy to eliminate waste, lawyers, consultants, lobbyists, and bureaucrats will continue to work this charade, at the expense of the environment and our resources.

Solving waste from the back end is not working! Explicit waste reduction and reuse regulations, incentives and enforcement for producers and consumers, and political will are needed now.
The province has the ability to ensure a smooth transition toward a circular economy without delay. Officials know what is required to achieve success. It has all been presented before.

Please consider the following recommendations:

The “Resource Recovery and Circular Economy Act”

1. Clarify “Resource Recovery”

The term “Resource Recovery” is used by incineration proponents as an alternate to Incineration or Energy from Waste. It’s called linguistic detoxification - it sounds less toxic and aims to justify burning wasted resources for energy.

Incineration destroys resources forever, contaminates our air, land and water, and expands resource depletion, as producers seek more materials to produce cheap, light weight, single-use products/packaging (especially plastics), so their waste can ‘disappear’ (into our air!).
Private/public landfills create similar problems. Strategies need to aim for an end to disposal.

To protect resources, including the air, land and water, the province needs to it make clear to producers now that incineration is not an option to manage their waste, so producers can plan for materials/programs that eliminate waste and pollution, rather than accelerate end-of-life.

2. A Circular Economy makes Reduction and Reuse top priorities

A Circular Economy includes sharing, leasing, reuse, repair, refurbishing, remanufacturing, and recycling materials as long as possible. Ontario’s 3R’s hierarchy already ranks Reduction and Reuse, before Recycling.

Ontario is more likely to achieve a Circular Economy by requiring that producers adopt reduction and reuse practices now, rather than focusing on recycling targets and end-of-life management.

BLUE BOX COLLECTION

Apparently, transitioning to a full producer responsibility framework, “will not impact how the public receives blue box collection services or diversion targets set by the blue box regulation”.

Yet, the urgency of our waste crisis warrants immediate changes to these services and targets.

For decades, the blue box has been the standard way to divert resources from disposal. Despite this time, effort, and expense, results are pitiful - it still has serious contamination problems, poor diversion rates, high costs, little to no markets, and is not consistent across the province.

In Ontario, less than 10% of materials collected for recycling are actually recycled. Electronic waste has more than tripled in 20 years and less than 20% is recycled.

One County, holding one of the highest diversion rates in the province, reports that “61% of curbside garbage consists of materials that can be diverted in existing diversion programs.” Most IC&I sectors, public facilities and events still offer little to no waste diversion. A similar scenario plays out across the province. It’s no wonder landfills are reaching capacity and disposal costs are rising exponentially.

A new system is needed, one that puts a price on waste materials, rewarding reduction and reuse, in order to achieve more promising waste reduction results.

PROVINCIAL PROMISES

The province claims new regulations will improve the blue box system “by providing consistent service that will reduce litter and allow more materials to be recycled in more communities.”

If the province was serious about this it would have enforced Deposit-Return regulations decades ago, by requiring the beverage industry to refund consumers, and collect and refill containers. Instead, provincial officials ignored industry strategies to phase out refillables.

This left municipal taxpayers responsible for 100% of the costs to collect, sort and find markets for containers. Other producers soon discovered disposables and the rapid influx of garbage, and associated high costs, quickly attracted serious attention.

DEPOSIT-RETURN SYSTEMS (DRS)

DRS work alongside blue box collections and can be used to divert E-Waste, batteries, electronic items and more. Putting a fair price on products/packaging results in successful waste diversion.

Benefits of DRS: reduces litter;
improves community clean-up;
offers education when sorting ‘at the source’;
achieves cleaner materials;
less contamination makes materials more marketable;
collecting items for refunds provides an income for some people; and
people receive a financial incentive to participate.

DESIGNATING “ELIGIBLE PRODUCTS”

The province has listed Beverage Containers as ‘eligible products’, for producers to manage. The province can provide an immediate solution to this waste by requiring the beverage industry to launch DRS on all containers. This should have been done decades ago!
(https://www.tvo.org/article/please-can-ontario-just-implement-a-deposit…).

Introducing DRS will free up the blue box to collect other items i.e., fibers, clothing, etc.

A SERIOUS OMISSION - Disposable Diapers, Hygiene and Incontinence Products
* THESE PRODUCTS DO NOT BELONG IN MUNICIPAL COMPOSTING FACILITIES! *

The province must designate Disposable Diapers, Hygiene and Incontinence Products as “eligible products” for producers to manage.

This multi-billion-dollar industry has the ability to set up special collections at curbside, day cares, senior homes, etc., to separate fibers from sewage and plastic for appropriate recycling.
These products represent a large part of the waste stream. Responsible diversion will keep dangerous pathogens and chemicals from seeping into our air, land and water.

Again, THESE PRODUCTS DO NOT BELONG IN MUNICIPAL COMPOSTING FACILITIES!

INCLUDE INDUSTRIAL, COMMERCIAL, INSTITUTIONAL (IC&I)

New legislation must require all sectors to participate in waste reduction programs.

IC&I generates the most waste. It is essential that the IC&I be included in regulations that require participation in effective waste reduction programs, promotion and education. Public facilities and special events are good places to educate the public and to increase awareness and participation in programs.

PROVINCIAL OVERSIGHT

Producer programs, material destinations, reviews, enforcement and follow-up will help ensure compliance. Shipping materials overseas should not be permitted, since it’s difficult to monitor standards and track responsible reuse or recycling of materials. Resources should remain local.

LEAD BY EXAMPLE

All provincial agencies, offices, facilities, and service providers must lead by example - securing green procurement policies and ensuring that effective waste reduction programs are successful.