October 30, 2023 Client…

October 30, 2023

Client Services and Permissions Branch
Ontario Ministry of the Environment, Conservation and Parks

RE: Proposal: Streamlining environmental permissions for waste management systems under the Environmental Activity and Sector Registry

Waste to Resource Ontario (W2RO) appreciates the opportunity to provide feedback on the proposed regulation on environmental permissions. We collected feedback from our members and support the ministries decision to move to a registry model that can provide flexibility and reduce administrative burdens. We are appreciative of any efforts to reduce red tape by the ministry and the move to EASR instead of ECA’s is welcomed.

However, there are a couple of items that need to be considered and accounted for within the regulation, as our members play a vital role in the waste management sector and need to ensure that there is no lasting impact on business operations due to this regulation.

1. Risks Associated with Transfer Stations:
While certain special wastes are not approved for transfer, our members anticipate that some of these materials might inadvertently end up at transfer stations, potentially hidden within construction and demolition (C&D) loads. This raises concerns about increased risks of exposure, non-compliance for Transfer Station operators, and the need for enhanced vigilance to prevent these materials from entering transfer facilities.

2. Landfill Management and Notification:
Special waste materials often need to be properly booked into landfills and direct buried. As the proposal may lead to increased volumes of these materials, there is a concern that they may arrive at landfills without proper advanced notice, insufficient containment, and the potential for increased risks of exposure and non-compliance.

3. Out-of-Province loads & In-Province loads:
Additionally, we appreciate the Ministry's consideration of allowing in-transit storage of waste on vehicles, specifically for Out-of-Province loads. We propose extending this courtesy to In-Province loads as well, especially given the evolving waste management landscape in Ontario. As local landfills close, haulers are required to travel longer distances to dispose of solid waste within the province. This, coupled with shorter operating hours at remaining sites on regular days and even shorter hours on holidays, presents a significant challenge for waste disposal. Allowing overnight storage onboard in a secure industrial terminal yard, as specified, would enable the timely and complete service of residents while addressing these operational challenges.

4. Compliance:
The proposal introduces specific management requirements to mitigate risks to employees and the environment. Our members and industry hold itself by high standards and we want to ensure that all companies alike will be held accountable and compliant to the process. While streamlining registrations through EASR offers benefits in terms of efficiency and cost-effectiveness, there is a concern that new entrants may not operate under the same high standards as established industry leaders. Any potentials that are coming into the industry are not given an unfair advantage, which could lead to inconsistent practices and potential environmental and public safety risks.

In light of the concerns and suggestions raised by our members, we urge the Ministry to carefully consider the potential ramifications of the proposed changes on the waste management sector. Collaborative efforts between the Ministry, industry stakeholders, and W2RO can help address these concerns, strike a balance between efficiency and compliance, and ensure the ongoing success of this change.

Thank you for considering our members feedback and taking the time to address these important matters. We look forward to the continued improvement of waste management practices in Ontario.

If you require any further information or clarification, please do not hesitate to contact:
Ravneet Gill
Waste to Resource Ontario
Manager - Policy & Stakeholder Relations
rgill@w2ro.org
Tel: (416) 674-1542 Ext. 25| Fax: (416) 674-1559
Cell: (905) 460-6611