Dear Ms. Friesen, The County…

Dear Ms. Friesen,

The County of Simcoe appreciates the opportunity to provide feedback on the proposed amendments to four producer responsibility regulations, which include the Tires Regulation (O. Reg. 225/18), the Batteries Regulation (O. Reg. 30/20), the Electrical and Electronic Equipment (EEE) Regulation (O. Reg. 522/20), and the Hazardous and Special Products (HSP) Regulation (O. Reg 449/21) made under the Resource Recovery and Circular Economy Act, 2016 (RRCEA). The County has also reviewed and supports a letter from AMO’s Municipal Resource Recovery and Research Collaborative (M3RC) regarding the proposed amendments.

Overall, the County of Simcoe is supportive of the producer responsibility regulations and understand the importance of amendments to ensure the regulations remain effective. The County’s observations are that the current set of amendments largely benefit producers (e.g. lower accessibility targets, increase in potential reductions, etc.) who are not meeting their requirements as established in the current regulations.

The attached letter summarizes our comments on the proposed amendments. Thank you for the opportunity to provide feedback on the proposed amendments to the four producer responsibility regulations. Please contact the undersigned should you have any questions or require any additional information.

Sincerely,
Rob McCullough
Director, Solid Waste Management