Preamble: a) 'Producers'…

Preamble:
a) 'Producers' should be defined as those companies who make packaging material rather than those consuming the material (RPRA is insisting that school boards are Producers). School Boards are funded through taxation (which is the model of funding that the change in recycling services is trying to get away from)
b) 'avoiding cost increases' implies service and supply reduction
Maintaining current services:
a) the right time to expand - this has been a challenge for recycling companies for a considerable amount of years, on the taxpayer funded model
Item 1:
-With time allotted for new investments and infrastructure, recovery targets should be increased across all categories
-Consideration should be given to compostable (in all compost facilities) packaging targets and criteria
Item 2:
-Rather than a reduction in expansion requirements, there needs to be increased expansion and service delivery model for multi-residential units, schools especially where tax payer funded services exist, along with allowing for new facilities (for example, a new public school down the street from a non-public school should be entitled to the same service)
- schools forced to pay for private recycling would be negatively impacted, especially where co-mingled recycling takes place, and diversion rates would significantly decline (schools use source separated recycling as an education tool - students separate into blue boxes and then can visually see the product that is being put to curb)
- Public recycling facilities are necessary and some are in place (recreation centres), however outdoor public spaces are proven to be difficult to enforce recycling
Item 3:
-Recycling for business and ICI covered under 102/94 and 103/94 - if schools are to be designated as PRO's, these regulations need to exempt schools from this requirement
- Beverage containers - with the model shifting away from taxpayers, cost changes likely absorbed through the consumer which can returned through 'incentives'. Beverage containers under a return system for payment can work towards achieving a 100% diversion rate
- Beverage containers supplied for business services is vague
- Diversion targets - should be viewed through the lens of what can be done to increase rates rather than the concern over the producers ability to comply with target rates
Item 5:
- Keep recovery target to 2026
Item 7:
'Best efforts' are not an effective response criteria and are not sufficient to drive diversion until 2031; amending with clarification as stated is necessary
Item 9:
-Clarification needs to be stated that all schools, new and existing, receive PRO funded collection
-where schools pay for recycling collection currently, a system should be in place for PRO repayment to school boards
Item 12:
-Print materials - should be targets set for on-line education, programming, advertising