Comment
Lisa Kingsmore Senior Policy Analyst Ministry of the Environment and Climate Change Climate Change and Environmental Policy Division Resource Recovery Policy Branch 40 St. Clair Avenue West, Floor 8 Toronto Ontario M4V1M2 RE: Comments regarding EBR Registry Number 012-9381 Dear Ms. Kingsmore, On behalf of the Ontario Environment Industry Association (ONEIA), we are appreciative of the opportunity to comment on the proposed Transitional Operational Agreement between the Ministry of Environment and Climate Change (MOECC) and the Resource Productivity and Recovery Authority (Authority). Ontario is home to Canada’s largest group of environment and cleantech companies. The most recent statistics from the federal government show that Ontario’s environment sector employs more than 65,000 people across a range of sub-sectors. This includes firms working in such diverse areas as materials collection and transfer, resource recovery, composting and recycling solutions, alternative energy systems, environmental consulting, brownfield remediation and water treatment – to name just a few. These companies contribute more than $8-billion to the provincial economy, with approximately $1-billion of this amount coming from export earnings. Members of ONEIA are committed to engaging with the Province as it develops policies and regulations that are consistent with our principles of sound science, sound environment and a sound economy. To that end, we convened a working group of ONEIA members drawn from across the Ontario waste services sector to review the Province’s proposed Transitional Operational Agreement as it pertains to the administration of the Waste Free Ontario Act. The biggest concern of ONEIA members with respect to product stewardship programs in Ontario has been the lack of transparency. We are supportive of promoting openness and transparency for the public interest and wholeheartedly support Section 9.7 under the proposed Transitional Operating Agreement, whereby the Authority may canvass stakeholders related to the effectiveness of the Authority’s activities under the Act. Whether these activities are facilitated by an independent third party or by the Authority itself, we believe these actions will improve accountability and transparency within the new framework and by extension the efficiency and effectiveness of stewardship programs. ONEIA is appreciative of the opportunity to provide its comments and suggestions and stands ready to work with the MOECC and the new Authority with the transition and development of regulations for the new producer responsibility framework. Should you have any questions about the information contained herein, please do not hesitate to contact the co-chairs of our committee noted below or the ONEIA office directly at 416-531-7884. Yours truly, Alex Gill Executive Director ON BEHALF OF: Randy Cluff, Brandon Moffatt Co-chairs ONEIA Resource Recovery Committee
[Original Comment ID: 208576]
Submitted June 5, 2019 8:30 AM
Comment on
Proposed Transitional Operating Agreement between the Minister of the Environment and Climate Change and the Resource Productivity and Recovery Authority under the Resource Recovery and Circular Economy Act, 2016
ERO number
012-9381
Comment ID
32105
Commenting on behalf of
Comment status