Oxford County Submission to the Proposed
Electrical and Electronic Equipment (EEE) and Batteries Regulation
As a municipality committed to achieving zero waste by the year 2025, Oxford County supports any initiative by the Province to help achieve this goal. The County has operated a municipal non-hazardous solid waste facility since 1985. In 2015, the County changed the name of the Oxford County Landfill Site to the Oxford County Waste Management Facility. This name change represents a shift in material handling from primarily garbage disposal to almost 30% diversion of incoming waste from landfill. As a result of this change in material handling, the County’s Waste Management Facility has become a destination point for residents to dispose and divert their waste material. In the interest of good customer service and good environmental stewardship, the County would like to continue being involved in the provincial diversion programs. The County therefore offers the following comments for consideration.
1. Funding for Municipal Collection Sites
Nowhere in the legislation does it speak to municipal involvement in the provision of collection sites. This similar oversight was observed with the Used Tire program resulting in the majority of Ontario municipalities losing program funding for collection site activities. Given that the operational requirements for a used tire collection site is minor, the budget impact of losing tire program funding for the County was considered minimal and therefore, the County deemed it important to remain a collection site for the new tire program.
However, should the Electrical and Electronic Equipment (EEE) and Battery transition program follow the process used for the tires, then Oxford’s budget impact will be more severe for several reasons:
• More real estate will be required to locate the various collection containers needed for each material stream.
• Greater staff resources will be required to ensure that incoming program materials are properly sorted into the correct bin. Under the current program, all electronics go into the same bin and batteries and fluorescent tubes and CFL bulbs are handled through the Household Hazardous Waste Depot.
• Greater staff resources will be required for the administration of the two programs given that the County will have to enter into contracts with additional haulers and processors, as well as, added documentation and retention requirements.
Oxford County realizes that they could choose not to be involved in the new programs as a collection site. But given the County’s long establish diversion depots for electronics, white goods, florescent lighting and batteries, it would be seen a disservice to the residents of Oxford County to eliminate this one stop disposal of waste.
2. Collection Container Requirements
Under the proposed program language, one of the collection methods could be the location of collection containers throughout municipalities. The County’s understanding of this proposed system would be similar to historical practices where a collection container might be found in a parking lot, along a busy street, etc. Previously, a container distribution system (i.e. clothing donations) have been proven to be problematic as there is greater opportunity for material to be scavenged or stolen, there is a lack of service resulting in stock piling and excessive litter making these sites unsightly. The County cautions the Province in encouraging this form of collection system as historical practices have demonstrated them to be problematic due to theft and are unsightly due to material volumes and lack of bin collection.
3. Collection Targets
Oxford County would like to see expanded regulatory and/or guidance language around the issue of collection targets. The concern is what will happen if collection targets are met before the end of the calendar year? The County would like to avoid any landfilling of designated materials under these two programs.
Along with municipal collection sites, several charitable organizations (eg. churches, community groups, youth organizations etc.), which currently collect electronics will see a loss in revenue as a result of the proposed transition. These organizations may be relying more heavily on this revenue to help fund programs they provide to the community.
5. Frequency of Collection
Currently collection of electronics is on an as-needed basis, the regulation states that producers may service sites at least 4 times per year and provide adequate containers at no charge. To uphold service standards, it would be desirable to have more frequent collection so that material does not stock pile.
Oxford County Responses to MECP Posed Questions:
1. The EEE regulation provides a definition for “large-scaled fixed installations” which is intended to exclude large-scale electrical and electronic equipment such as elevators, escalators and streetlights. Is this definition appropriate?
In the County’s view, this definition is appropriate.
2. Does the proposed methodology for each of the producer hierarchies regulate the people in the supply chain who are most responsible for putting the product on the market in Ontario?
Yes, this hierarchy allows the brand holders primarily responsible for recovering the majority of EEE and batteries.
3. Our intention in exempting producers with recovery requirements below a certain threshold from collection and management responsibilities is to reduce burden on small businesses while also limiting the overall exemptions for each category to no more than 1-3 percent of the total weight of material required to be managed in Ontario. Are the proposed thresholds for each category of EEE and batteries appropriate?
No additional input or comment.
4. We are considering what level of auditing is required for a producer’s supply data. The regulations currently propose an audit once every three years for the three-year period. We have also considered a requirement for producers to only audit the first year’s data within the same three-year period. While the second option would result in lower auditing requirements for producers, it would require the Authority to undertake additional inspections for the other two years of supply data. What do you consider to be appropriate audit requirements for supply data and why?
No additional input or comment.
Submitted June 18, 2019 12:57 PM