Please note the following…

Please note the following comments in regards to the proposed regulation:

1. The current transition schedule included with the draft regulation does not specify all municipalities by name, and in some cases has allocated municipalities through Associations (i.e. Bluewater Recycling Association). It is requested that all municipalities with existing recycling programs be individually listed within the transition schedule. For instance, if municipalities were allocated a transition schedule of 2024 being listed under an association, the municipalities should be individually listed for that date for clarity.

2. Some municipalities leverage automated, single stream recycling programs at the present time, while other municipalities offer separate stream collection programs (i.e. all materials intermingled within a collection container or sorted at curbside by residents). The proposed regulation should require existing service delivery standards of this nature be maintained.

3. Compostable items should be more clearly defined within the Regulation, and to exclude fibre based products that can be recycled. Without a clearly defined definition, producers could market products or packaging as compostable, which could shift costs back to municipalities, for instance green bin programs or for smaller municipalities that do not have green bin programs, waste costs.

4. Depot recycling collection is a vital component to existing service delivery standards. Under the proposed regulation, the requirement for producers to provide depot collection is removed following transition by 2026. This would be seen as a service reduction. Current depots, such as those located at municipal landfills, or in downtown commercial cores offer a great and convenient means for residents to dispose of material, while also offering a convenient collection means for producers. The regulation should be amended to maintain depots following the transition period should Municipalities have such means in place already.