The following comments are…

The following comments are provided by CSR for your consideration. Positive Aspects of the Document 1) CSR supports the acknowledgement in the document of the overriding Waste Management Principles: - Environmental protection is a shared responsibility - Integrated waste management systems that reflect the local circumstances - Waste management choices consider economic, social and environment - Producer responsibility is incorporated into waste management - Maximum value from waste is recovered from the waste stream 2) CSR supports the overall direction with the policy direction and guidelines in the area of municipal waste planning. The draft documents outlines strategic directions that industry supports including; - the need for integrated waste management planning - the recognition that thermal treatment is an acceptable option for municipalities - encouraging that municipalities cooperate to seek efficient waste management solutions - a considerable focus on the need for municipalities to have good waste generation, diversion, disposal and composition data both in the planning stages (3.4) and regarding ongoing monitoring and reporting (3.11). This supports and compliments the efforts of organizations such as WDO and Stewardship Ontario to establish sound and comprehensive data practices. Additional Comments CSR would like to submit to the MOE 1) The MOE continues to refer to thermal treatment as a disposal option. In many jurisdictions, thermal treatment is identified as a waste processing or treatment option and not simply as a disposal option. The output from thermal treatment systems often require final disposal (e.g. fly and bottom ash). 2) The Province is likely one of the largest generators of waste in the province in terms of municipal waste (office waste, maintenance yards, operations, cafeterias etc.), construction, renovation and demolition waste and municipal hazardous or special waste (e.g fluorescent tubes, automotive wastes including used oil, tire etc.). It is therefore important for the table on page 13 that identifies roles and responsibilities that under “the province” that the following points be added: - Takes a leadership role in reducing and diverting from disposal waste generated through provincial government and agency operations - Take a leadership role in procurement products and services that minimize the life-cycle impacts of products and their packaging 3) CSR is surprised WDO is largely absent from the document, and is only referred to in a general way. Given that the WDO has a key role to play in the development and monitoring of industry stewardship programs for wastes that are managed by municipalities, we would have expected a more formal and explicit role for the WDO. 4) Would recommend that that “cooperation among municipalities” somehow be incorporated as part of the minimum recommended plan content section, and not simply a suggestion. Making this a requirement may identify practical opportunities for municipalities to cooperate including, but not limited to, combined purchasing of equipment to obtain lower per unit costs, sharing of specialized equipment, and utilizing existing or new recycling facilities to achieve greater economies of scale.

[Original Comment ID: 103654]