This comment pertains to the…

This comment pertains to the proposed transition schedule within the draft regulation and a potential anomaly for the transition year proposed for the Municipality of Sioux Lookout.

The Municipality of Sioux Lookout currently operates its Blue Box Recycling Program in partnership with both the City of Dryden and the City of Kenora. Collected Blue Box materials from the Municipality of Sioux Lookout are transported to Dryden where materials are then off loaded at the City of Dryden's recycling depot and further loaded into compactor trailers for transportation to a MRF in Manitoba. The transportation of the compactor trailers from Dryden to Manitoba is provided by the City of Kenora. The Municipality of Sioux Lookout does not own or operate any Blue Box recycling infrastructure such as trucks or compactor trailers to forward collected Blue Box materials out of Sioux Lookout for further processing at a MRF and therefore relies on the partnership with the City of Dryden and the City of Kenora to operate its Blue Box Program.

Currently in the draft regulation, both the City of Dryden and the City of Kenora are proposed to have their Blue Box Programs transition in the year 2023 which has the potential to cause operational issues for the Municipality of Sioux Lookout's Blue Box Program if it does not transition in the same year. A potential conflict could exist for Sioux Lookout to continue to transport and off-load its Blue Box materials in Dryden, where Sioux Lookout's Blue Box materials are co-mingled with Dryden's Blue Box materials, if the City of Dryden is transitioned under the new, full producer responsibility framework and Sioux Lookout is not. In order to ensure the ability for the Municipality of Sioux Lookout to continue to operate its Blue Box Program with the collaboration of the City of Dryden and the City of Kenora it may be better presented to Producers if Sioux Lookout was scheduled to transition in the same year to avoid any potential conflicts. The Municipality of Sioux Lookout cannot operate its Blue Box Program without the assistance of the City of Dryden and the City of Kenora and therefore an aligned transition year for all three (3) locations is presented, which involves changing the proposed transition year for the Municipality of Sioux Lookout from 2025 to 2023. Without knowing how the transition to the full producer responsibility framework will allow for the operations of existing Blue Box programs to continue to operate as they do now, an aligned transition year for municipalities/cites that collaborate for the operation of their Blue Box Programs is presented for consideration.