I appreciate the opportunity…

I appreciate the opportunity to comment on this proposal and applaud the government's efforts to improve the Blue Box program. I have concerns with the proposal that are outlined below. Overall, the proposal, as currently drafted, does not sufficiently ensure that the government and producers are committed to contributing to a circular economy and a recycling a reasonable percentage of plastics and packaging that are produced. Here are my key concerns with this proposal:

- Proposal would allow producers to set their own rules for the program which does not allow for accountability and robust enforcement

- Producer Responsibility Organizations (PROs) would be “engaged” by the producers which means they would be accountable to those organizations and not the government and Ontarians

- Administrative penalties regulation to give the Authority enforcement powers is expected to be consulted on at a later date. Why? How does it fit together with the proposed legislation and interact with the rules that the producers will be setting?

- Overall, the fact that this proposal would extend the blue box program to all Ontario communities and ensure it is consistent across the province is positive.

I am also concerned that the Recycling Council of Ontario and 6 other environmental groups issued a joint statement on this proposal which outlined several concerns but mainly that, "As drafted, the proposed regulation locks Ontario into years of poor performance." I put forward my support for these additional comments provided by this coalition in their statement and encourage the government to consult with these organizations on how the proposal can be improved. At a minimum, Ontario needs to:

Include plastics and packaging that are created by the business and industrial sectors, which are responsible for nearly two-thirds of Ontario’s waste generation and disposal;

Set high and detailed diversion targets to ensure producers can’t ignore the hardest-to-recycle materials and to encourage reduction and redesign;

Include specific recycling standards to make sure that materials are going to the highest and most valuable uses, and are free from toxic chemicals and additives;

Include mechanisms to prevent toxic substances from contaminating recycling systems and recycled materials; and

Ensure that comprehensive and standardized recycling is available for all Ontarians, no matter where they live, work, and play.

Thank you again for the opportunity to comment.