The County of Dufferin is…

The County of Dufferin is pleased to submit comments on the Ministry’s proposed regulation, and proposed regulatory amendments, to make producers responsible for operating blue box programs. We thank the MECP Minister and Ministry staff for their ongoing commitment and hard work on this file.

An ERO submission has been made by the joint group of AMO, Toronto, RPWCO and MWA, in which the County of Dufferin is in strong support. The County would like to highlight a few specific areas in our comments.

First, we reiterate that the core policy components found in the draft regulation should be maintained:

• Establishment of a province-wide common collection system
• An enhanced and standardized list of materials
• High, progressive and enforceable targets
• Certainty for planning to ensure a seamless transition
• Removing burden from municipal budgets at a time when it is needed more than ever

As highlighted in the AMO/Toronto/RPWCO/MWA submission, we agree that there are some areas in the draft regulation that are problematic and require amendment/attention. Specifically, the County has further comments as noted below.

Compostable materials:
We strongly reiterate that compostable materials must not be exempt from collection and management requirements (i.e. amend section 2(2) and 2(3)). A separate target for compostable materials must be established based on progressive targets similar to those used for other lower performing materials like flexible plastic. As a municipality with a long-standing Green Bin organics program, we are concerned that some producers will shift their packaging to “compostable” materials, and hence municipal taxpayers will continue to pay for the processing of packaging that should be the responsibility of the producer.

Transition timeline:
For many municipalities, their contract expiry dates do not follow a quarterly configuration. We request that the final transition schedule contain a more specific date than quarterly to ensure municipal service contracts do not expire before producers become responsible. By aligning transition to a specific date (for the County that would be June 1, 2023), a more seamless transition to blue box responsibility by producers can be achieved, while maintaining the integrity of the County’s integrated waste management system.

IC&I servicing:
Within the County’s integrated waste management system, IC&I locations are able to access collection and processing services as long as they meet our Waste By-law. The County understands that most IC&I sources are out-of-scope within this regulation, however we are concerned about the ability of small businesses, charities, faith-based organizations etc. being able to access recycling services post-transition. We would strongly advise the province to ensure that these entities can continue to receive servicing through other means (e.g. a fee per service mutual agreement between producers and municipalities). This will help to prevent backsliding of all the efforts these locations have achieved in diverting recyclables from landfill, in an economical manner. The County also looks forward to the upcoming consultation on an IC&I waste framework, as great gains can be achieved with further effort around IC&I waste diversion.

Regulatory Timeline:
The County encourages the province to move this regulation forward without delay, and to maintain the implementation timelines set out in the draft regulation. With a set timeline, the parties will have the time and structure to prepare for the necessary changes.

Thank you for the opportunity to comment.