Commentaire
This Regulation is very important to the waste management industry to fix the monopsonistic activities of Stewardship IFOs and ISPs.
Paramount items
You do NOT know the trust I have put into this Reg finally getting it right for the waste industry - the Ministry must really understand these issues the Service Provider sector is highlighting - the investment does not come from the sale of these products but rather by the waste management sector employing and managing these wastes - very few producers remain in the province now except for some distribution warehousing and retail employment
1-100% collected and managed must be funded - targets are necessary and exceeding collection targets require this certainty for Service Providers these will be funded not discouraged or not paid
2-Regulation must acknowledge the Regulation is compliant with the federal Competitions Act - not a Regulatory Defence to unfairly exert market dominance
3- The Authority has 2 Procedural sections - these need to be better defined in a framework of key elements - flexible but a guide of overarching elements - also, the authority should develop these principle details with the Producers and the Service Providers
4-Producers MUST SUBMIT QUARTERLY TO THE AUTHORITY to map out their progress and to ensure that Service Providers are not left managing these responsibilities on the Producers behalf - this WIL HAPPEN without interim submissions - Also awaiting for 18 months for first rep[ort is unacceptable - NO BUSINESS RUNS WITH REPORTING 18 MONTHS AFTER IT BEGAN - Such a manger would be fired - THIS IS DOABLE - THE SERVICE PROVIDERS DO ALL OF THE REPORT PREP ANYWAY - MAKE THEM REPORT IT TO RPRA PLS - I am concerned for our waste management industry if you do not
5- "Circular Economy" needs to be supported with imposed reuse buy producers - mandating and incentivizing reuse of product - eg all paint should need a post consumer content to it just like paper - Producers use ReWork all the time - make them integrate into the product otherwise "Circular" that should look like a circle (ie circular) "O".... only looks like a "C" - circle unclosed -even though it is the beginning letter for "Circular-" its just in the word not in the function - this is DOABLE - I've worked in a paint recycling company - don't let the paint associations say it is not - pls make this missing link happen for paint and any other suitable products (eg antifreeze but not pesticides)
6- What is the Ministry hoping to do to make more competition amongst PROs - no lead time to the Reg- ie July 1 - means that the incumbents WILL DOMINATE this space - they currently also have all of the pricing, customer lists, and rates for EVERYONE- what chance does another PRO have moving into this space - not a level playing field - info should be shared upon request by IFOs and ISPs
7- ECA facilities are key to the HSP program - these are NOT like electronics and tires and blue box and even batteries that can be collected and "piled up in the corner" - We need ECAs to manage these materials and this should NOT be downgraded because it is an EPR program - Producers must be required to file for same ECAs as the rest of the industry for the management of these materials or use the existing network of ECAs - TSDFs. In the past Regulation the IFOs dismissed the Transfer Facilities as "transporters" - these facilities are key ingredient in the properly trained staff and management of these HSP products
8 Other details in my attachment - I implore that you strongly consider these elements
thank you for your consideration - sincerely
Supporting documents
Soumis le 28 mars 2021 7:37 PM
Commentaire sur
Proposition de règlement sur la responsabilité des producteurs à l’égard des produits dangereux et spéciaux (PDS)
Numéro du REO
019-2836
Identifiant (ID) du commentaire
52928
Commentaire fait au nom
Statut du commentaire