Prior to proceeding with…

Prior to proceeding with these changes, OWMA recommends that the Ministry of Environment, Conservation and Parks produce additional documents and amendments for the proposal to provide the following two very important assurances (Our recommendations below are described in more detail in the enclosed supporting document letter):

1. That new requirements for advanced recycling facilities will not establish a framework that will simply see recyclable materials being redirected from current users, which include other material recovery facilities (MRFs), mechanical plastics processors and tire recycling facilities.

OWMA recommends that further policy explanation be provided on how these new requirements will not redirect recyclable materials away from MRFs, mechanical plastics processors, and tire recycling facilities. The Ministry should consider a regulatory requirement that advanced recycling facilities only source their feedstock from processed residual streams from MRFs, mechanical plastics processors, and tire recycling facilities, and/or from separate streams of difficult-to-recycle materials, as a condition of being eligible for these proposed requirements.

2. That these new requirements will not negatively impact or include anaerobic digestion technologies (AD) into a thermal treatment regulation. The ministry’s background documents for this proposal state that that any facility that does not meet the classification of advanced recycling will remain under the current environmental assessment regulatory requirements.

To provide improved clarity, OWMA recommends this proposal be amended to explicitly exclude anaerobic digestion and composting under the regulation, and more clearly define the technological process that are captured under this regulatory proposal.