Comments

Standard 1. A 3 year sales average is ok. 0.85 adjustment factor is a bit low as is 60%by weight recovery...they can do better. On large tires over 39 inches I'm certain that recovery could easily be 95%. And a carry over to the next year is just asking for administration nightmares and fraud.

Sent via email lisa.kingsmore@ontario.ca

Submission regarding the new Used Tire Program of Tire Stewardship Regulation under the RRCEA.

North West Rubber Ltd. supports the draft regulation in principle and will provide commentary to the Ministry via a letter to assist in improving the draft regulation.

[Original Comment ID: 212173]

Lisa Kingsmore
Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Resource Recovery and Policy Branch
40 St. Clair Avenue West
Floor 8
Toronto, Ontario
M4V 1M2

Thank you for the opportunity to submit feedback regarding the proposed Used Tires Regulation (“draft Reg”).

Comments Regarding the Draft Tire Regulation under the Resource Recovery and Circular Economy Act, 2016