In the June 3 article published by the Globe and Mail, Environment Minister Yurek has been quoted as saying that despite the pandemic, Ontario’s draft residential Packaging and Printed Paper (PPP) program regulation(s) are still on track to be made public in the coming months. While details are not yet known, municipalities can begin to anticipate what the initial regulation(s) may contain and start preparing for the impact of transition. One example of this could be building out a plan to address ineligible sources of PPP.
Ontario’s current regulation does not require local municipalities with less than 5,000 people to provide Blue Box recycling services, however it does not prevent these communities from voluntarily establishing a Blue Box program and receiving funding. The Blue Box Program Plan excludes non-residential sources such as schools, municipal buildings, public spaces, and Business Improvement Areas (BIA). The Globe and Mail article highlighted concerns with the fact that, over the decades since O.Reg 101/94 was passed, many communities below the population threshold have voluntarily opted to deliver Blue Box recycling services to residents. Under the new regulation(s), Producers may no longer be obliged to provide service to these communities. Many municipalities also collect from non-residential sources, which similarly producers may not be obliged to service under the new IPR arrangement.

Under current system, some small communities and non-residential sites receive service
While not currently required, some municipalities with a population of less than 5,000 offer recycling services to help preserve local landfill space. Often, municipalities that provide recycling services for local parks, schools, public spaces and BIAs do so as it provides the opportunity to deliver consistent servicing and messaging to the resident whether they are at home, school, work or play. It is viewed as an important part of promotion and education (P&E) efforts and a chance to reinforce good recycling habits.

A potential change to service levels
If the new regulation(s) do not require provision of recycling service by Producers to smaller communities or to non-residential sites, municipalities will need to decide whether to continue servicing them at their own cost or to transfer the costs where possible. Given the strain on municipal budgets in the aftermath of COVID-19, local governments will want to understand the financial impact and diversion opportunities now in order to ready themselves for the choices they may need to make as a result of transition. Starting the planning process now will give municipalities time and opportunity to collaborate with all affected parties to help determine potential new collection opportunities.
Engage with stakeholders now to prepare for potential change
Charlotte Ueta, Project Director of Business Transformation (EPR), for City of Toronto, and Erwin Pascual, Manager of Waste Planning for the Region of Peel recommends initiating the planning process as soon as possible to engage with stakeholders to a) make them aware of the potential for change and b) begin developing potential solutions. Their ‘action plan’ advice, while straight forward, requires time to implement. Here’s are some of their tips to help municipalities get started:
Seeking help with planning issues like these? The CIF still has limited funds available through the 2020 REOI for transition related initiatives of a collective benefit, on a first come first served basis. Please contact Jessica Landry to discuss your needs.