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Waste Diversion 01

Draft Preliminary R For Consultatic

Blue Box Program Plai

Draft for Consultation - February 6, 2009

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Purpose of This Draft Preliminary Report for Consultation

This draft preliminary report includes a set of draft recommendations in response to the Minister’s request to undertake a review of the Blue Box Program Plan. These recommendations were developed on the basis of the range of stakeholder comments received through the public opinion survey, stakeholder meetings, written submissions and discussions at the Municipal Industry Program Committee (MIPC) of Waste Diversion Ontario (WDO).

Where there was general agreement among stakeholders, the draft recommendations are intended to be representative of stakeholders’ comments.

Where there was not general agreement among stakeholders, the draft recommendations propose an approach that responds to the Minister’s questions while considering stakeholder concerns.

This draft report, and the draft recommendations it contains, are presented for the purposes of additional consultation with stakeholders.

Sections 1 through 6 of this report are presented in the anticipated format of the final report to the Minister of the Environment to provide stakeholders with the opportunity to consult on the draft recommendations.

The appendices are additional information provided in this draft report for consultation purposes. The appendices will be removed prior to submission of the report with recommendations to the Minister.

Stakeholders reviewing this report may also wish to refer to the Backgrounder to Support a Review of the Blue Box Program Plan available on WDOs website which contains information on each of the ten issues raised in the Minister’s correspondence to WDO.

Drafl for Consultation - February 6,2009

Table of Contents

1 .O Background

2.0 Minister's Request for Blue Box Program Pian Review

3.0 Consultation Process

4.0 Extended Producer Responsibility

4.1 Defining Extended Producer Responsibility

4.2 Extended Producer Responsibility Principles

4.3 Shaping the Review Framework

5.0 Summary of Issues Identified in Consultation Process

5.1 Different Perspectives

5.2 Key Themes

6.1 Existing Blue Box System

6.0 Draft Recommendations

Program Performance

Material Specific Performance

Consistency Across Municipalities

Problematic Wastes

Environmentally Responsible Management

Stewardship Fees

EPR Funding

Changing the Scope of the Blue Box System

Blue Box Wastes from the IC&l Sector

Blue Box Wastes Collected Outside of the Blue Box

Additional Blue Box Wastes

6.2

Appendix A CCME EPR Principles

Appendix B

Appendix C

Calculated Quantity Recycled if Material Specific Targets Are Achieved

Examples of Performance Targets in Other Jurisdictions

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1

2 2

2

3

3

4

4

6

6

7

a 10

12

13

14

16

17

19

19

21

23

25

27

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Draft Preliminary Report for Consultation Review of the Blue Box Program Plan

1 .O Background

Waste Diversion Ontario (WDO) is a non-crown corporation created under the Waste Diversion Act (WDA) on June 27, 2002. WDO was established to develop, implement and operate waste diversion programs for a wide range of materials. The WDA empowers the Minister to designate a material for which a waste diversion program is to be established. Once the Minister has designated a material through a regulation under the WDA, the Minister asks WDO to develop a diversion program. WDO is required by the Act to work co-operatively with an Industry Funding Organization to develop a waste

Electrical and

used oil filters in Minister set aside this designation when the MHSW designation.

The Blue Box Program Plan (BBPP) was 2003 and commenced on Fe Funding Organization with who

the Honourable John onduct a review of ten

the principles of extended Minister directed that the

BBPP review

overnment organizations.

by March 20,2009 that: t was completed, including stakeholder

s regarding the BBPP issues, including the rationale for such as key arguments made during stakeholder

producer responsibility principles shaped the framework ed the recommendations.

The report submitted by WDO to the Minister is comprised of two volumes: a separate document titled Report on Consultation to Support Review of the Blue Box Program Plan that summarizes the BBPP review process including the stakeholder consultation; and this document which includes draft recommendations regarding the BBPP issues and the rationale for these recommendations and indicates how EPR principles shared the review framework and informed the recommendations.

Draft for Consultation - February 6,2009 1


3.0 Consultation Process

WDO has implemented a consultation process that, to date, has included: public focus groups and opinion survey: one day meetings with five stakeholder groups:

o municipalities o Stewardship Ontario Board o Ontario Waste Management Association Board and members o Industries representatives o non-government organizations:

two day meeting of the Municipal Industry P Blue Box Program Plan; and written submissions.

Committee (MIPC) for the

submissions received prior to December Support Review of the Blue Box Program

Posting of this draft report for consultation process. A consultation wor this draft preliminary report.

Consultation to

4.0 Extended

developed by the Canadian Council d as a starting point for purposes of

means an .environmental policy

ed that this definition is too vague to be helpful in

r's responsibility: and consumer stage of a product's life cycle.

With respect to the scope of the producer's responsibility, stakeholder comments suggest that a producer's responsibility under EPR can be limited to financial responsibility for the management of products and packaging, as in the shared responsibility model. or can also include physical responsibility for the management of products and packaging, including responsibility for achieving program performance objectives, as in the full responsibility model.


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With respect to the scope of the post-consumer stage of a product's life cycle, stakeholder comments suggest that a producer's responsibility under EPR can include some or ail of the following:

reduction in o the quantity of (primary or secondary) materials (weight andlor volume)

used to manufacture a product or package, andlor o the toxicity or other characteristics that affect the environmental impact of

the product or package: reuse of the product or package; recycling of the product or package; recovery of energy from the product or packa landfiiling of the product or package.

4.2 Extended Producer Responsi

clarification of the CCME princi

text in Principle 3 may

ms can be designed to encourage nment to minimize impacts to

holders. Replacing the phrase 'without eaning of the principle:

iew Framework

The Minister directed WDO to undertake the BBPP review using the principles of extended producer responsibility to form the review framework.

The definition of EPR and EPR principles developed by CCME were utilized as starting points for purposes of the consultation process. Discussions during the consultation meetings considered:

setting targets, establishing a consistent list of materials, addressing problematic wastes, ensuring environmentally responsible management and options to utilize

Draft for Consultation - Februaty 6, 2009 3

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the fee setting methodology within the context of the existing BBPP under full EPR; and utilizing EPR to expand the scope of the BBPP to address Blue Box materials from the IC&l sector, in the garbage and litter stream and a wider definition of Blue Box materials.

Some stakeholder comments are relevant only under fuii EPR. For example, municipalities indicated certain activities that are not reflected in existing service provider contracts or have financial implications for the Blue Box system should be deferred until fuii EPR is in place. *

Other stakeholder comments were provided on the b2 scenario for the Blue Box Program Pian. Stakehoi review and recognize that amendments to Box Program Pian shared responsibility mod be rz

so participating in the WDA 's the basis for the Blue

to establish full EPR.

5.0 Summary of issues ldenti

5.1 Different Perspectives

Consultation with stakehoide contrasting perspectives on key key differences in perspective am

Shared Responsibi

The shared res a partnership bet ,

municioalities man:

iat full EPR is one Dossibie

aragraphs outline some of the

bBPP and was designed as

the shared responsibility model remains mers engaged in waste diversion and is

their view. the shared resoonsibilitv model is not an eaual ' contribution has been' less thHn 50% and b e c a k

-of-life handling issues faced by municipalities when

Role of Stewards onde?h// EPR

industry indicated that, under full EPR, stewards would be entitled to control the Blue Box system design and operation.

Other stakeholders raised concerns that industry will seek the lowest cost system design which may not yield the desired environmental objectives. These stakeholders believe that industry must be held accountable by operating within provincial regulation andlor policy direction and that it may be necessary for municipalities to deliver curbside collection services to ensure reasonable service levels for residents.

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Driving More Diversion

Industry indicated that it would drive diversion where it is most cost effective through focusing on the 'next least cost tonne'.

Municipalities indicated they want more diversion in order to reduce garbage and litter and raised concerns that the 'next least cost tonne' approach will not address the disposal problems or litter problems municipalities currently manage.

Other stakeholders indicated they want more diversion in order to achieve broader environmental objectives and to drive Ontario's gr onomy using secondary resources.

Need for Flexibility

Stakeholders generally agreed on the n under full EPR for Blue Box wastes. flexibility varied among stakeholders.

cost efficient system

materials to collect.

ithin defined program nd accessibility targets try could design a cost

rather the 'next least cost

litter are behaviour problems that are . As industly believes it cannot affect

e should have no responsibility for garbage and

Industry reported that, in their view, they have no control over consumers and that education of residential generators should be done by municipalities.

Other stakeholders reported that, in their view, industry effectively markets products and packages to consumers and should therefore also be able to effectively market diversion to residential generators.

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5.2 Key Themes

Readiness to engage in discussion on the BBPP review issues differed among stakeholders. Industry representatives asked for additional information on which to base their consultation comments including a rigorous analysis of the shared responsibility model and costlbenefit analyses of alternative models. Municipal representatives differed in their level of concern about industry control of the Blue Box system and therefore their willingness to have industry assume control over collection.

avoid media risk to industry brands.

to ensure consistency in materials col ways to handle problematic wastes a diversion.

Some stakeholders expressed

re these materials are

collection and processing

ut management of Blue Box materials keholders disagreed about the role of

a cost effective system; other environmental and social objectives; and regional differences across Ontario: and

a free marketplace and intervention to achieve policy objectives.

6.0 Draft Recommendations

The Minister directed WDO to undertake the BBPP review using the principles of extended producer responsibility to form the review framework. For many stakeholders, considering the BBPP within the framework of EPR represented a move to privatize residential Blue Box services that have historically been delivered as a public service in Ontario. While industry has contributed to the early Blue Box system capital investments



and more recently, through the shared responsibility model, to system operating costs, the Blue Box system continues to be viewed as a public sewice.

The following sections present draft recommendations on each of the ten issues raised by the Minister in two categories:

0 draft recommendations related to the existing municipally operated Blue Box system including:

o program performance; o material specific targets; o consistency of materials across municipal o problematic wastes; o environmentally responsible manag o stewardship fees; o moving to full EPR; and

include: o Blue Box materials from o Blue Box wastes remain

are linked, a notation is provided to 'see al

ted to the existing municipally operated

Where recomm linked, a notation is provided to 'see also Draft Recornmendatio

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Program Performance

The BBPP has reached its 60% waste diversion target. A new target may encourage further increases in wasta diversion. Recommend a new target for the next 5 years of the BBPP that goes beyond the 60% target ofiginalry set for the 2004-2008 period.

Rationale for Draft Recommendations

Some stakeholders suggested that targets should not be set in advance of the MOE establishing environmental and economic goals, ssessment of the barriers to increased diversion under the BBPP and assessment of the cost implications of collecting and processing additiona

Other stakeholders suggested that a hig efforts to increase diversion, noting that m materials remaining in the garbage strea

End markets suggested that program from processing at end markets. Measuri portion that is utilized in new municipalities would be a more

Some stakehold and should not

BBPP would drive

ntial Blue Box materials

70% proposed by industry

ocuses only on residential Blue Box entia1 Blue Box materials managed by rangement results in some residential

ty has been addressed by proposing to include Blue

printed papers and packaging while an industry funding organization (IFO) is responsible for recycling, rather than diversion of these materials. These stakeholders suggested presentation of program performance targets in terms of collection and recycling, rather than diversion.

Some stakeholders suggested that additional Blue Box materials can be sorted from processing residues from Blue Box material recycling facilities (MRFs) if these materials

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were directed to a 'dirty MRF" for additional sorting. It was also suggested that 'ditty MRFs could be utilized to process residues from end markets and recyclable materials collected in public space recycling systems if these materials are too contaminated to process in a regular Blue Box MRF and to process garbage collected through public space waste systems as this stream often contains a significant portion of recyclable materials. As one of the products of a 'dirty MRF' is a fuel pellet, it was also suggested that a target for energy recovety be incorporated into the Blue Box Program Plan to reflect the portion of Blue Box materials that would be incorporated into the fuel pellets. (See also Draft Recommendation # 19.)

The rationale for the draft recommendations is: to provide a response to the Minister's req years of the BBPP; to include residential Blue Box collection systems in the BBPP program's performance targets; to set targets that fall within recycling target slightly above t slightly below the top of the range; to reflect the recomme materials remaining in

ew target for the next five

0

Draft Recommen

performance targets2:

3, # 17 and # 18); and o comprised of materials for which 3Rs

nically feasible (see also Draft Recommendation

A 'dirty MRF' is a material recycling facility that accepts and processes mixed waste and/or highly contaminated recyclable materials rather than fuiiy source separated recyclable materials,

Refer to Appendix C for Examples of Performance Targets in Other Jurisdictions. Materials collected will be processed with some loss to residue. A collection target is therefore

higher than a recycling target to account for processing residue. 4The recycling target of 75% is based on materials marketed for consistency with the existing target of 60% and the 2007 recycling rate of 63%. The proposed 65% collection target and the proposed 75% recycling target would be reviewed following implementation of Draft Recommendations # 2 and # 3, when the 2007 recycling rate of 63% can be expressed on the basis of ail sources of residential materials rather than soieiy municipal collection systems and materials utilized in new products rather than materials marketed by municipalities.

2

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Draft Recommendation # 2

To improve the methodology to calculate the quantity collected by incorporating the following collection systems for residential Blue Box materials in the Blue Box Program Plan and by counting the residential Blue Box tonnes collected towards the collection target:

collected from residential generators by municipalities reported via the Municipal Datacall; collected from residential generators by stewards reported via steward reports to Stewardship Ontario; collected from residential generators by ret . grocery store carry out bags); collected from multi-unit buildings direct1

aluminum can collections). collected from residential generators her organizations (e.g.

Draft Recommendation #! 3

To modify the methodology to calculate t from measuring recycli municipalities as a pod

ew products which would

Draft Recomm

further increases in waste diversion for the

Rationale for Dra

Stakeholders differed In their support for material specific targets.

Some industry representatives opposed material specific targets on the basis that they would reduce operational flexibility. Other industry representatives proposed a

Until such time as this methodology is developed, recycling targets will be measured based on materials marketed.

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maximum of two categories - printed papers and packaging with a target of 80% to 85% for printed paper and 50% to 55% for packaging.

Municipal and ENGO stakeholders proposed material specific targets for each of the more than twenty Blue Box material categories used as the basis for reporting Blue Box Program recycling rates in 2007 on the basis that this approach to material specific targets would drive increased diversion. Suggested approaches for setting each material specific target included:

applying the principle of continuous improvement year over year: requiring a specified increase (e.9. 10% or 25%) setting a uniformly high target for each compliance for those materials with lower r

lowest cost approach to implementing th higher diversion without an economic in

ould not strive for

industly clearly understands the co

The rationale for the draft reco rial specific targets for the

based on six material

ile recognizing that different challenges

portionateiy above existing recycling

to establis for missing material specific targets in order to create an economic incentive to achieve the program performance targets, to utilize the steward fee structure to increase waste diversion by incorporating these penalties into the fee setting methodology (see also Draft Recommendation # 11) and to direct these penalties, should they become due, to support waste diversion in Ontario.

A 'dirty MRF' is a material recycling facility that accepts and processes mixed waste and/or kighiy contaminated recyclable materials rather than fully source separated recyclable materials.

Refer to Appendix B - Calculated Quantity Recycled if Material Specific Targets Are Achieved.

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To set the following 5 year Blue Box Program Plan material specific recycling targets':


To support the material specific recycii value that is higher than the cost of Recommendation # 11) with the penalty

Consistency Across M

confusion. Recorn Box wastes that a

increases in wa

Rationale for Dra

sistency in the Blue ize public confusion,

and encourage further

nefits of standardization in Blue Box

and concerns were raised about the ion. For example, municipal representatives dardized materials on municipal programs prior

n which Blue Box materials should be collected in all nts reflected the stakeholder's particular interest in a industry. While views on which materials should be

the basis for selecting these materials.

The rationale for the draft recommendation is: to expand the list of materials collected across Ontario to support higher collection and recycling targets (see also Draft Recommendation # 1) and material specific targets (see also Draft Recommendation # 5);

Refer to Appendix C for Examples of Performance Targets in Other Jurisdictions


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a to recognize that materiais collected and collection methods are important aspects of service levels to be addressed under full EPR; to establish a process that will involve consultation to develop criteria and select materials for standardization; and to establish a process that will involve consultation to determine appropriate collection approaches for the standardized materials in different areas of the province.


To establish a process to: select Blue Box materials to be collected i criteria such as

o percentage of Ontario househ g collection service for the material;

o capacity in the curbside c o compatible with the depot o ability to be managed in p o will not contaminate other m

determine differential

location.

Some Blue Box inefficiencies for municipal

nd how problematic Blue Box BPP or other mechanisms.

tic materials may have been introduced into the and that stewards may not fully understand the on the Blue Box system. These stakeholders

e introduction of problem packaging, including an

ge in collection systems that would result in lower d with the packaging review process were identified,

including the proprietary nature of new product and packaging design and the large number of new products and packages introduced into the marketplace each year.

While stakeholders acknowledged that stewards would be responsible for managing problematic materials under full EPR, it was noted that an iF0, as a collective of competing stewards, requires a policy framework or direction in order to take action on problematic wastes.



The rationale for the drafl recommendations is: to establish an advisory service for stewards inquiring about management of their products or packaging in Ontario's Blue Box system to avoid the introduction of problematic materials; to establish a regulatory framework to prevent shifling a product or package to an alternative collection system if it would result in reduced diversion and increased disposal; and to assign responsibility for identifying problematic materials and determining an appropriate course of action to ensure increased collection and recycling of Blue Box materials and a sustainable Blue Box system t~ an organization other than the IFO.


To minimize the introduction of problematic or packaging into the Ontario marketplace by:

implementing an advisory se compatibility of new Blue Box p and processing system.

Draft Recommendation # 9 pl

ducts or packaging once introduced into t

authorizinL . and manaqii

environmen offshore. Recc ~

Box wastes are I final market.

a product or package less the diversion rate

E materials, evaluate options for collecting :eration with Stewardshio Ontario and

on the management 'of problematic

2 Managemenf

: Box wastes may not be managed in an anner, including waste marketed in Ontario or sent F isms that can be added to the BBPP to assure that Blue

3n environmentally responsible manner from collection to I

Rationale for Draft Recommendation

Stakeholders generally agreed that actions to assure environmentally responsible management are required. However, stakeholders held different views on appropriate actions. Some stakeholders raised concerns about imposing more requirements on secondaty materials than are placed on primary materials.

Most stakeholders supported tracking materials from collection to final disposition. Tracking to final disposition would be required in order to measure recycling as materials

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utilized in new products (see also Draft Recommendation # 2) as information from primary and downstream processors and end markets would be required to establish the actual amount of residue and the quantity of Blue Box materials utilized in new products.

Many stakeholders indicated that vendor standards may not be required as existing regulatory requirements, such as Certificates of Approvals with appropriate enforcement, may be sufficient for Blue Box materiais as Blue Box materials are not hazardous and there is, for most materials, a well established commodity based management system.

However, implementation of a tracking system implies that value based decisions will be made to select processing facilities and end sure materials within the

level of environmental

contracts, likely through competitive prop performance requirements which wou standards on which to base decisions end markets.

Most stakeholders also indicat would minimize tracking requir the environmental impacts of a

Blue Box wastes by

ario's green economy.

naged in an environmentally responsible manner

racking system from collection to final disposition (see

Draft for Consultation - Februaly 6,2009 15


Stewardship Fees

Current steward fees for certain Blue Box wastes may be too low to encourage either increased waste diversion or the use of materials in product manufacturing or packaging that can be easily recycled. Recommend how the steward fee structure can be revised to (I) increase the waste diversion rate for certain Blue Box wastes (e.g., plastics) and (2) encourage stewards to incorporate materials that are easily recycled into their products or packaging.


esigning products odology results in

packaging to be easily recycled, stakeh order to increase the value of the price signal would be more likely to achieve the

Limitations of the fee setting m

cisions often occur in

ard would become the

to allocate increased program costs ards as a result of missed material

endation # 6) and costs associated with also Draft Recommendation # 2) and

ased processing and end market utilization of Ontario ort Ontario's green economy.

Draft Recommend

To revise the Blue Box Program Plan steward fee structure to increase waste diversion by:

incorporating penalties for materials that do not achieve material-specific targets into the fee setting methodology (see also Draft Recommendation # 6); incorporating any costs incurred to operate or provide incentives to non- municipal collection systems (see also Draft Recommendation # 2); incorporating the costs of the following activities into the fee setting methodology:

o sorting Blue Box materials at 'dirty MRFs' for recycling, and



o production of fuel incorporating Blue Box materials at 'dirty MRFs" (see also Draft Recommendation # 20), and

modifying the three factor formula equalization factor to replace the existing 60% program target with the proposed material specific recycling targets (see also Draft Recommendation # 5).

EPR Funding

The BBPP does not ref/ect full Extended Producer Responsibility (EPR) funding since the WDA requires Blue Box stewards to fund 50% o 'cipal program costs, with municipalities funding the rest. Recommend how to e BBPP towards full EPR funding.

Since different collection and processing sys decisions made by local municipalities, I consider the potential impact to the ma industry moves to full EPR funding.

stes are the result of mmendation, please

ling programs as


The consultation process f o r t

and the full EPR essed support for the their view, the model

ntabiiity of industry under a ieving environmental policy objectives.

naturally gravitate to the lowest cost and would not take environmental

ion to do so. These stakeholders work established by

BPP to full EPR. All sition issues such as:

on during and after the transition period to minimize vestments and contracts extending beyond the transition

ontinuous Improvement Fund (CIF) can be used prior to and during the transition to assist in the transition process; regulatory amendments including Regulation 101, the Municipal Act and Certificate of Approval amendments for MRFs; communicating with municipal councils; ensuring seamless services to residents throughout the transition period:

' A 'dirty MRF is a material recycling facility that accepts and processes mixed waste andlor highly contaminated recyclable materials rather than fully source separated recyclable materials,


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customer service and communications with residents during and after the transition period; managing expiry of existing contracts, both labour and service providers, and replacement with new contracts; determining the terms of new contracts; cross-jurisdictional issues such as integrated collection routing and processing waste sheds; devising an acceptable fee-for-service payment where full EPR is implemented prior to expiry of existing contracts; building competency within the IFO; manaaina different service levels across the orod

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marketplace intervention and competition i determining whether andlor how a

uncertainty during the transition.

The rationale for the draft recommendatio to provide a response t move the BBPP toward

ry of Blue Box services of Blue Box services

ion of Blue. Box system

policy framework, including program objectives, for the Blue Box Program

ill develop operational objectives and

of Blue Box services under the Blue Box Program Pian five year period in the following phases:

o The IF0 will develop a detailed operations plan that addresses the transition process.

o The IF0 will assume full financial responsibility for the Blue Box system at a date specified during the five year transition period by contracting for collection and processing services directly with service providers where municipal contracts have expired and, where municipal contracts continue to operate during Phase 2, by offering to contract with municipalities on a fee-for-service basis.

0 Phase 2: Financial EPR

Draft for Consultation - February 6, 2009 i a

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Phase 3: Physical EPR 0 The IF0 will assume physical responsibility as existing municipal service

provider contracts expire and would be responsible for establishing new contracts.

o The IF0 will continue to contract with municipalities on a fee-for-service basis where contracts extend beyond the five year transition period on an exception basis until the entire system has been shifted to the management of stewards.


To inform municipal property taxpayers of the tran municipalities to Blue Box stewards.

6.2 Changing the Scope of the Blue B

This section presents draft recommenda system to include:

ue Box system costs from

of the Blue Box

Blue Box wastes remai expanding the range packaging.

d to 'see also Draft Recommendati

is not included in the BBPP. ded to include Blue Box wastes

that certain 1C&l organizations or sectors have Other g programs based on their direct experience.

minimal recycling activities in the IC&l sector.

All stakeholders agr regarding activities to increase IC&i diversion.

at better data are required on which to base decisions

Some stakeholders suggested that IG&i diversion can be addressed through provincial enforcement of Regulations 102 and 103. Some stakeholders also suggested that the reporting requirements under these regulations could be utilized to gather data on IC&i recycling activities.

Other stakeholders felt that these regulations require amendment to be effective, for example extending these regulations to apply to service providers so that:


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IC&l generators would be responsible for implementing recycling programs, and service providers would be responsible for providing recycling services, recycling the materials collected and reporting on the quantity of materials collected and recycled.

This approach would reduce the number of data points from many thousands of generators to a smaller number of service providers. While this process would provide information on the quantity of materials collected and recycled (Le. the numerator” in a diversion percentage), it would not provide information on the quantity of Blue Box materials available for collection (the denominatoe’ in a

Other stakeholders felt that EPR would be more n relying on amendments

The rationale for the draft recornrnendat to establish a system to compil base decisions regarding an IC& to establish a process to resolve p model to the lC&l secto to establish a process collection and recycling

ies on which to

Draft Recommend

ctivities and determine

lace through reports to an IF0 (if Draft Recommendation # 16); or terlals purchased under an amended

cled under an amended Regulation 103 or an

recycled under an amended Regulation 103 or

Y

Draft Recomme

To assess if, and how, Box wastes generated by the IC&l sector under full EPR by:

Blue Box Program Plan could be extended to include Blue

assessing whether stewards can identify sales into the IC&l sector for purposes of reporting sales to Stewardship Ontario:

e

Io A recycling rate is calculated a5 a percentage with the numerator representing the quantity of materials recycled and the denominator representing the quantity of materials available for collection.

See footnote 8. See footnote 8. 12



assessing, within one year after baseline data has been compiled (see Draft Recommendation # 15), whether an incentive model or a fee-for-service model could be utilized by stewards to increase collection and recycling of Blue Box wastes generated by the IC&l sector.

Blue Box Wastes Collected Outside ofthe Blue Box

Blue Box wastes not captured in the Blue Box are collected as garbage or litter by municipalities, fully at their cost Recommend (1) bow collection options beyond

and (2) how steward responsibility can be use Box wastes that are collected beyond municipal curbside and depot,


Some stakeholders proposed activities the garbage and litter stream including:

Box wastes from

education of consumers:

alternate collection increasing the cost of disposal or re

recycling systems, re

materials. It wa

sort additional a fuel from the remaining

ere to assume responsibility for both

The rationale fort

reduce the amount of these materials remaining in the garbage and litter streams; to utilize steward responsibility to manage Blue Box wastes if directed to 'dirty MRFs' and sorted for recycling markets or utilized as fuel: and

l3 A 'dirty MRF' is a material recycling facility that accepts and processes mixed waste and/or highly contaminated recyclable materials rather than fully source separated recyclable materials.


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to ensure that property taxpayers are aware of the transition of costs from municipalities to industry for management of Blue Box wastes directed to 'dirty MRFs'.


To increase collection of Blue Box waste by: 0 educating the public to reduce the generation of printed paper and package

waste, use collection systems (to improve capture rate) and to use these

encouraging municipalities to utilize the lable tools to restrict ly garbage collection,

considering other collection o return-to-retail, etc.) m inefficiencies and

disposal (e.g. disposal bans, bag limits, cl

taking into account the effect consumers.


To increase recycling of Blue B utilizing 'dirty MRFs' to Blue Box MRFs and

portion of recyclable

ecyclable materials collected through

terial contributing to energy recovery counting

Draft Recommen

To address Blue Box wastes that are collected beyond municipal curbside and depot or disposed as waste or litter through steward responsibility by incorporating the following costs in the calculation of the BBPP cost and stewards' fees:

public education to use Blue Box material collection systems correctly; other collection systems (e.9. private depots, return-to-retail, etc.); and processing Blue Box wastes at 'dirty MRFs'.


s



To inform municipal property taxpayers of the transition of costs from municipalities to Blue Box stewards for Blue Box materials directed to 'dirty MRFs' if sorted for recycling or energy recovery.

Additional Blue Box Wasfes

Some of the designated Blue Box wastes, such as plastic products, are not included in the BBPP.

Recommend how the BBPP can be expanded designated by regulation within the program.


additional wastes already

additional items while producing ma concerns about confusing consumers packaging.

Most stakeholders agreed that

Stakeholders s if additional materials

to the BBPP and referring

uld be utilized to maximize

another diversion program.

materials to be added to the BBPP;

rn Plan to include additional wastes already designated tion but excluded from the BBPP definition of printed iishing a process to evaluate whether specific products

materials deemed

papers and packag? andlor packages shoa limited to:

sufficient collection capacity; 0 ' compatibility with collection systems;

sufficient processing capacity; compatibility with processing systems: available end market capacity; clarity for the consumer; ability to track the material from collection to final disposition; and ability of the IF0 to levy a steward's fee that meets the nexus test.




To refer products and packages that may fall under the Blue Box Wastes Regulation deemed unacceptable for inclusion in the Blue Box Program Plan for consideration as a separate diversion program plan.

Draft for Consultation - Februaty 6, 2009 24

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Appendix A CCME Guiding Principles for the Design and Development

of EPR Policies and Programs

1. Environmental Principles

1. To the greatest extent possible, programs seek to reduce the environmental impact of a product.

b. Reusability or recyclability c. Reuse d. Recycle e. Recovery, of materials an

/I. Program Design Principles

product or materials to

rious actors in the product

determined on a case-by-case basis.

development and implementation is based on

9. Programs'and policies are designed and implemented in a way that environmental benefits are maximized while economic dislocations are minimized.

I O . A communication strategy is devised to inform participants in the product chain, including consumers, about the program and enlist their support and co- ooeration.



11. EPR programs undergo periodic evaluations to ensure that they are functioning appropriately, are subject to performance measurement, and include accessible and transparent reporting.

12. Costs of program management are not borne by general taxpayers.

13. Consumers have reasonable access to collection systems without charge, to maximize recovery opportunities.

Drafl for Consultation - February 6,2009 26

Calculz


Amendix B ed Quantity Re&hed if Material Specific T-.:ge

Are Achieved (based on 2007 Generation)

Material

Quantity Marketed by

Municipalities in 2007

Recycling I Calculated


s

Proposed Material Specific

Recycling Targets

(%)

85%

50% 85%

74%

Tonnes Recycled If Targets are Achieved (based on

tonnes

27

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