Submitted Jan. 30, 2017
The Resource Recovery and Circular Economy Act, 2016 requires the Minister of the Environment and Climate Change to develop and maintain Strategy for a Waste-Free Ontario: Building the Circular Economy (PDF) to support the provincial interest in having a system of resource recovery and waste reduction.
The Government of Ontario invited comment on the proposed strategy before finalizing it, after which it will serve as a roadmap to shift Ontario toward a circular economy and zero-waste future.
While RCO supports the goals and objectives contained in the strategy, there are aspects that are absent and require more detail. RCO offers each recommendation in the spirit of maximizing results of its implementation.
- Disposal levies have proven themselves to be a basic tenet to addressing cost disparities between disposal and diversion, and pivotal to the success of transitioning to a circular economy. The provincial strategy should include the introduction of disposal levies that would be reinvested in waste reduction infrastructure and programming.
- Reduction and reuse objectives and measures are central to achieving zero waste and zero greenhouse gas objectives. The strategy should include action items that support reduction and reuse with measurable targets.
- As drafted the strategy proposes a low six per cent increase in waste diversion from disposal for its first incremental target (2012 – 2018). Overall performance benchmarks (short-, mid-, and long-term) outlined in the strategy should be increased.
- Action items in the proposed strategy should express proposed impacts by tonnage incrementally. These benchmarks will inform how to prioritize each action items and provide a mechanism to report progress.
- Clear timelines and/or processes for reporting status against objectives, and a mechanism to facilitate transparent reporting against objectives and action items for government and obligated stakeholders, should be included.
- The Government of Ontario should activate progressive environmental procurement policies and practices, and prioritize implementation in 2017.
- Disposal bans on material that have existing recycling solutions or established programs should be made a priority (2017 implementation): mercury-containing lamps; fibre-based materials such as boxboard, cardboard, and paper; organics; and metals.
- All activities made voluntarily and/or mandated through policy should be subject to credits under the Government of Ontario’s cap and trade program. If these measures are measurable, sustainable, and contribute to zero waste and zero emissions goals, they should be recognized and rewarded.