Project Description

Policy Response

Submitted Jan. 28, 2019

On Thursday, Nov. 29, 2018 Ontario Minister of Environment, the Hon. Rod Phillips released Preserving and Protecting our Environment for Future Generations: A Made-in-Ontario Environment Plan. The 53-page document will guide development of new environmental policies in Ontario.

The Plan contains proposed solutions to protect Ontario’s air, land and water, and reduce litter and waste while lowering greenhouse gas emissions and helping communities protect themselves from climate change.

RCO provided comment on the Plan, which also outlines critical environmental issues that Ontario currently faces: economic, environmental, and social losses associated with increasing generation of waste and disposal.


  • RCO estimates that 15 of Ontario’s largest landfills will reach capacity within the next 10 years and potentially strand 48 million tonnes of material. As such, Ontario’s commitment and expertise in waste reduction through reduced generation and increased recycling has never been as important as it is now.
  • The Plan, however, neglects to acknowledge additional and significant effects of waste:
    • Economic losses of valuable discarded materials that could displace virgin materials in production cycles.
    • Energy and water losses when goods are produced with virgin rather than recycled materials.
    • Economic and social losses of sustainable jobs; the ratio of jobs created by recycling versus landfilling for every tonne disposed is 7:1.
    • Economic and environmental losses and liabilities of maintaining landfill during and beyond lifespan.
  • Disposal Levies Absent
  • Disposal Bans Beyond Organics Absent
  • Targets, Monitoring, and Reporting Strategies Absent
  • RCO supports the Plan’s commitment to government leadership on waste reduction objectives, and specifically, its procurement practices. Annually the Government of Ontario procures approximately $6 billion worth of goods, services, and construction in partnership with more than 52,000 vendors.
  • RCO encourages government to prioritize action on organic wastes developing an implementation strategy with multiple short-term actions:
    • Province-wide disposal ban.
    • Government procurement requirements with all food-related vendors and service providers, as well as a requirement of organizations that receive government funding.
    • Focus on the Industrial, Commercial, and Institutional (IC&I) sector and enforce reporting and source separation requirements from Regulations 102, 103, and 104. Progress with a full review of these regulations to modernize and make them more effective.
  • Prioritize waste reduction in the IC&I sector through investments, regulatory review, improved data and reporting, and greater support.
  • Expand Extended Producer Responsibility
  • Transition the Blue Box
  • Review any thermal treatment policy and ensure it is considered disposal and does not count toward diversion targets made under regulation or claims made in reporting.