OWMA News & Submissions

OWMA Submission on Discussion Paper: Developing a Modern Renewable Fuel Standard for Gasoline in Ont
March 12, 2017 – The OWMA has expressed support for a modern renewable fuel standard, but has made several recommendations to make a future regulation more effective.

 
OWMA submission on the Strategy for a Waste-Free Ontario: Building the Circular Economy


 
January 19, 2017 – The OWMA’s pre-budget submission to the Standing Committee on Finance


 
OWMA’s letter on Ontario’s Food Waste and Organics Action Plan
The OWMA sent this letter to Environment Minister Glen Murray on Dec. 9, 2016, to provide a series of recommendations on the government’s Food Waste and Organics Action Plan that would help increase organics diversion, foster growth in the circular economy and reduce greenhouse gas emissions.

 
Webinar Presentation on the Waste-Free Ontario Act & Strategy
The OWMA provided a webinar on Dec. 7 to discuss the proclamation of the Waste-Free Ontario Act and the government’s plans to update its Waste-Free Ontario Strategy, as well as develop new producer-responsibility regulations under the Resource Recovery and Circular Economy Act.

 
OWMA Recommendations on Modernizing Approvals
This letter to the Ontario government includes a comprehensive list of recommendations on how to streamline the Environmental Compliance Approvals (ECAs) process in a way that will reduce greenhouse gas emissions and advance the province’s move toward a more circular economy.

 
State of Waste in Ontario - Organics Report

“The Ontario Waste Management Association (OWMA) is the largest waste/resource management trade association in Canada, representing over 230 members across Ontario including private and public organizations, municipalities, and individuals involved in the waste management sector. OWMA members manage over 85% of the province’s waste and recyclables and have diverse interests and capital investments in areas such as waste and recyclables collection, landfills, transfer stations, material recovery facilities (MRFs), energy from waste facilities, organics processing and composting facilities and hazardous waste. They are at the core of the green economy......”



 
OWMA Submission on proposed Automotive Materials ISP
April 28, 2016 – The OWMA calls on Waste Diversion Ontario to reject the proposed Automotive Materials Industry Stewardship Plan.

 
OWMA Amendments on the Waste-Free Ontario Act
April 11, 2016 - OWMA’s submission to the Standing Committee on Social Policy on proposed amendments to the Waste-Free Ontario Act.

 
Cap-and-Trade Research for Ontario's Waste Management Sector

Cap-and-Trade Research for Ontario's Waste Management Sector

“In September 2015, the Ontario Waste Management Association (OWMA) retained GHD Limited (GHD) to perform a study related to cap-and-trade research for the Ontario waste management sector. This study was commissioned by the OWMA with the support of Canada's National Brewers, the Region of Peel, the City of Toronto, the Region of Waterloo, the City of London, the Regional Municipality of Durham, the Regional Municipality York, and the Regional Municipality of Niagara. GHD notes that this Report is intended to accompany "Greenhouse Gas Emissions and the Ontario Waste Management Industry" white paper report completed by Torrie Smith Associates, Sonnevera International Corp., and Kelleher Environmental, as well as provide more specific and detailed information related to greenhouse gas (GHG) emissions in the Ontario waste management sector.....”



 
Submission to Cap Trade Legislation and Regulation
April 8, 2016 - OWMA submission to Climate Change Mitigation and Low-Carbon Economy Act, 2016 & Cap and Trade Regulatory Proposal and Revised Guideline for Greenhouse Gas Emissions Reporting.

 
Submission on Ethanol in Gasoline
April 1, 2016 – OWMA submission to proposed government amendments O. Reg 535/05 to change the definition of “cellulosic ethanol” to include the addition of the bio-based component of post-diverted municipal solid waste (MSW).

 
Submission on Excess Soil Management Policy Framework
March 24, 2016 – OWMA comments on the government’s proposed Excess Soil Management Policy Framework.

 
Submission to the Standing Committee on Bill 76, the Natural Gas Superhighway Act
March 16, 2016 - OWMA’s submission supports Bill 76, the Natural Gas Superhighway Act, which recognizes the important role natural gas can play as a transportation fuel in medium and heavy-duty vehicles on Ontario’s major transportation routes.

 
Opinion Piece: Why We Should Price Pollution
March 9, 2016

 
Letter to OTA seeking support for Commercial Vehicle Operators Registry (CVOR) amendments
March 1, 2016 - OWMA letter to the OTA seeking their support on changes to the definition of pointable collisions under the Commercial Vehicle Operator’s Registration (CVOR) Guideline to reflect a ‘tow away’ standard.

 
Submission to the MOECC on the Waste-Free Ontario Act & Strategy
February 24, 2016 - OWMA response to the EBR posting on the proposed Waste-Free Act & Strategy.

 
Submission to the MOECC on Cap & Trade Program Design Options
December 16, 2015 - OWMA response to the EBR posting on Cap & Trade Design Options.

 
Submission to IESO Proposal for a Standard Offer for Energy-From-Waste Facilities
October 27, 2015 - OWMA expresses concerns related to the proposed Standard Offer Program for Energy-from-Waste (EFWSOP) facilities in the province.

 
Driving A Circular Economy through Organic Waste Reduction, Reuse and Recycling
October 22, 2015 - Joint News Release on ReThink Organic Waste Report.

 
Submission to the MOECC on Hazardous Waste Program Fee Increases
September 18, 2015 - OWMA responds to proposed fee increases to Ontario Hazardous Waste Program.

 
Submission to IESO Proposal for a Standard Offer for Energy-From-Waste Facilities
August 24, 2015 - OWMA advice to IESO on a Standard Offer for Energy-From-Waste Facilities.

 
Submission to MOECC on Soil Management Review & Soil Acceptance
July 21, 2015 - OWMA express concern to MOECC on the review of excess soil management policy.

 
Waste Management Sector Calls on Government to Enact Slow Down Move Over & Yield Provisions
July 7, 2015

 
Statistics Canada Report Underlines the Need for Reform of Ontario’s Waste Diversion Framework
June 11, 2015

 
Submission to MTO on Reporting Threshold & CVOR
April 30, 2015 - OWMA reiterating support for increasing the reporting threshold for property damage only (PDO) collisions in Ontario. and suggestion for an additional change to the definition of pointable collisions under the Commercial Vehicle Operator’s Registration (CVOR) Guideline to be in line with a tow away standard.

 
Submission to MOECC on the Compost Quality Standards
April 9, 2015 - OWMA expresses concerns around changes to the Compost Quality Standards.

 
Submission to MOECC regarding Climate Change Discussion Paper
April 1, 2015 - OWMA submission to the EBR posting on the MOECC’s Climate Change Discussion Paper and the role of the waste management sector in helping the government meet its reduction targets.

 
LTR to WDO regarding Competition & the WEEE Program
February 26, 2015 - OWMA expresses concerns to the WDO on competition related issues associated with the interaction between the allocation channel and the processor incentive channel within the Waste Electrical & Electronic Equipment (WEEE) Program.

 
Submission to the MOECC regarding the use of low carbon fuels
February 2, 2015 - The OWMA responds to EBR posting concerning the proposed Regulation to allow facilities designed to combust coal or petroleum coke for the primary purpose of producing clinker, lime, iron, steel or metallurgical coke to use waste derived fuels without the need for a waste disposal approval, if they meet certain conditions.

 
OWMA Pre-Budget Submission
January 30, 2015

 
LTR to the AMO, MWA, RPWCO re CVOR and procurement
December 18, 2014 - Letter to AMO, RPWCO and MWA to express some concerns about the use of CVOR safety ratings in public tenders and to hopefully open a discussion on how this might be more effectively managed moving forward.

 
LTR to Minister of Finance re: SPBPA Review – Landfill Assessment
November 3, 2014

 
LTR - Compost Guideline - Aug 21, 2014


 
LTR - Competition & EPR - Aug 20, 2014


 
Ontario 2014 Budget Highlights


 
Update on Management of Household Hazardous Waste in Ontario


 
Letter to Waste Diversion Ontario Regarding Decisions & Election


 
Conference Board of Canada Report Highlights Economic Opportunities Associated With Waste Diversion
 
Today, the Conference Board of Canada released a report entitled the ‘Economic Impacts of Waste Diversion in North America.’ The report examines numerous studies across North America that looked at the net economic opportunities associated with waste diversion. Based on a conservative estimate, it suggests Ontario could create 13,000 net new jobs and increase GDP by $1.5 billion if waste diversion was increased to 60%. A copy of the report can be found at http://conferenceboard.ca/e-library/abstract.aspx?did=6233.html
 
A copy of OWMA’s news release can be found at http://huffstrategy.com/MediaManager/release/Ontario-Waste-Management-Association/29-5-14/Ontario-economy-would-benefit-from-recycling-reforms/2974.html
 
The Conference Board’s briefing supports the basis of the OWMA’s ReThink Waste Report released in 2013, which provided a blueprint to unlock Ontario’s resource recovery potential and encourage millions in investment to expand the province’s current waste management infrastructure. The report received widespread support for the need to address the enormous loss of resources and economic opportunities associated with sending 75% of our waste to disposal.
 
We hope this report will help to re-focus the political discussion around moving forward with waste diversion initiatives to capture these opportunities.
 
If you have any questions please contact Rob Cook or Peter Hargreave at 905-791-9500.


 
Questions to Party Leaders Regarding the 2014 Provincial Election:

The OWMA has sent each of the party leaders a series of questions related to their party’s positions on issues of importance to the sector.

  • How is waste reduction and diversion addressed in your environmental protection plans and commitments to Ontarians?
  • Do you support open and competitive marketplaces for waste diversion programs and servicing in which no party is provided the opportunity or authority to dominate or dictate commercial activity and marketplace outcomes?
  • What is your opinion/position on the Waste Diversion Act and the current programs operating under it? What if anything will your party do to improve these current waste diversion programs?
  • What, if anything, will you do to help better harness the economic benefits of the resources in our waste?
  • Do you support the use of different forms of service delivery like Delegated Administrative Authorities (DAA) or other arms-length bodies to help improve regulatory outcomes; strengthen enforcement; and better track waste management data in Ontario?
  • Will you support the regulation brought forward by the Ontario Waste Management Association with regards to the assessment of landfills to ensure transparency, simplicity, predictability, equity, sustainability and encourage environmental protection?
  • Will you support changing pointable collisions in the Commercial Vehicle Operator’s Registration (CVOR) Guideline to a tow away standard in order to deal with the inequitable treatment of low-kilometric fleets under the kilometric model?
We will keep you informed as we hear back from each of the political party leaders. If you have any questions please contact Rob Cook or Peter Hargreave at 905-791-9500.



 
OWMA Landfill Tax Assessment Regulation
The OWMA has finalized a proposed regulation and explanatory document relative to the assessment of landfills for municipal tax purposes. The regulation establishes a consistent approach to valuation across the waste sector (private & public) and is based on a series of principles. Attached for your information is the explanatory document (principles), the regulation and a comparison chart of different assessment models for both private and public landfill properties. The sites chosen include four private and for municipal which were selected in consultation with the RPWCO waste committee. The Ministry of Finance is still engaged in consultation on landfill assessment and will be recommending a preferred approach over the next several weeks. If you have any questions, please contact Rob Cook or Peter Hargreave at 905-791-9500.

 
CELA EBR Review Request Decision
As many of you are aware The Concerned Citizens‘ Committee/Tyendinaga & Environs (“CCCTE”), the Mohawks of the Bay of Quinte (“MBQ”), and the Canadian Environmental Law Association (“CELA”) jointly filed an Application for Review under the Environmental Bill of Rights (“EBR”) in July arguing Ontario‘s approvals are not restrictive enough for landfills. The Application for review seeks to request key changes to provincial legislation governing the siting of waste disposal sites. In their application, the groups argue the science is clear that landfills should not be built on fractured bedrock in hydrogeological sensitive areas. They are seeking to amend section 27 of the Environmental Protection Act o prohibit the use, operation, establishment, alteration, enlargement, or extension of a waste disposal site in a hydrogeologically unsuitable location and to prohibit repetitive applications for approval at locations which have already been rejected by the Ministry of the Environment for hydrogeological reasons. The OWMA did submit comments to the Ministry arguing such a review was not necessary. The Ministry has released their decision which agrees that a full review is not necessary. They have agreed however to a more focussed review of guidance materials related to the landfills approvals process. The Ministry has stated they will be consulting with stakeholders. The rejection of the review as requested is positive for members and OWMA will have an opportunity to engage in any discussions around the guidance document review. Please contact Rob Cook or Peter Hargreave if you have any questions or concerns.

 
Environmental Commissioner of Ontario (ECO) Annual Report - 2013
The Environmental Commissioner of Ontario (ECO) last week released his 2013 Annual Report entitled ‘Serving the Public.’ The Report touches on several areas that might be of interest to members including: • Expansion of MOE’s Environmental Activity and Sector Registry • New Compost Framework for Ontario • Regulation of the Safe Disposal of Waste Pharmaceuticals and Sharps Here is a brief summary of each: Expansion of MOE’s Environmental Activity and Sector Registry (EASR) The ECO is encouraged by the Ministry of Environment’s ongoing work on approvals modernization. The Report indicates the Ministry is striking an appropriate balance between reducing the administrative and financial burden on proponents of certain lower-risk environmental activities, while redirecting resources to higher risk activities. Additional attention will be paid as to how the Ministry follows through with an effective process for monitoring and enforcing compliance to ensure that EASR registration ultimately provides at least the same level of environmental protection as the individual approvals process. A New Compost Framework for Ontario The ECO is pleased with the Ministry of Environment’s new composting framework. The Report indicates the Guideline should help to improve the success rate and public acceptance of composting operations in the province. The Report does caution that new or newly imported technologies and methods should receive close scrutiny before permits are issued. The ECO will be monitoring this concern in years to come. Regulation of the Safe Disposal of Waste Pharmaceuticals and Sharps The ECO is pleased that Ministry of the Environment has taken a step forward with respect to waste diversion and EPR in Ontario. The Report states the new EPA regulation rightly shifts the onus for collecting and managing waste pharmaceuticals and sharps back onto the individual companies that made them, while giving them the flexibility to meet outcomes how they see fit. This approach should help ensure the proper management of pharmaceuticals and sharps while avoiding many of the process related problems that have strained stakeholder relations and plagued IFO-operated waste diversion programs in the past. The ECO does however have some some reservations. First, the regulation does not require producers to meet any targets other than those related to the number of collection locations. The Report strongly urges that actual diversion targets and public education targets are essential to the success of the program . Second, although MOE asserts that “the regulation implements an [EPR] approach that requires producers of pharmaceuticals and sharps … to be responsible for the management of the wastes resulting from their products,” the regulation does not make producers responsible for the management of all of these wastes, since municipalities manage and incur the costs of managing pharmaceuticals and sharps collected in the residual waste stream. Likewise, the regulation fails to make producers responsible for collecting and managing the large volume of waste pharmaceuticals and sharps generated in nursing homes, hospitals, veterinary clinics and veterinary clinics and other facilities. The ECO hopes that this regulation is just the start of innovative action to minimize the environmental impacts of waste in Ontario. However, the ECO cautions that, with respect to enforcement, if the program is to succeed in meeting the desired outcomes, the ministry must ensure that charges are laid against non-compliant producers. Given MOE’s history of failing to monitor and enforce compliance with other waste diversion regulations under the EPA, and given the ministry’s limited capacity (see Part 2.3 of this Annual Report), it seems unlikely that MOE will have the inclination or resources to enforce producer compliance. The ECO strongly urges the ministry to reverse this pattern. If you have any questions or concerns about the ECO’s Annual Report please contact Rob Cook or Peter Hargreave at 905-791-9500.

 
New Requirements for Transportation of Non-Hazardous Waste
As many of you may already know, the government is putting in place new requirements as of November 18, 2013 for all companies transporting non-hazardous waste. The change makes it mandatory for all drivers that transport municipal, hazardous and liquid industrial waste to be trained. This requirement already exists for waste management operations that transport hazardous and liquid industrial waste and is now being broadened to include municipal waste. These changes were made through an amendment to paragraph 19 of subsection 16 (1) of Regulation 347 (General - Waste Management) under the Environmental Protection Act. Many waste transportation operations already train their drivers and this requirement will simply apply a standard for environmental management that applies across the sector. In order to ensure the sector is ready for these changes the OWMA held two free lunchtime webinars. The Ministry of Environment provided a brief presentation on the new requirements and that document is now available.

 
HST Invoice Requirements
It has been brought to the attention of the OWMA that CRA has/is/may be conducting audits of waste management companies related to the collection/redemption of HST as it is posted on invoices that provide a credit back to the customer for material. As an example - your customer has a bin that you charge them $100 to pick up (for services). You would charge HST on the full amount ($13.00). As part of that invoice you also credit the customer $50 for the materials that are in the bin. You would claim an HST ITC back from the $50 ($6.50). Essentially this practice does not provide the “paper trail” that is required for CRA to allow those ITC‘s. The services transaction and the purchase (credit) transaction must be treated as two separate items, however, the two items can be shown on the same invoice (as attached sample), provided that the customers' GST/HST number is shown (or available to be shown if requested). The OWMA had retained the services of a lawyer regarding this and had convened a committee a few months back to address this matter and a course of action that may be taken to address this matter. Following discussions with CRA, the Committee and the lawyer, the OWMA would like to provide you with the guidelines that CRA provides in claiming ITC‘s - please see the attached HST Chart as well as a "sample invoice". If you have any questions, please contact Michele Goulding at the OWMA office.

 
OWMA Response to an Application for Review of Landfill Siting
On July 11, 2013, the Concerned Citizens’ Committee/Tyendinaga & Environs (“CCCTE”), the Mohawks of the Bay of Quinte (“MBQ”), and the Canadian Environmental Law Association (“CELA”) jointly filed an Application for Review under the Environmental Bill of Rights (“EBR”) arguing Ontario’s approvals for landfills were not restrictive enough. The Application for Review requests key changes to provincial legislation governing the siting of waste disposal sites. In their application, the three groups argue that landfills should not be built on fractured bedrock in hydrogeological sensitive areas. They seek to amend section 27 of the Environmental Protection Act to prohibit the use, operation, establishment, alteration, enlargement, or extension of a waste disposal site in a hydrogeologically unsuitable location and to prohibit repetitive applications for approval at locations which have already been rejected by the Ministry of the Environment for hydrogeological reasons.

 
OWMA's response to Windsor Star on the Waste Reduction Act
Below is OWMA’s response to a recent article in the Windsor Star on the Waste Reduction Act. The full article can be found at http://www.windsorstar.com/news/Liberal+scam+works/8800932/story.html

A ‘Left Wing’ Recycling Conspiracy – please!

I read with interest the story by Chris Vander Doelen on August 17th about proposed new Waste Diversion legislation which is generally described as a ‘left-wing’ conspiracy to tax people; make Ontario less competitive; and hire new government employees. Each of these assertions is factually incorrect.

For the last 10 years, businesses, municipalities, the waste management sector, consumers, the Environmental Commissioner, and all political parties have argued our current waste diversion framework is broken. It has failed consumers, the economy and our environment. Numerous controversies over eco fees, repeatedly missed diversion targets, and major marketplace disruptions illustrate that the current legislation is unworkable.

For the last two decades, our province’s waste diversion rate has essentially "flat-lined" at only 25 percent. Sending 75 percent of our wastes to disposal makes little economic sense. They are resources that should be rerouted back into Ontario’s economy after proper processing. Ontario is not alone, governments around the world are building waste diversion strategies out of economic need.

Ontario’s proposed Waste Reduction Act was introduced to address the mistakes of the past based on feedback from numerous consultations and proposals from all political stripes. Is the legislation perfect – absolutely not but it comes a long way to fix the problems all have identified.


 
Development of an Ontario Recycling Process, Audit, and Verification Guideline
The OWMA has begun a new project with the Canadian Standards Association to develop Recycling Process, Audit, and Verification Guideline for Ontario. More information on the initiative can be found in the latest copy of Waste Edge magazine - http://mediaedge.imirus.com/Mpowered/book/vwaste13/i2/p22

New projects include the development of new standards or guidelines and new editions (including adoptions), and endorsements. If you have relevant expertise and would like to contribute time, comments, or are able to support the development, please contact the CSA Group Project Manager: Megan McGarrity - Megan.mcgarrity@csagroup.org - (613) 565-5151 x 59224.

You may also contact Rob Cook or Peter Hargreave at 905-791-9500 if you have additional questions.


 

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Ontario Waste Management Association
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