The MOECC received comments from businesses, individuals, non-governmental organizations, and broader public sector entities. All comments received were considered prior to finalizing the decision on the proposal.
Comments were primarily on the following issues:
- the adverse effects of the fee on businesses;
- the potential for the fee increase to encourage illegal dumping; and,
- the need for program service improvements.
The following is a summary of the comments received from the public and the ministry’s responses.
Comment: The fee increase will adversely affect businesses.
Response: Businesses that generate hazardous waste and are required to register with the ministry will experience fee increases in proportion to the amount of hazardous waste they generate. Of the 33,000 registered generators, approximately 29,000 generate less than one tonne of hazardous waste per year and would be subject to tonnage fee increases of $20 or less per year.
Approximately 40 per cent of hazardous waste subject to the tonnage fee is imported into Ontario, so 40 per cent of the fee increase falls on generators outside Ontario.
The ministry is phasing in the fee change over a two-year period to give hazardous waste generators time to adapt processes before the full impact of the fee change is in place.
Comment: The ministry should implement a modernized, electronic IT system as a mechanism to improve service and lower program costs prior to implementation of a fee increase.
Response: The ministry will be implementing service improvements and will review the cost of the program after the implementation of these service improvements to ensure fees are properly set to continue to achieve program cost recovery.
Comment: Illegal dumping will increase.
Response: Illegal dumping continues to pose a risk to Ontario’s environment. The ministry will continue to be vigilant in ensuring that hazardous waste is managed appropriately and will follow-up swiftly in cases where it is not managed or disposed appropriately.
Comment: It is unclear what program activities the fee increase is paying for.
Response: Program activities include operating and maintaining the hazardous waste IT system, processing registrations and manifests, compliance and enforcement activities, public reporting, responding to information requests, collecting and processing revenue and developing/implementing new program policies and directions
Comment: The ministry should use external benchmarks to ensure the Hazardous Waste Program is cost efficient prior to implementing a fee increase.
Response: The government recognizes the need to continuously review its programs to ensure that they deliver against environmental objectives and, where possible, reduce the burden on the regulated community.
Comment: Generators of liquid industrial waste should also pay tonnage fees.
Response: Hazardous waste presents a greater environmental risk to the province than liquid industrial waste (LIW). While it is important to ensure that LIW is managed and treated appropriately, the majority of the cost of the Hazardous Waste Program relates to oversight of activities concerning hazardous waste.
Comment: The fee increase will help firms remain aware of the environmental impact of their waste.
Response: The fee increase aligns with the ‘polluter pays’ principle, according to which the generators of hazardous waste should bear the burden of managing hazardous waste, rather than taxpayers.