The Draft PPP Stewardship Plan reviewed with stakeholders during the October 29 workshop/webcast was developed with consideration for the information on the current PPP residential collection and recycling system and assessment of the various program design options compiled during the Phase 1 project as well as discussions with stakeholders between November 2011 and October 2012.
In addition to the questions and discussion at the October 29 workshop, MMBC received comments on the Draft PPP Stewardship Plan submitted via the online feedback form, by email to consultation@multimaterialbc.ca and in letters to the Chair of MMBC from the following stakeholders:
- 26 submissions were received from representatives of local governments;
- One submission was received from a not-for-profit organization;
- Nine submissions were received from private companies that provide PPP collection and processing services and one submission from an industry trade association;
- 14 submissions were received from stewards of PPP, three submissions from producer trade associations and two submissions from trade associations representing suppliers to stewards.
As a result of these submissions, the Draft PPP Stewardship Plan was revised to provide more clarity to address specific points raised by stakeholders and to address a number of general areas of confusion among numerous stakeholders.
Examples of specific points that were revised include:
- The reference to ‘estimated 50%’ in Section 1 was changed to ‘estimated 50% to 57%’ with a footnote citing the source document;
- A footnote was added in Section 2 to direct readers to MMBC’s draft definition of producer for purposes of obligation and reporting;
- The reference to Schedule 2 containers in Section 3.1 was revised and a footnote defining ‘empty container’ was added to more clearly define excluded packaging;
- The text introducing the bullets in Section 4.1 was revised to avoid misinterpretation that a local government that currently contracts for processing services is considered a primary processor;
- A footnote was added in Section 4.4 indicating that MMBC will work with the local government to mitigate confusion for residents where PPP collection service is provided by MMBC and garbage collection service is provided by the local government;
- A sentence was added in Section 4.4. to indicate that the market-clearing price will reflect collection system cost drivers;
- The word ‘and’ was added following the second bullet under single-family households in Section 5.2 to indicate that depots can be operated in areas in which curbside collection service is provided and the word ‘and’ and the third bullet were repeated under multi-family households to indicate that depots can service multi-family households; and
- The adjective ‘residential’ was inserted in a number of locations to specifically indicate the source of the PPP.
More substantial revisions were made to address areas of general confusion among stakeholders. In particular:
- The first two bullet points in Section 4.4 were revised to more precisely describe the distinction between curbside collection services and multi-family building collection services;
- A new sentence was added to the introduction in Section 4.5 to clearly state that MMBC will contract directly with processors and to more precisely describe the distinction between collection and post-collection services;
- A new Section 4.6 was added to describe the relationships that are expected to be established between collectors and processors;
- Section 5.1 was expanded to describe the sources of data for the numerator and denominator in the recovery rate calculation and the time required to compile and validate these data before MMBC is able to consult with stakeholders on a timeline to achieve the 75% recovery rate; and
- The list of indicators in Section 5.5 was expanded to include the quantity of PPP managed by recycling, recovery and disposal.
MMBC thanks those stakeholders who provided comments. Your feedback is important and is appreciated. Your submissions helped us prepare the final version of the PPP Stewardship Plan that was submitted to the Ministry of Environment on November 19, 2012.