Thank you very much. Thank you for the opportunity to provide a submission today.
As background, the Ontario Waste Management Association is a not-for-profit industry trade association. We represent over 300 private and public sector members who manage roughly 85% of the waste in Ontario.
Our members have diverse interests and capital investments in areas such as waste and recycling collection, landfills, transfer stations, material recycling facilities, energy from waste facilities, organics processing, and hazardous waste from both recycling and disposal perspectives.
Today's topic is quite expansive and would likely fill several days of discussion, so I have chosen to focus specifically on three areas in which the federal government should be taking a more active role. These are doing data collection, providing environmental standards, and ensuring competition and extended producer-responsibility programs.
I should emphasize that we are speaking in an Ontario context. The situation in each province is slightly different, but there are obviously a lot of consistencies.
Let me begin by providing some context about current problems and opportunities associated with waste management. The waste management sector is in the process of a monumental change. Previously materials managed were regarded as suitable only for disposal. This is certainly no longer the case. Waste collected is valued as a source of raw materials and energy that can be rerouted back into the economy after proper processing and collection. Recycled materials are actually commodities: aluminum, steel, paper, and so on.
Organizations are spending millions to pursue these commodities, but innovation and technological advancement can achieve only so much. Whereas there has been some success in harnessing the value of Ontario's waste, particularly residential waste, the overall recycling rate or diversion rate has remained relatively stagnant at under 25% for the last two decades. As a result the vast majority of our waste remains destined for disposal, and around three million tonnes of industrial commercial waste is exported to U.S. disposal facilities. That represents around one-third of Ontario's annual disposal needs. It represents an enormous loss of resources and economic opportunities.
It is not just the material or energy value from the waste that is lost but also the business opportunities associated with integrating recovered resources into new products and packaging that can be sold again. Diversion activities are hindered largely as a result of the wide differential between the cost of disposal and the cost of diversion. Issues related to convenience and capacity are also contributing factors.
As the waste management sector is largely dictated by regulation, it will take strategic government involvement to harness the value of waste as a resource. This involves utilizing economic tools and opening competitive markets coupled with environmental standards and oversight.
A Conference Board of Canada report released last week confirms what we have long known, that there is a significant net economic opportunity associated with waste diversion. A conservative estimate by the Conference Board of Canada suggests that if Ontario's waste diversion rate were increased to 60%, that increase would support close to 13,000 net new jobs in the province and provide a boost of about $1.5 billion to the GDP.
While jurisdictions throughout the world are moving forward with strategies to take advantage of waste diversion as an economic driver, we are being left behind. Over a year ago we released a report entitled “Rethink Waste”, which provided recommendations to better harness the economic benefits of resource management in Ontario. Several of these recommendations apply to the federal government.
Let me start with the need for sound data. Statistics Canada is currently the only source of broad-level information on the movement of waste materials in Ontario and across the country. I've referenced some of their numbers in my presentation so far. While it provides a reasonable high-level picture, it does miss large portions of data, and it lacks detail that would allow businesses and policy-makers to make more informed decisions. This is an area in which the federal government should be working with provincial governments and with the waste management sector to make improvements.
We've also consistently advocated the importance of environmental standards for the waste management sector. Currently companies that play by the rules in terms of quality and due diligence are often adversely impacted by companies paying scant regard to how their processes affect the environment and human health.
Without a common set of environmental standards, it is difficult, if not impossible, for recyclers and other diverters who have invested in sound technology and processes to compete in the marketplace, since non-conforming processors are able to sell their materials at a lower cost for higher margins. These standards are needed to help foster competition and innovation in the waste diversion sector by promoting a level playing field amongst processing facilities.
Evidence for this has been seen in the aftermath of China's Green Fence policy, which strictly enforces regulations on importing contaminated scrap materials into the county. While the policy has put some recyclers out of business, at least temporarily, it has opened up opportunities for those companies that invested in sorting equipment and labour as well as other features to deliver high-quality material.
In addition, an accountability framework is also necessary to enhance the transparency of material flows from the point of collection through to final disposition. There certainly have been a lot of concerns around the export of materials like waste electronics, plastics, and other waste materials.
With a vacuum in political leadership, the OWMA has moved forward with funding a process under the Canadian Standards Association to develop a broad-based recycling guideline. Our hope is that the guideline will be used by purchasers of services, including governments, or adopted by the government as a requirement to operate.
Finally, I want to touch on extended producer responsibility and competitive markets. EPR is an economic policy approach in which producers of products and packaging bear responsibility for ensuring proper end-of-life management of those materials. It is a policy concept that's been endorsed by the federal government and by the CCME.
The application of EPR has grown tremendously over the last five years and is expected to continue to grow across the province. In most jurisdictions, under this approach, stewards of designated materials combine into a single collective stewardship agency. These monopolies allow businesses to run collective programs, set recycling fees, and externalize these fees directly on to the consumer. In many ways, eco-fees are private taxation, in essence.
In Ontario, the Minister of Environment and all the political parties have referred to these agencies as a form of cartel. Take waste electronics as one example. The Electronic Products Recycling Association operates programs in B.C., Saskatchewan, Manitoba, Quebec, Nova Scotia, and P.E.l., and indirectly in Ontario. In these provinces, this entity is allowed to directly charge consumers over $115 million in fees annually, completely unhindered by government oversight or accountability.
Taking into account other materials including tires and beverage containers and new programs coming into effect, the impact on the consumer grows exponentially. The consumer has no choice but to pay these fees. It is amazing that the Competition Bureau has not addressed what is essentially fee-setting under the auspices of environmental protection.
In Europe, competition bureaus have started to take action. Germany and Austria have both recently taken steps forward towards market liberalization and the elimination of producer monopolies, which distort both consumer and recycling industry markets.
The German Federal Cartel Office indicates that, after addressing these monopolies, costs to consumers dropped by more than 50%.
The Competition Bureau in Canada should be taking action in this area. These issues have been brought to its attention, but as of yet there has been no substantive action. We have the opportunity to avoid the competition pitfalls experienced in Europe in this area, but the bureau really needs to engage this issue.
Thank you very much.