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HomeMy WebLinkAbout2025-10-03 Electronic Council Communications Information Package Date:October 3, 2025 Time:12:00 PM Location:ECCIP is an information package and not a meeting. Description: An ECCIP is an electronic package containing correspondence received by Staff for Council's information. This is not a meeting of Council or Committee. Alternate Format: If this information is required in an alternate format, please contact the Accessibility Coordinator, at 905-623-3379 ext. 2131. Members of Council: In accordance with the Procedural By-law, please advise the Municipal Clerk at clerks@clarington.net, if you would like to include one of these items on the next regular agenda of the appropriate Standing Committee, along with the proposed resolution for disposition of the matter. Items will be added to the agenda if the Municipal Clerk is advised by Wednesday at noon the week prior to the appropriate meeting, otherwise the item will be included on the agenda for the next regularly scheduled meeting of the applicable Committee. Members of the Public: can speak to an ECCIP item as a delegation. If you would like to be a delegation at a meeting, please visit the Clarington website. Pages 1.Region of Durham Correspondence 1.1 Winter Warming Centre Extension of Hours - September 29, 2025 3 2.Durham Municipalities Correspondence 3.Other Municipalities Correspondence 3.1 City of Kitchener - Postage - September 26, 2025 5 3.2 West Lincoln - Consultation on the Future of Community Natural Gas Expansion - September 26, 2025 7 3.3 Town of Midland - Opposing the Elimination of Automated Speed Enforcement (ASE) Cameras - September 25, 2025 8 4.Provincial / Federal Government and their Agency Correspondence 4.1 Minister for Seniors and Accessibility - Deadline Extension: 2025 Ontario Senior Achievement Award - September 29, 2025 10 4.2 Environment and Climate Change Canada - PFAS: Early consultation on Phase 1 ─ AFFF firefighting foams - September 26, 2025 12 5.Miscellaneous Correspondence 5.1 Ontario Producer Responsibility Organizations (PROs) regarding Blue Box collection from IC&I locations - October 1, 2025 15 5.2 Bowmanville Business Improvement Area - Advocacy for Co-Mingled Recycling Services in Commercial Areas under Blue Box Regulation (O. Reg 391/21) 20 (56 Signatures were included in the petition) October 3, 2025 Electronic Council Communications Information Package (ECCIP) Page 2 The Regional Municipality of Durham Social Services Department 605 Rossland Rd. E. PO Box 623 Whitby, ON L1N 6A3 Canada 905-668-7711 1-800-372-1102 durham.ca Sahar Foroutani Area Manager, Homeless System Management Sent Via Email September 29, 2025 The Corporation of the Municipality of Clarington 40 Temperance Street, Bowmanville, ON L1C 3A6 RE: Winter Warming Centre Extension of Hours Thank you for your correspondence dated September 24, 2025, regarding Resolution #C-191-25 and the request to extend hours for the Winter Warming Centre in Clarington. Durham Region remains committed to working collaboratively with Clarington and all local area municipalities to ensure that Winter Warming Centres can operate effectively across all communities. We recognize the importance of providing safe, warm spaces for individuals experiencing homelessness, especially during extreme weather conditions. The proposed extension of operational dates would have system- wide implications for the Winter Warming Program, including staffing requirements, resource allocation, and coordination among multiple service providers. At this time, the Region will maintain a standardized operating schedule for Winter Warming Centres, running annually from December 1 to March 31. While the extension of operating hours is an important consideration, the Region must prioritize the allocation of any resources toward the development of additional shelter beds, given the continued growth of the By-Name List. Expanding system capacity remains essential to Page 3 The Regional Municipality of Durham Social Services Department 605 Rossland Rd. E. PO Box 623 Whitby, ON L1N 6A3 Canada 905-668-7711 1-800-372-1102 durham.ca Sahar Foroutani Area Manager, Homeless System Management ensuring that a greater number of individuals have reliable access to safe and stable accommodations. Durham Region continues to work closely with Clarington to address local homelessness needs and greatly values Clarington’s ongoing efforts and advocacy. We continue to encourage community members to contact homelesshelp@durham.ca with any concerns or requests for support related to individuals experiencing homelessness. Thank you, Sahar Foroutani Area Manager, Homeless System Management Income, Employment and Homelessness Supports Division Social Services Department The Regional Municipality of Durham Page 4 AMANDA FUSCO Director of Legislated Services & City Clerk Corporate Services Department Kitchener City Hall, 2nd Floor 200 King Street West, P.O. Box 1118 Kitchener, ON N2G 4G7 Phone: 519.904.1402 Fax: 519.741.2705 amanda.fusco@kitchener.ca TTY: 519-741-2385 SENT VIA EMAIL September 26, 2025 Honourable Doug Ford Premier of Ontario Legislative Building Queen’s Park Toronto ON M7A 1A1 Dear Premier Ford: This is to advise that City Council, at a meeting held on August 25, 2025, passed the following resolution regarding postage: "WHEREAS Postage costs have seen significant increases, including 25% in 2025 alone; WHEREAS paper billing has a further environmental cost in both materials (trees) and transportation; WHEREAS paper billing is increasingly being displaced by environmentally friendly and cost-efficient e-billing; WHEREAS the Municipal Act indicates the right to a paper bill, and cost - recovery fees for paper billing for tax, and utility bills are unclear; THEREFORE BE IT RESOLVED that Kitchener City Council request the Province of Ontario to amend the Municipal Act to permit municipalities the ability to grandfather-out paper billing as the default option, and to permit municipalities to establish fees for paper billing for new accounts that opt for this method of delivery; THEREFORE BE IT FINALLY BE RESOLVED that a copy of this motion be sent to the Association of Municipalities of Ontario, the Premier of Ontario, the Ministry of Municipal Affairs and housing, all other municipalities within Ontario for their consideration and possible endorsement." Page 5 -2- Yours truly, A. Fusco Director of Legislated Services & City Clerk Cc: Hon. Rob Flack, Minister of Municipal Affairs and Housing Association of Municipalities Ontario (AMO) Sloane Sweazey, Senior Policy Advisor, City of Kitchener Ontario Municipalities Page 6 318 Canborough St. P.O. Box 400 Smithville, ON L0R 2A0 T: 905-957-3346 F: 905-957-3219 www.westlincoln.ca September 26, 2025 Ministry of Energy and Mines 77 Grenville Street Toronto, Ontario M7A 2C1 Re: Support Consultation on the Future of Community Natural Gas Expansion This is to confirm that at the September 15, 2025, Corporate Services Committee Meeting the following resolution was adopted with respect to the above noted matter: Supports the Ministry’s consultation on the Future of Community Natural Gas Expansion (NGEP Phase 3) and endorses access to natural gas as an option to other energy solutions to advance the Township of West Lincoln’s housing, employment lands, and economic development objectives. Directs staff to submit comments to ERO 0250923 reflecting Township of West Lincoln’s priorities, including: priority application types, alignment with Official Plan/Secondary Plans, sites and corridors where gas access would enable development (housing/employment lands), any Phase 1 and 2 learnings (if applicable) and practical barriers (e.g., timing, permitting, costs, land access). Forwards this resolution to MPP Sam Oosterhoff, the Minister of Energy and Mines, the Ontario Energy Board, AMO, and neighbouring municipalities. If any further information is required, please contact the undersigned at 905-957-3346, Ext 5129. Yours Truly, Justin J. Paylove Manager, Legislative Services/Clerk jpaylove@westlincoln.ca JJP/jmt cc. Sam Oosterhoff, MPP Association of Municipalities of Ontario Niagara Region Municipalities Ontario Board of Energy Page 7 Page 1 of 2 The Corporation of the Town of Midland September 25, 2025 Via Email doug.fordco@pc.ola.org Honourable Doug Ford Premier of Ontario Legislative Building Queen’s Park Toronto, Ontario M7A 1A1 Dear Premier Ford: Re: Council Resolution Opposing the Elimination of Automated Speed Enforcement (ASE) Cameras Please be advised that Town of Midland Council passed the following Resolution at their September 24th, 2025 Regular Council Meeting: Moved By: Councillor MacDonald Resolution Number: RES-2025-247 Seconded By: Councillor Ball WHEREAS a 2025 CAA survey of 1,500 Ontario drivers found 73 per cent actually support the use of speed cameras and 76 per cent say they deter speeding. A recent SickKids study also found they cut speeding around Toronto schools nearly in half; AND WHEREAS the Ontario Association of Chiefs of Police (OACP) who said “Employing ASE tools has been proven to reduce speeding, change driver behaviour, and make our roads safer for everyone — drivers, cyclists, pedestrians, and especially children and other vulnerable road users”; AND WHEREAS the Town of Midland entered into legal and good faith implementation of Provincially approved automated speed enforcement cameras to reduce speeds in our school and community safety zones and has committed to the continued installation of traffic calming infrastructure in our community whose funding source is fines from offenders rather than law abiding taxpayers; AND WHEREAS the Premier has announced his intention to introduce legislation to ban automated speed enforcement; BE IT resolved that Midland Council send this resolution expressing our opposition to any attempts to usurp this community safety initiative in our community and that copies be circulated to the MMAH, the MTO, AMO and Ontario Municipalities. CARRIED 575 Dominion Avenue Midland, ON L4R 1R2 Phone: 705-526-4275 Fax: 705-526-9971 info@midland.ca Page 8 Page 2 of 2 Yours Truly, Sherri Edgar Sherri Edgar Director of Legislative Services/Town Clerk cc. Hon. Rob Flack, Minister of Municipal Affairs and Housing, minister.mah@ontario.ca Hon. Prabmeet Sarkaria, Minister of Transportation, prabmeet.sarkaria@pc.ola.org MTO, mtoinfo@ontario.ca AMO, resolutions@amo.on.ca Ontario Municipalities Page 9 You don't often get email from ontariohonoursandawards@ontario.ca. Learn why this is important From:Michelle Chambers To:ClerksExternalEmail Subject:Deadline Extension: 2025 Ontario Senior Achievement Award Date:October 3, 2025 10:28:55 AM Attachments:image001.png From: Ontario Honours And Awards (MCM) <OntarioHonoursAndAwards@ontario.ca> Sent: September 29, 2025 6:40 PM Subject: Deadline Extension: 2025 Ontario Senior Achievement Award / Prolongation de la date limite : Prix d'excellence de l'Ontario pour les personnes âgées 2025 EXTERNAL (Un message en français suivra) Dear Friends, It is my pleasure to invite you to submit a nomination for the 2025 Ontario Senior Achievement Award. Each year, the program recognizes extraordinary seniors who, after the age of 65, have made significant contributions to their community or province. This is to inform you the deadline to nominate someone will be extended to December 1st. You can submit a nomination online by registering through the Ontario Honours and Awards Portal. For more information about the program, please visit the Ontario Senior Achievement Award webpage. You may also contact Ontario Honours and Awards Secretariat at OntarioHonoursAndAwards@ontario.ca, if you have questions about the Ontario Senior Achievement Award and how to submit a nomination online. Thank you in advance for taking the time to consider putting forward the name of a special senior in your community. Sincerely, Raymond Cho Minister for Seniors and Accessibility Page 10 ____________________________________________________________________________ _____________________________________________ Madame, Monsieur, J’ai le plaisir de vous inviter à proposer une candidature au Prix d’excellence de l’Ontario pour les personnes âgées de 2025. Chaque année, le programme rend hommage aux aînés extraordinaires qui, après l’âge de 65 ans, ont apporté une contribution exceptionnelle à leur communauté ou à la province. Nous souhaitons vous informer que la date limite pour présenter une candidature sera prolongée jusqu’au 1er décembre. Pour soumettre une candidature en ligne, veuillez-vous inscrire au Portail des distinctions et prix de l’Ontario. Pour plus de renseignements sur le programme, veuillez consulter la page Web du Prix d’excellence de l’Ontario pour les personnes âgées. Si vous avez des questions au sujet du Prix d’excellence de l’Ontario pour les personnes âgées, veuillez contacter aussi le Secrétariat des distinctions et prix de l’Ontario à OntarioHonoursAndAwards@ontario.ca. Je vous remercie d’avance de prendre le temps de songer à proposer le nom d’une personne âgée exceptionnelle de votre collectivité. Veuillez agréer, Madame, Monsieur, l’expression de mes sentiments les meilleurs. Sincèrement, Raymond Cho Ministre des Services aux aînés et de l’Accessibilité Page 11 1 Chambers, Michelle From:AFFF (ECCC) <AFFF@ec.gc.ca> Sent:September 26, 2025 12:08 PM To:ClerksExternalEmail Subject:SPFA: Consultation préliminaire pour la Phase 1 ─ mousses extinctrices AFFF / PFAS: Early consultation on Phase 1 ─ AFFF firefighting foams EXTERNAL English follows Bonjour, Vous recevez ce message, car Environnement et Changement climatique Canada a déterminé que vous pourriez être impliqué dans des activités en lien avec des mousses extinctrices qui contiennent des substances perfluoroalkyliques et polyfluoroalkyliques (SPFA), communément appelées mousses à formation de pellicule aqueuse (mousse AFFF). Consultation préliminaire par rapport à la proposition d’éliminer progressive les mousses AFFF C6 : Un document de consultation sur la Phase 1 de la gestion des risques liés aux SPFA, à l’exclusion des fluoropolymères : Interdiction de l’utilisation des SPFA, non réglementées actuellement, dans les mousses extinctrices a été publié pour une période de consultation publique de 60 jours se terminant le 25 novembre 2025. https://www.canada.ca/fr/environnement-changement- climatique/organisation/transparence/consultations/spfa-mousses-extinctrices-afff-phase1- interdiction.html Pour plus d’informations sur les activités liées aux SPFA et aux mousses AFFF au niveau fédéral, veuillez consulter cette page web : You don't often get email from afff@ec.gc.ca. Learn why this is important Page 12 2 https://www.canada.ca/fr/environnement-changement-climatique/services/gestion- substances-toxiques/liste-loi-canadienne-protection-environnement/sulfonate- perfluorooctane/mousses-pellicule-substances-toxiques-interdites.html Restez informé : Vous êtes invité à vous inscrire au Service d'abonnement pour la gestion des risques liés aux SPFA afin de continuer de recevoir les dernières nouvelles sur les mesures potentielles de gestion des risques proposées par le gouvernement du Canada par rapport à la catégorie des SPFA, à l’exclusion des fluoropolymères, dans le cadre du Plan de gestion des produits chimiques (PGPC), y compris celles en lien avec les mousses AFFF. https://www.canada.ca/fr/environnement-changement-climatique/services/gestion- substances-toxiques/inscription-gestion-risques-categorie-spfa.html Environnement et Changement climatique Canada | Gouvernement du Canada Hello, You are receiving this message because Environment and Climate Change Canada has determined that you may be interested in the risk management activities regarding firefighting foams used in firefighting that contain per- and polyfluoroalkyl substances (PFAS), commonly known as aqueous film-forming foam (AFFF). Early consultation on the proposal to phase-out C6 AFFF: A Consultation Document on Phase 1 of the Risk Management of PFAS, Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams was published for a 60-day public comment period ending on November 25, 2025. https://www.canada.ca/en/environment-climate- change/corporate/transparency/consultations/pfas-firefighting-foams-afff-phase1- prohibition.html Page 13 3 For more information on activities related to SPFA and AFFF at the federal level, please visit this Web page: https://www.canada.ca/en/environment-climate-change/services/management-toxic- substances/list-canadian-environmental-protection-act/perfluorooctane-sulfonate/film- forming-foam-prohibition-toxic-substances.html Keep in touch: You are invited to subscribe to the Risk management of the class of PFAS subscription service to continue to receive the latest news related to potential risk management activities being proposed by the Government of Canada on the class of PFAS, excluding fluoropolymers, under the Chemicals Management Plan (CMP), including those regarding AFFF. https://www.canada.ca/en/environment-climate-change/services/management-toxic- substances/subscribe-risk-management-class-pfas.html Environment and Climate Change Canada | Government of Canada Page 14 1 October 1, 2025 Circulated via email: mayor@clarington.net Adrian Foster Mayor Municipality of Clarington Re: Collection from IC&I Locations Dear Mayor Foster, In response to the request made by the Minister of the Environment, Conservation and Parks (MECP), the Producer Responsibility Organizations (PROs) representing producers obligated under the Ontario Blue Box Regulation consulted with municipalities and First Nations to support consideration of a collaborative and effective approach to IC&I. This included: • August 15, 2025: consultation with municipalities on the draft approach; • September 10, 2025: consultation with First Nations on the draft approach; and • Between August 15 and September 10, 2025: the PROs considered feedback, assessed implications to the common collection system (CCS) and reached consensus on next steps. As a result of these consultations, the PROs have agreed to allow the blending of eligible source and IC&I blue box material at depots with producers and municipalities assuming operational and financial responsibility for each party’s respective proportionate share of the blended material. Due to several unresolvable challenges that emerged from the analysis and stakeholder engagement, the PROs have determined that it is not possible to provide curbside collection to IC&I locations in municipalities. An overview of these challenges is provided below. Capacity: The CCS was procured for eligible sources included in Initial and Transition Reports. Further eligible communities with additional eligible sources were subsequently added by the MECP in December 2022 and February 2024. With these additions, the CCS has no remaining capacity for IC&I. The CCS was procured to service eligible sources receiving collection prior to transition and single-family households eligible for curbside collection of blue box material in 2026, as reported in Initial and Transition Reports, plus allowances for natural growth based on historical year-over-year growth. CCS procurement and the resulting contracts did not include capacity for non-eligible source blue box material. In response to requests from municipalities to provide sufficient time to prepare to service IC&I locations, CCS capacity procured for eligible sources was ‘loaned’ to non -eligible sources on a temporary basis during transition, on the understanding that the capacity Page 15 2 would become available again for eligible sources entering the system in 2026 and going forward. Following the CCS procurement process, expansion of the MECP’s Transition Schedule and the introduction of the MECP’s Outside-of-Transition Schedule added more eligible sources to be serviced. The CCS capacity loaned to non-eligible sources during transition is required to service the new eligible sources in 2026 and natural growth going forward. The graph presented in Figure 1 illustrates the number of non-eligible sources serviced during transition compared to the new eligible sources added since procurement, including the impact of these new eligible sources on the procured CCS capacity. Figure1: CCS Capacity Utilization The Total Eligible Sources in 2026 (in the right bar) is greater than the Eligible Sources in RFPs for which CCS services were procured (in the left bar) by the number of New Eligible Sources since RFPs. In addition to the eligible sources detailed in Table 1, the CCS is responsible for adding eligible sources arising from natural growth in 2027 and beyond. As illustrated, the CCS has no surplus capacity for non-eligible sources. Any additional stops or increased quantity per stop would jeopardize service to eligible sources and may trigger the acquisition of additional collection vehicles. Procuring additional collection vehicles would require 18 to 24 months lead time based on current supply chain realities, leaving the CCS without sufficient collection vehicles to service the eligible sources on January 1, 2026. This would impact resident collection services, which compromises our commitment to provide a seamless transition to EPR for Ontarians. Regulatory Obligation: Servicing IC&I creates risk for the CCS and producers in meeting regulatory obligations. The final step in the transition to full extended producer responsibility is taking place in January 2026, requiring PROs to meet post-transition obligations set out in Ontario’s Blue Box Regulation. This is a substantive change for the province of Ontario and requires considerable effort. - 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000 Eligible Sources in RFPs NES during Transition New Eligible Sources since RFPs Total Eligible Sources in 2026 Eligible Sources in RFPs, Non-eligible Sources During Transition, New Eligible Sources Since RFPs and Total Eligible Sources in 2026 277,023 5,059,324 46,472 5,336,347 Page 16 3 Implementing CCS IC&I blue box services within the six-month timeframe provided by the Minister on June 4, 2025 would create risk for disruption of services to eligible sources and compromises the ability of PROs to meet the regulatory obligations of their producers. Regulatory Obligation: IC&I material in performance reporting is contrary to the Ontario Blue Box Regulation. In developing the approach to IC&I services, PROs assumed that producers would not be required to deduct IC&I material from reporting in the six performance categories. RPRA has indicated that the Blue Box Regulation does not permit materials collected from the IC&I sector to be counted towards producers’ performance requirements. This poses a challenge as: • Deducting IC&I from performance reporting significantly compromises the reconciliation of blue box material picked up by each PRO with blue box material supplied by each PRO’s producers in each of the six performance reporting categories. This reconciliation process is already complex in meeting the regulatory reporting timelines. Further complications to this process cannot be borne. • Deducting IC&I from performance reporting substantially increases sampling and auditing of collected materials which would further increase the preliminary cost recovery rates well above private sector service options. Timing: The CCS and municipalities cannot complete the required tasks by January 1, 2026. Municipalities report there is insufficient time for staff to complete their review and municipal councils to reach their decisions prior to the October 31, 2025 deadline for execution of IC&I service agreements. The October 31, 2025 deadline for execution of IC&I service agreements cannot be deferred given the January 1, 2026 timeline. Eligibility: CCS cannot address the needs of IC&I locations serviced by municipalities. CCS eligibility criteria for curb collection from IC&I are required to: • Limit the amount of blue box material collected from IC&I locations as the CCS has no surplus capacity. • Predict the quantity set out by an IC&I location to ensure accurate cost recovery rates to fully recover IC&I costs and to avoid charging producers for IC&I service (i.e., IC&I locations cannot set out more than the cost recovery rate covers); and • Align curbside service with CCS curbside collection contracts. The implications of the eligibility criteria for municipal buildings, BIAs and other IC&I locations are illustrated in the following table. Page 17 4 Table 1: CCS IC&I Eligibility Criteria Implications Feedback from municipalities on the August 15, 2025 proposal indicated many IC&I sources do not meet the CCS eligibility requirements in the right column of Table 1. Municipalities would need to seek alternative solutions for their IC&I locations that would not be eligible as set out in the middle column of Table 1. Costs: CCS cost recovery rates for small IC&I are higher than private sector quotes to municipalities. Preliminary estimated CCS cost recovery rates for small IC&I are substantially higher than private sector costs being quoted to municipalities, according to recent media coverage, for IC&I service. These preliminary estimated CCS cost recovery rates are likely to increase as a result of change notices to, and cost estimates from, affected CCS contractors. As final cost recovery rates cannot be set until the change notice process is complete, any municipal council decisions would be based on preliminary cost recovery rates that are subject to adjustment. Such uncertainty further complicates council decision-making processes. CCS cost recovery rates for larger IC&I cannot be calculated as the quantity per IC&I set out cannot be predicted. Alternative Options: Municipalities have other options to service IC&I. Some municipalities have already contracted, or implemented procurement processes, for IC&I services in 2026. Municipalities can leverage ‘at the curb’ efficiencies in their garbage and organics collection systems without encountering the complexity of EPR requirements. The northern and rural communities identified by the MECP are already providing garbage and blue box collection services for larger IC&I. Establishing the CCS has resulted in a private company operating in each community on the MECP’s Transition Schedule and Outside-of-Transition Schedule. Municipalities that did not previously have a private sector option available in their community may now be able to explore IC&I services from these companies. Page 18 5 Summary We thank you for your feedback during the consultation process. After consultation and analysis, system capacity limitations, current regulatory obligations, and time constraints for both the CCS and municipalities make it impractical for the CCS to provide curbside collection from IC&I locations. While it is not feasible for the CCS to provide curbside collection from IC&I locations, PROs have agreed to allow blending of eligible source and IC&I blue box material at depots with physically sharing of responsibility by producers and municipalities. The CCS will pick up its proportionate share of blue box material from required depots and will be responsible for management of this material. The municipality will be responsible to haul, consolidate if required and process the remaining blue box material accepted at the depot. Municipalities should make the appropriate arrangements to do so prior to January 1, 2026. Municipalities with IC&I locations provided with curbside collection of blue box material by the CCS during transition should have alternative arrangements in place prior to January 1, 2026, as these IC&I stops will no longer be serviced by the CCS as of this date. We welcome the opportunity to meet with you to address any questions. Sincerely, Allen Langdon Chief Executive Officer, Circular Materials Gordon Day Vice President, Ryse Solutions John Hayes President, Landbell Canada (formerly H2 Compliance) Cc: Mary-Anne Dempster, CAO, Municipality of Clarington Page 19 Page 20 Page 21 Petition To the Legislative Assembly of Ontario WHEREAS Under Ontario Regulation 391/21: •Blue Box producers are only responsible for recycling from eligible sources.•'Ineligible sources' such as businesses, places of worship, daycares, campgrounds, public-facing municipal spaces, and non-profit organizations are excluded from producer responsibility. This forces municipalities to either: •Absorb 100% of the cost of recycling for these 'ineligible' sources, or•Discontinue recycling services to these vital community spaces and busi nesses. We the undersigned petition the Legislative Assembly of Ontario to amend Ontario Regulation 391/21 so that producers pick up all recycling materials (from both eligible and non-eligible sources), or direct or encourage producers and producer responsibility organizations (PROs) to allow for the commingled co-collection of recyclables from eligible and non-eligible sources within the same service streams. Page 22 Page 23