August 5, 1998

Honourable David Tsubouchi
Minister of Consumer & Commercial Relations
35th Floor, 250 Yonge Street
Toronto, Ontario
M5B 2N5

Dear Mr. Tsubouchi,

I am writing this letter to convey the Citizens' Network on Waste Management's (CNWM) concern regarding the possible repeal of Regulations 340 and 357 (Container Regulations) under the Environmental Protection Act, as well as to express the CNWM's support for a deposit-return system for beverage containers, in particular, L.C.B.O. containers.

Background
The Container Regulations mandate that at least 30% of soft drink packaging are to be sold in refillable bottles, and are subject to a deposit-return collection system. Currently, the amount of sales volumes in refillable containers is less than 2%, as the Ministry of Environment (MOE) has not enforced the Container Regulations since 1991.

Recently, the MOE has drafted a proposal for a new waste diversion program for Ontario. Our understanding is that the MOE intends to recommend that the government remove the deposit-return and refilling requirements from regulation 340, and revoke regulation 357 in its entirety. The net effect of these proposals would be to eliminate the soft drink refillables quotas and the deposit-return system for refillable soft drink containers.

Deposit-Return Systems
While Ontario's Blue Box recycling program has made an impact on waste reduction, the environmental and economic (in)efficiencies of the Blue Box, combined with the Province ending its financial commitment to the Blue Box in March 1996 , and the failure of industry to pay for Blue Box costs have led many municipalities to look at options to improve their recycling programs by taking beverage containers out of the Blue Box and landfills, and subjecting them to a deposit-return system.

The CNWM is not alone in our support for deposit-return systems. To date, more than 50 environmental/citizen groups have endorsed this concept. As well, 250 distinct Ontario municipalities representing 84% of Ontario's population support a deposit-return system for beverage containers through the endorsement of various council resolutions. Deposit-return systems do not compete with curbside programs. Evidence suggests that the two systems are compatible, and when used together achieve higher recovery rates and recycling rates, and reduce overall waste diversion costs.

If the government revokes the Container Regulations, it is probable that the soft drink industry will sell its deposit-return system infrastructure, making it impossible to ever again implement such a system for their containers. It is for these reasons, among others, that we would like to have your support in the maintenance of Regulations 340 and 357.

We also support the immediate implementation of a deposit-return system for the L.C.B.O. because glass is the most problematic and least cost-effective material to collect. Furthermore, the L.C.B.O. is about to begin a sizeable capital modernization program for its stores, and is a provincial crown corporation with a centralized and exclusive distribution system. These factors make the L.C.B.O. a prime candidate for a deposit-return system for the containers it sells.

Thank you for your attention to this matter.

Sincerely,


John Jackson
Coordinator

cc: Honourable Michael Harris, Premier of Ontario
Honourable Norm Sterling, Minister of Environment

Minister Tsubouchi's response to this letter