Comments and Reply: Waste-Export Reduction Plans

• Application of Plans
• Content of the Plan
• Information Collection and Analysis

A number of comments were received by environmental groups, provincial, industry and association stakeholders with respect to the provisions for waste export reduction plans set out in the proposed Regulations.

A province and a number of environmental group stakeholders commented that:

Waste export reduction plans should equally apply to imports of hazardous waste and should not be limited to exports. In addition the reduction plans should apply to all four streams: exports of both hazardous waste and hazardous recyclable materials and imports of both hazardous wastes and hazardous recyclable materials.

There is also a need to focus on source reduction and pollution prevention rather than hazardous waste recycling.

Industry and association stakeholders commented that:

Response: Section 188(1) of CEPA 1999 provides the Minister with the authority to request an exporter or class of exporters of hazardous waste for final disposal to submit and implement a plan for the purpose of reducing or phasing out the export of the waste. Section 191(g) of CEPA 1999 takes into account the proximity or benefit of using the nearest appropriate disposal facility, and the increased production of goods responsible for generating the hazardous wastes for disposal. The proposed Regulations define the information to be included in such plans.

A number of comments were received by industry and association stakeholders with respect to the content of the plan and the information collection and analysis of the plans.

Response: Environment Canada agrees that some of the proposed provisions may impose requirements that are too demanding. As such, two of these provisions have been replaced with a more practical one. An exporter who submits a plan may ask that it be treated as confidential under CEPA 1999 if it contains confidential information.

Response: Environment Canada will notify exporters when they are required to prepare a reduction plan for the export of waste destined for final disposal. Regulatees who have been asked to prepare a plan must submit it before a permit to export will be granted.

Environment Canada anticipates that one of the triggers for requiring export-reduction plans will be based on its review statistics in addition to the notification information of 8(j)(ix), the reduction or phase-out options considered, and the reason the disposal is taking place outside Canada.