Board of Directors Meeting Highlights

Held on July 20, 2016 at 9:00 AM at the Bluewater Recycling Association

Material Recovery Facility

Receiver Appointed For Sarnia Company That Employs 155 Workers

A Sarnia-based plastic recycling company with 155 employees announced Thursday it has ceased manufacturing operations. Entropex, located on Lougar Street in Sarnia, said that its bankers went to court earlier in the day Thursday to ask for the appointment of a receiver to take over management and control of the company. Entropex has struggled in recent months to meet financial challenges caused by declining oil prices and a competitive business environment. Despite our best efforts to reduce costs, the costs of operating Entropex's business remain prohibitively high and sustainable. Because of the company's deteriorating financial position, its bankers moved earlier this month to call Entropex's loan. As a result of the bank actions, Entropex has ceased manufacturing operations effective as of 3 p.m. on Thursday, July 14. We have a tremendous team here, Entropex president Keith Bechard said Thursday. It has been a very challenging environment, and we've done as much as we could possibly do. The company's management does not know if, or when, operations will resume. That decision is in the hands of the court-appointed receiver, MNP Ltd. The company has been in operation since 1978. WDO Brings Some Good News, And Some Bad News To Municipalities

Ontario municipalities received good and bad news in June as Waste Diversion Ontario (WDO) made a decision about how much they should be paid for running Ontario’s blue box program. In a bulletin released June 20, WDO noted that in its review of all of the many consultant and staff reports and documents prepared in recent months to help guide this decision, the Board wanted to ensure that its decision was fair and reasonable, particularly given the wide gap between Stewardship Ontario’s recommendations on the one hand, and the Association of Municipalities of Ontario (AMO)/City of Toronto’s recommendations on the other. WDO said it also wanted to ensure that these reports were prepared and discussed with stakeholders in a transparent manner that gave the parties every opportunity to review and comment on the scope of work and on recommendations before they were finalized. On June 15, 2016, the Board invited both Stewardship Ontario and AMO/City of Toronto to make separate presentations during the Board meeting. In the end, the WDO Board set the 2016 funding obligation at $121.5 million, a 6% increase over the 2015 funding obligation, after making the following adjustments to the 2014 reported Gross Costs of $337.7 million:

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• The addition of $2,286,031, representing the cost of In- Kind advertising. (WDO reviewed the ads placed in 2013, 2014 and 2015 and determined that 49% of the ads were Blue Box related and therefore, only 49% of the amount spent should be an eligible expenditure.)

• The normal annual process was used to calculate the three year rolling average of commodity revenue received by municipalities and $88,700,190 was deducted.

• The normal annual process was used to apply Prior Year Adjustments (PYAs) as a result of WDO’s audits of municipality’s 2014 Datacall submissions and $128,934 was added.

This resulted in a Net Cost of $251,494,341 which was further adjusted as follows:

• Dividing the net cost in half to arrive at Stewardship Ontario’s 50% share of $125,747,171 as is required by the Waste Diversion Act, 2002.

• The net cost deduction of $6,185,076 to reflect the application of cost containment principles, i.e. Cost Bands to adhere to the principles in the Cost Containment Plan. This was the amount recommended in the Final Report of the Working Group (which was comprised of expert consultants with both municipal and steward backgrounds).

• Deducting $109,543 representing the net cost of non-obligated material in the municipal Blue Box system as was recommended in the Final Report on the Review of Non-Obligated Material.

• Adding $2,100,000 reflecting a contribution by Stewardship Ontario associated with the increase in costs resulting from changes in the nature of packaging material in the Blue Box stream to adhere to the principles in the Cost Containment Plan.

The WDO Board also determined, based on the recommendations of the Continuous Improvement Fund (CIF) Committee (of which Stewardship Ontario, AMO and the City of Toronto are members) that $4,200,000 of the 2016 steward obligation amount will be allocated to the CIF. As part of the motion approving the 2016 funding obligation, the Board also:

• Directed WDO staff to review and improve the data sources used by the Working Group in the development of the Cost Containment “Model”.

• Asked that WDO develop better and more precise instructions to municipalities concerning non-obligated materials to ensure further non-obligated material costs are removed from future steward obligations.

• Approved the In-Kind Guidelines revised in accordance with the Report of the Cost Containment Panel and WDO December direction to staff.

WDO has not re-opened the 2015 funding obligation that was determined in June 2015. The WDO Board directed Stewardship Ontario to commence paying the 2016 industry funding for each municipality’s Blue Box program on or about June 30, 2016.

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Regulations Under The Waste Diversion Transition Act, 2016

The Waste Diversion Transition Act, 2016 (WDTA) provides the Ministry of the Environment and Climate Change with an approach to wind-up the four existing waste diversion programs that were established, and are currently operating under, the Waste Diversion Act, 2002 (WDA). The WDTA would also enable the wind-up of the industry funding organizations that operate these programs. In order to wind-up the programs and the industry funding organizations under the WDTA, the programs and their governing regulations must first be transferred from the WDA to the WDTA. The Ministry of the Environment and Climate Change is proposing regulations under the WDTA for the purposes of transferring the four waste diversion programs to the WDTA. Until the programs are wound-up and the wastes managed under the programs are transitioned to the new producer responsibility framework under the Resource Recovery and Circular Economy Act, 2016, the programs will operate under the WDTA. The four waste diversion programs are for:

• blue box waste; • municipal hazardous or special waste; • used tires; and • waste electrical and electronic equipment.

The proposed regulations will be updated to reflect the provisions in the WDTA and current drafting standards. They will continue to address the designation of wastes, governance of the three industry funding organizations;

• Ontario Tire Stewardship, • Ontario Electronic Stewardship • Stewardship Ontario, and • as well as prescribe a cost recovery fee methodology for the used tire and municipal hazardous

or special waste programs. The proposed changes are largely administrative and technical in nature. If made, the proposed regulations would come into force simultaneously with the coming into force of the WDTA and the repeal of the Waste Diversion Act, 2002. If approved, the proposed regulations would enable the smooth transfer of the existing waste diversion programs from the WDA to the WDTA, as well as the wind-up of the programs under the WDTA once the wastes managed under the programs are transitioned to the new producer responsibility framework under the Resource Recovery and Circular Economy Act, 2016. US Paper Recovery Nears 52 Million Tonnes In 2015

According to data from the American Forest & Paper Association (AF&PA), around 52 million tonnes of paper was recovered in the U.S. last year. The association estimates the overall paper recovery rate at an all-time high of 66.8%, which compares to 65.4% in 2014. AF&PA credits the higher numbers to growth in the country’s recycling infrastructure and to paper mill demand for recovered material. Overall paper generation in the USA fell slightly to just under 78 million tonnes in 2015 and has dropped around 25% since 1999. OCC generation reached 33.7 million tonnes last year - of which 31.3 million tonnes, or 92.9%, was recovered.

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Declines Seen In Exports Of Most Materials

Export figures for recyclable materials continue to slump when compared with 2015 totals. In April, the most recent month for which figures are available, scrap plastics exports totaled 401.67 million pounds, an increase of 11.8 percent from March 2016 export levels. That marked the third straight month of volume gains over 10 percent. When matched against April 2015 levels, however, the volume of plastic scrap exports in the month was down by 10.7 percent. Meanwhile, the weighted price of recovered plastic exports in April 2016 was 16.8 cents per pound, down 2.0 percent from its March standing. That price-per-pound figure was down 8.7 percent from the price level in April 2015. With 1.34 billion pounds of scrap plastics exported through the first four months of 2016, the volume was down 7.7 percent from the April 2015 year-to-date (YTD) figure. At 17.0 cents per pound, the average price through April 2016 was down by 8.6 percent from its 2015 YTD standing. As for other exported materials, recovered paper exports were up slightly through the first four months of 2016. Through April, 6.63 million metric tons were exported, a 3.5 percent increase from April 2015 YTD levels. At $150 per metric ton, however, the weighted average price of exported recovered paper through April was down YTD by 5.2 percent. The 4.42 million metric tons of ferrous scrap exported through April 2016 amounted to a 20.2 percent YTD decrease. This was the fourth month in a row of YTD declines over 20 percent in the ferrous category. At $332 per metric ton, the weighted average price of exported ferrous scrap was down 21.1 percent from April 2015 YTD levels. Finally, the 920.09 million pounds of aluminum scrap exported in 2016 through April amounted to a 9.0 percent decrease compared with the April 2015 YTD figure. At 62 cents per pound, the average price of exported aluminum scrap through April 2016 was down by 17.3 percent compared with last year’s total through April. This report is based on statistics provided by the U.S. Department of Commerce and the U.S. Department of Labor – Bureau of Labor Statistics.

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ISRI: Paper From Mixed Waste Not Up To Snuff

Survey results released by the Institute of Scrap Recycling Industries indicate buyers of recovered fiber have second thoughts when it comes to material from mixed-waste processing operations. Released late last week, ISRI's survey of 41 industry representatives found that more than 75 percent steer clear of paper from mixed-waste recycling facilities. Of those respondents that do purchase some paper from mixed-waste outlets, 70 percent said the quality was worse than "most other recovered paper purchased." In mixed-waste processing systems, garbage and recyclables are collected in one bin, and facilities aim to separate out marketable material. The strategy has gained some traction in the municipal space in recent years. ISRI, which has formally opposed mixed-waste processing in recent years, said in a press release the latest survey results from RRS prove why "one-bin systems continually fail." "Where mixed-waste processing is used, the recycling of paper is significantly diminished, both in quality and quantity," stated Robin Wiener, ISRI's president. "There is little, if any, market for such paper. Communities that are still debating between one-bin and dual-stream operations can now better make an informed decision." Several communities across the U.S. have discussed the potential of moving toward mixed-waste processing as a way to unlock higher recovery rates, but many in the recycling industry have vehemently opposed the method, especially when it comes to the issue of recovered fiber. In February, Indianapolis announced it would suspend its plans to allow Covanta to build a $45 million mixed-waste operation to handle the City's solid waste. In March, Houston officials, who had also toyed with the idea, opted to renew a contract with Waste Management that will keep single-stream recycling in place for at least the next two years. According to the recent survey, conducted on ISRI's behalf by consultancy RRS, contamination, odor and low quality were the top three reasons buyers choose not to purchase fiber from mixed-waste operations. It did not address the viability or quality of other recovered materials generated by mixed-waste operations. A study from the American Forest & Paper Association from last October found that while mixed-waste facilities often produce lower-value recovered paper, the facilities have the potential to unlock more recovered plastics and metals than single-stream operations.

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Trash Limits Designed To Extend Life Of Landfill

City council this week debated staff’s recommendation to cut by 25 per cent the amount of trash Londoners are allowed to put out curbside for collection. A classic example of the small-but-important issues municipal governments handle, it was decided in a lopsided vote. Here are the details: Since 2006, Londoners have been limited to putting out no more than four garbage containers per trash collection. That could mean four individual bags, or four containers containing several bags, up to 20 kilograms each. So that’s a total of 80 kg of trash per pickup, or the equivalent of a typical grown man. City staff proposed lowering the limit to three containers, still at 20 kg apiece. That’s still a lot of trash. Coun. Stephen Turner’s push to lower the limit to two, backed by Coun. Anna Hopkins, failed. A “container” is best described as “a single lift” by trash collectors, whether it’s an individual bag or a 20-kg container. About 91 per cent of Londoners already put out three containers or fewer. The city average is actually two containers per home. But in a recent city survey that drew 5,000 responses, 59 per cent said they wanted the four-container limit unchanged. Without increased waste diversion, London’s landfill has enough space to last about nine more years. Council voted to lower the limit to three containers from four but only after Turner’s push to lower it to two was defeated. The new limit will start being enforced mid-January 2017. Staff will report back on a proposal to sell $1.50 “garbage tags” for anyone putting out more than three containers; if approved, they would be available starting in January. Peel Set To End Curbside Collection Of Large Home Appliances

Peel Region will end curbside collection of large home appliances at the end of June. Items such as refrigerators, stoves, iceboxes and freezers, washing machines and dryers, furnaces and dehumidifiers, hot water tanks and metal bath tubs will not be picked by the region’s waste collection personnel after June 30. If residents want to book an appointment before the program ends, they must do so before 12 p.m. on Friday, June 24 at peelregion.ca/waste. Pick up fees apply. “Our goal is to meet residents’ needs while delivering cost-effective services,” said Waste Management Director Norm Lee in a news release. “Due to low uptake of the service, coupled with the fact that there are charitable and private organizations picking up appliances, and an ongoing challenge to complete the pick up before scrap metal collectors, it became apparent that it was no longer necessary for the region to continue delivering this curbside service.” For a full list of items that will no longer be collected by the region, visit peelregion.ca/waste.

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MMBC Refuses To Pay RDEK's Recycling Invoice

The Multi-Material BC (MMBC) Corporation has responded to an invoice sent by the Regional District of East Kootenay(RDEK), with MMBC telling the RDEK it has no intention of paying. In April 2016, the RDEK sent a $764,000 invoice to MMBC for costs the RDEK incurred collecting and processing recyclable materials identified in the recycling regulation of B.C. and part of the Packaging and Printed Paper Stewardship Plan operated by MMBC — a move that RDEK directors said, at the time, was meant to highlight the lack of recycling service provided by MMBC to rural and remote areas such as the East Kootenay. The RDEK board of directors received, at their Friday, June 10th meeting, a reply from MMBC managing director Allen Langdon, in which Langdon writes that MMBC will “not be honouring” the invoice, and that if the RDEK “wish to be placed on MMBC’s wait list, (it) will need to be in a position to comply with the mandatory requirement of secured and supervised bins.” The invoice stems from money the RDEK spent collecting household recyclables through its yellow bin program. When MMBC took over over responsibility for most recycling programs in B.C. in May 2014, it told the RDEK the yellow bin program would “not fit” MMBC’s service model. In the yellow bin program, 739 large yellow dumpster bins are placed in East Kootenay communities, usually near businesses, schools or in other prominent locations, for commercial, residential, industrial and institutional use to collect recyclable materials. To make the invoice, RDEK staff calculated how much of the waste collected in the yellow bins came from residential sources. “RDEK’s bins are not staffed and therefore fall outside of the requirements for depots in MMBC’s program that any bins must be secured and supervised,” wrote Langdon, adding “MMBC has no plans to include unstaffed bins in the programs due to contamination concerns.” “The response from MMBC is what I expected, bringing attention to the issue. The way that some parts of rural B.C. collects recyclables doesn’t fit the model that MMBC offers,” RDEK Area F director Wendy Booth told The Echo just prior to the RDEK board meeting, adding “the Ministry of Environment has a target of 75 per cent compliance across the province, which I believe MMBC is meeting, however the target should be 75 per cent in each region, as some areas of the province are not meeting that target.” “My initial response was I called it (the MMBC response) a load of horse poo, but it doesn’t come as a surprise. We all knew they wouldn’t pay,” said Invermere mayor Gerry Taft, speaking the afternoon after the meeting. “They have a whole bunch of excuses about why they don’t provide service. It’s really frustrating. They have a one-size-fits-all model that works well in urban centres and densely populated areas, but doesn’t work at all in the more rural areas, such as the East Kootenay.” That MMBC model is centred around curbside pickup, and offers no scope for something such as the yellow bin program, he said, adding that if the RDEK were to comply with the MMBC’s requirements, it would likely mean having three or four supervised yellow bins through the whole East Kootenay, instead of the current 739 unsupervised ones. And that means in our area, and other areas in a similar situation, consumers are paying twice. Private companies are embedding the cost of the program into the products they sell. In areas where MMBC provides service, those are the only costs for residents. Here residents are paying those embedded product costs and then they are also paying the tax for the yellow-bin program. The solution rests with the province. The province created this mess; the province should fix it. It really comes down to money.

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Automatic For The People: Edmonton Urged To Adopt High-Tech Garbage Collection

The world is moving to automated garbage pickup and Edmonton better get on board or prepare to pay higher costs for customized old-school trucks. In a list of 15 cities — the major ones from across Canada, Alberta and in the Edmonton region — the capital is the only city with no automated pickup. “We can push against that trend,” said utilities branch manager Chris Ward, but “it’s becoming harder and harder to buy a truck that’s not automated.” City councillors will get a formal overview of what that decision means in August. Residents should expect a series of open houses and questionnaires over the winter. A plan for implementation should be in front of council in 2018. The move comes with a lot of questions: who pays for the new wheeled carts each resident will need? Will homeowners be limited to one cart full of garbage? Where on the property will you need to place cart to let the new robotic arm easily dump it in the bin? Will Edmonton add a green cart to separate food waste and compost? Coun. Michael Walters called food waste “a huge issue. Across Canada, 40 per cent or more of food gets thrown out. Almost one million people wasting a lot of food puts a lot of demand on our facility.” Currently, much of that waste gets sorted and composted by the City of Edmonton at its waste management facility. Some of it goes to a landfill. Leduc, St. Albert, Strathcona County and Spruce Grove have automated collection for garbage and compost. Fort Saskatchewan has a pilot project to collect garbage, organics and recycling by trucks with robotic arms. Union officials are in favour because of improvements to worker quality of life and safety, said Mike Scott, president of Local 30 of the Canadian Union of Public Employees. At least one contractor, Progressive Waste Solutions, is in favour, too. It switched its Camrose crews to automated trucks in May. “Finding people now a days willing to do that manual work, it’s getting more and more difficult all the time,” said Dave Martens, the company’s district manager for northern Alberta. Most employees last only five years on the job, lifting anywhere from 15 to 30 tonnes of garbage a day. The company is constantly hiring. “Their body wears out — shoulders, rotator cuff,” Martens said. “They are the athletes of our industry. They have to be in peak physical condition every day.” Trent Tompkins, director for waste collection services, said Edmonton has been slower to move on this because it’s focused on improving processing and separation of waste. A chain of complications make the old trucks more expensive. First, the back hopper needs to be lower for workers to hoist in the garbage. That means taking the truck off the job and cutting down into the frame. But then the lower hopper displaces the emission control system, which normally runs under the truck, so it needs to be moved behind the cab. That requires a longer truck body, which makes them more difficult to manoeuvre in Edmonton’s back alleys.

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Panama Builds Village From 1 Million-Plus Plastic Bottles

An eco-residential community consisting of between 90 and 120 homes, and made entirely out of plastic bottles, is being built in Panama. Every home incorporates between 10 000 and 25 000 used plastic bottles.

According to the project’s website, a person born after 1978 who lives to be 80 years of age will leave behind a minimum of 14 000 plastic bottles. The site also states that a two-storey plastic bottle house of 100 square metres or 1000 square feet per floor can be built reusing 14 000 plastic bottles, thus ‘neutralising the negative effect of your passage on this planet’. The bottles also serve as an insulation agent within the concrete walls, resulting in an interior temperature that is 17 degC cooler than the exterior, and in turn making the homes energy-saving. The structure is also said to be earthquake-resistant as the panels flex slightly and release energy. Over the three phases of development, the village will consist of around 120 homes per lot, a small boutique and an eco-lodge that will mesh with a fruit, vegetable and herb garden for the community. Phase one began in late 2015 with the construction of the community’s first single-storey, two-bedroom house. Work on the project’s second model home commenced in early 2016. Sale of homes in phase one has already begun and 36 natural lots are left. For more information, visit: www.plasticbottlevillage.com

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EuRIC: Pull Measures Needed To Make Circular Economy Work

Europe: The European Commission’s revised Circular Economy package ‘should have proposed a number of regulatory “pull” measures so as to correct existing market failures’ and thereby help create ‘strong and resilient markets for secondary raw materials’, according to a joint statement from the European Recycling Industries’ Confederation (EuRIC) and the FEAD waste management federation.

For a Circular Economy to work in practice, they argue, waste which cannot be prevented must be capable of being recovered as a useful resource in line with the waste hierarchy. ‘This will only happen if the recovery of those waste resources is economically viable at prices which reflect the true cost of collecting them, sorting them, recycling and marketing them to end users,’ EuRIC and FEAD insist. ‘It is therefore key to reward the environmental benefits of recycling and level the playing field with virgin materials.’ EuRIC and FEAD have also called for: minimum recycled content requirements for selected products; minimum green public procurement requirements at EU level to boost purchases of recycled products and materials; amendment of eco-labelling rules to incorporate indications of recycled content and recyclability; and encouragement of member states to adopt fiscal and financial incentives - such as a lower or zero rate of VAT - to favour secondary raw materials. European Commission proposals to ban separately collected waste from landfill and to set binding recycling targets for municipal waste ‘are very much welcomed’, they continue. But while targets would increase supply of secondary raw materials, they would not automatically create demand for them, it is pointed out. ‘We need to make sure that European legislation lays down the framework conditions to support a sustainable demand for those secondary raw materials, so that the economics of a Circular Economy become self-supporting,’ they insist.

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Brewery Has Created Six-Pack Holders That Can Be Eaten By Marine Life

When you’re cracking open a cold can of beer, the last thing you want to think about is that plastic six-pack holder it came in ending up around a seagull’s neck or in a turtle’s stomach. So, one Florida-based craft beer brewery has come up with an ingenious solution. Saltwater Brewery is rolling out fully edible six-pack rings for their Screamin’ Reels IPA, with the help of advertising agency We Believers. The holders are made out of a pulp from byproducts of the brewing process, such as wheat and barley. Not only does this make them totally biodegradable, but they’re also just as strong as their plastic counterparts. So far, the company has created a few hundred of the holders. However, they hope to up their production to cater for 400,000 six-pack rings every month, Gustavo Lauria, CCO and founder of We Believer, told Creativity-Online. More than that, the companies have high hopes that the larger breweries and drinks companies could also follow suit and develop their own edible six-pack ring holders. In many states, conventional six-pack rings now have to be made 100 percent photodegradable under federal law. Although this may have somewhat eased the problem for marine life, an estimated 1 million birds and 100,000 marine mammals and turtles still die from the six-pack holders a year, after being entrapped or swallowing them. Nevertheless, with the world’s oceans becoming progressively more and more clogged with plastics, seeking inventive solutions to consumable packaging is always a welcoming idea. Landfill Assessment Methodology Review

On June 30, 2016, The Minister of Finance accepted the recommendations of the PricewaterhouseCooper (PwC) report on landfill assessment methodology. While direction on this file is appreciated, there are concerns by inaccuracies in the report and the direction provided. The main concerns revolve around two aspects of the recommendations: • The creation of a new property tax class and tax ratios specific to landfills, and, • Mandatory data collection, which negates the right of appeal. These recommendations are not in keeping with the guiding principles of the review; set a troubling precedent for all businesses operating in Ontario; and create a great deal of uncertainty for the sector and others.

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The recommendation to establish a new property tax class for landfills with corresponding tax-ratio ranges has the overall impact of making the valuation methodology meaningless. It is not in keeping with the approach taken by the province in dealing with similar property types, and removes the commonly applied principle of equity in taxation between similar properties. We are not aware of any other jurisdiction that has taken a similar approach. Further, no explanation in the report is provided as to why a completely separate property tax class is necessary or what makes this property type so different that it should be treated differently. There is also no indication as to how a landfill will be defined for property tax purposes and how co-located facilities like transfer stations, recycling facilities or compost facilities will be dealt with to ensure they are treated in an equitable tax manner. In many ways, this decision appears to reverse the recommendations made by the Ontario Committee on Taxation (the Smith Committee) in 1967. This committee, like similar committees in other provinces at that time, condemned property tax for being regressive and for being inequitably administered (because properties of similar value were not assessed the same amount). As a result, today, industrial and commercial properties, such as mines, quarries and various types of renewable energy projects, are valued in a similar manner and are subject to a shared tax classes. The business sector should be extremely concerned about what this reversal will mean for them. We would strongly recommend delaying the creation of a new tax class until all the potential issues have been discussed and addressed. Tax ratios will now be set at a range determined by politicians based on what is believed to be a “fair level of taxation.” No indication is provided in the report as to what is considered a fair level of taxation. These tax ratios create a potential political tool that could be used to ensure landfills cannot be sited within certain municipal boundaries due to a lack of economic viability. The recommendation also provides a significant amount of uncertainty about the potential magnitude of impact. We have no guidance as to what the targeted tax ratios will be and the potential impact versus current taxes. Depending on the magnitude of the impact, these ratios have the potential to create significant distortions in the waste management marketplace and change the cost structure within the province. It could also exacerbate the exportation of waste from the province and increase tensions with Michigan. We also strongly disagree with the conclusion reached that host agreements are not an essential pre-condition of obtaining an Environmental Compliance Approval (ECA) and therefore are not relevant to the property tax discussion. ECAs often include parts of these host agreements within the conditions. Large landfills provide their host municipalities with significantly higher host fees than property taxes and also provide in-kind services. Host fees and in-kind services must be accounted for. The data required by the Ministry to assess landfills through the historic cost methodology is all publicly available as part of the Environmental Approvals process through the Ministry of the Environment and Climate Change. It remains unclear why the Ministry of Finance would need to make this data collection mandatory over the short-term. With the move to an income-based approach, mandatory data collection may need to be necessary, but it comes with a whole host of problematic questions that must be addressed. We do not agree with the decision to remove the right to appeal an assessment. This change was not a part of any discussion during the review, and no evidence has been provided to show why such a change is necessary. Given the lack of detail and the lack of consultation with the rest of the business community, the Ministry should not move forward with this change.

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