This letter submitted by Mark S. Winfield, Director of the Pembina Institutes Environmental Governance Programs submitted to Mr. Dhaliwal, then Senior Programs and Policy Officer of the Waster Management Policy Branch, comments on the EBR Registry Posting RA01E0003 (Hazardous Waste Change Initiative).
The Institute strongly supports both of the initiatives contained in this proposal in principle. The establishment of annual registration requirements for hazardous waste generators will address a significant gap in the hazardous waste regulatory framework first put in place in the mid-1980's. In the absence of such requirements, no reliable information is available to the Ministry or the public regarding the total generation and fate of hazardous wastes in the province. However, the Pembina Institute has specific comments on a number aspects of these proposals which are outlined in this letter.