30 June 2021
P. O. Box 6000
VIA Email: Jeffrey.Porter@gnb.ca
Re: Packing and Printed Paper Extended Producer Responsibility Program (“PPP-EPR”) Draft Regulations
Dear Mr Porter:
Thank you to the Government of New Brunswick for the consultation process regarding PPP-EPR – the staff working on this project have been accessible and very helpful throughout the process to provide presentations, answer questions and provide information as it became available. They have helped us understand the goals of the department and why the government is seeking to set up a PPP-EPR system.
We also appreciate that some of the feedback provided by our organization and others have been incorporated into the draft regulations where appropriate. In particular, the small business exemptions will benefit and provide comfort to many of our members that would not have the capacity to incorporate a complex new regulatory obligation under this regime.
Coming out on the other side of the pandemic is welcomed by all in the business community, of course, but we are encouraging all government officials to keep in mind that for many, it was the worst 18 months they will ever have experienced in business and for some sectors, the economic fallout will still be felt long after the health crisis is behind us. This means that any new costs or red tape would be ill-timed for many New Brunswick businesses that have their sights set on the recovery process and making up for lost time.
As the program begins to take shape, we ask your department to continue to view PPP-EPR through a small business lens and provide as much time and flexibility as possible within the system for “brand owners” that will be obligated under the regime to create a stewardship plan.
We agree that taking care of the environment and the economy go hand-in-hand and we look forward to working with government and the private sector to ensure that New Brunswick has strong records on both fronts moving forward.
CEO, Fredericton Chamber of Commerce
cc: Hon Gary Crossman, Minister, Department of Environment and Climate Change
cc: Mark Miller, Project Coordinator, Department of Environment and Local Government