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Reply to Comments Received in Submissions on the Proposed Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations
- Introduction
- Parties Providing Submissions
- Comments and Reply
- Comments and Reply: Harmonization
- Comments and Reply: Pre-Approved Facilities and Three-Year Permits
- Comments and Reply: Decoupling the Definition of Waste and Recyclables
- Comments and Reply: Delisting
- Comments and Reply: Definitions
- Comments and Reply: Content of Notice
- Comments and Reply: Conditions of Export and Import
- Comments and Reply: Movement Document
- Comments and Reply: Returns and Reroutements
- Comments and Reply: Confirmation of Disposal or Recycling
- Comments and Reply: Low-Risk Recyclables
- Comments and Reply: Waste-Export Reduction Plans
- Comments and Reply: Environmentally Sound Management
- Comments and Reply: Permits of Equivalent Level of Environmental Safety
- Comments and Reply: Public Access to Information and Decision Making
- Comments and Reply: Schedule 2 - Recycling Operations for Hazardous Recyclable Materials
- Comments and Reply: Schedule 3
- Comments and Reply: Schedule 4
- Comments and Reply: Schedule 5
- Comments and Reply: Schedule 6
- Comments and Reply: Persistent Organic Pollutants
- Comments and Reply: Vanadium Pentoxide
- Comments and Reply: Treated Wood
- Comments and Reply: Other General Comments
- Comments and Reply: Interprovincial Comments
Comments and Reply: Permits of Equivalent Level of Environmental Safety
A number of industry and association stakeholders provided comments on Permits of Equivalent Level of Environmental Safety (PELES)
We had understood through the consultations to date that there would be a process introduced for PELES within the regulation. However the allowance for PELES is not apparent in the proposed EIHWR.
If the PELES are to be regulated at the CEPA level, we would like to see a clear guidance or administrative document that details the process and sets out the criteria for 'equivalency'.
Also, permits should be issued with the intent of eventually incorporating the equivalent level of environmental safety into the regulations.
The variance provision or PELES is not visible within the regulation. Can we apply for conditional exclusions through PELES?
Provisions for closed-loop recycling were not provided. TMB should provide guidelines for the submission of a PELES application for the exclusion of specific closed-loop recycling activities.
Response: Section 190 of CEPA 1999 authorizes the issuance of permits of equivalent level of environmental safety (PELES), which may continue to be used to address variances to the proposed Regulations. Environment Canada will consider addressing these permits further in compliance-promotion material.
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