February , 2014 Office of the Municipal Clerk City Hall 1841 Argyle Street, Main Floor PO Box 1749 Halifax, NS B3J 3A5 e-mail: clerks@halifax.ca Mayor Savage and Councillors: As a retailer in Halifax Regional Municipality, I am writing to express my concern over the recommendation of municipal staff regarding the Integrated Solid-Waste Resource Management Strategy Review – Final Report. My specific concern relates to the second part of the recommendation to: Amend By-law S-600 to allow for the export of ICI residual waste (garbage) outside HRM, and amend Administrative Order number 16 to provide for an increase in fees for disposal of ICI residual waste from $125 per tonne to the assessed system cost of $170.00 per tonne; Although I would welcome the option of exporting ICI residual waste outside of HRM, it is concerning that I would even need to explore this option. As a business owner, it is troubling to see the significant price difference for dealing with solid waste in HRM versus HRM’s neighbouring municipalities. HRM wants to be a national leader in solid waste management yet I understand that much of the price difference between HRM and neighbouring municipalities is the result of HRM’s decision to enter into a generous long term operations agreement with the Otter Lake site operator. The price difference can also be attributed to HRM’s decision to create considerable extra costs by using a front end processor at the Otter Lake site. Conversely, neighbouring municipalities are also seen as national leaders in solid waste management yet they have made decisions that allow them to offer more reasonable tipping fees. The continued fee increases for garbage disposal in HRM have become cost prohibitive. In this sluggish economy, retail businesses in HRM are already faced with exorbitant solid waste fees, high property taxes and unjustified water tax increases. Not only do these continued tax increases make it difficult to conduct business in HRM, the unfair nature of decisions like the Halifax Regional Water Commission’s parking lot tax do not give comfort to businesses that HRM and its agencies appreciate the positive impact of retail on the municipal economy. Halifax Regional Municipality Solid Waste Resource Management Strategy Review Page 2 The retail sector is Nova Scotia’s second largest employer behind only the Health Care Social Assistance Sector. Retail represents approximately 13% of the province’s labour force and retail trade generated over $13 billion in economic activity for the province in 2012. As the majority of Nova Scotia retailers are doing business within HRM, the retail sector plays a vital role in the HRM economy. The Solid-Waste Resource Management Strategy Review’s recommended thirty-six percent increase in tipping fees would be another government obstacle for my retail business in HRM. As a retailer, I am willing to pay my fair share but adding a thirty-six percent increase to tipping fees that were already high by any comparative standard, is excessive. In the interest of allowing potential cost saving options to the business community, I would support the part of the proposed amendment to allow HRM businesses to send their ICI residual waste to neighbouring municipalities. The strategy review states that the municipalities of Chester, West Hants and Queens will take HRM generated ICI residual waste at their facilities for a significantly cheaper price per tonne than is offered in HRM. I trust HRM Council will give serious consideration to setting tipping fees at a more reasonable level while also providing industry with the option of sending ICI residual waste outside of the municipality. Sincerely, Retailer