OFA provides comments to the Ministry of the Environment, Conservation and Parks regarding the proposed Administrative Penalties Regulation under the Resource Recovery and Circular Economy Act. OFA supports MECP commitments to design environmental enforcement tools that hold regulated parties in contravention of legislation and regulations accountable for non-compliance. When imposing penalties, OFA recommends the Ministry consider the size of the corporation when determining the appropriate penalty amount. In addition to proposed Registrar or Deputy Registrar penalty determination  powers, OFA supports enabling the administration to address the inconsistency of penalty assessments for small, incorporate businesses compared to significantly larger corporations. Considering the potential for a considerable number of new participants during the transition to the Individual (waste) Producer Responsibility model, OFA recommend reinforcing education as a first step prior to penalty for a non-continuing (non-willful contravention) category of offences. OFA also recommends the Authority make more information available related to an “appropriate amount of time to become compliant,” and parameters around how and when the Authority will apply per-day penalties for continued non-compliance. OFA supports a model where non-compliance and financial benefit penalty revenues offset other waste stream management cost obligations.