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Beyond Bans – Challenges and
Opportunities for Economically Viable
Reductions in Food Waste Volumes
and Waste Sector Emissions
November 20, 2017
Karlis Vasarais, B.Com, M.I.P.P.
Dr. Jack Carr, B.Com, M.A., Ph.D.
_____________________________________________________________________________________
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EXECUTIVE SUMMARY
There is no argument to counter the notion that food waste is an economic loss to society. Where
there is ongoing debate is in finding economic, evidence-based outcomes that have successfully led to
consistent and sustained gains in food waste reduction. Food waste bans are an economically inefficient
policy mechanism, that deliver suboptimal greenhouse gas (GHG) emissions reduction outcomes. Not
only are they exceedingly hard to implement, but they also require extensive and complex supporting
mechanisms. These supporting mechanisms are also costly. According to analysis conducted in this
paper, the true-life cycle costs of implementing the necessary waste diversion infrastructure and
procedures to support food waste recycling would comfortably exceed Canada’s 2022 carbon tax goal of
$50 per tonne of carbon dioxide equivalent (CO2e).
This paper contends that food waste recycling issues do little to address the underlying cause of the
problem, namely the generation of food waste in the first instance. Current policy making is severely
inhibited by the lack of publicly available, reliable data, on the volume, management practices and type
of food wastes created across Canada. While all resource recovery and landfill diversion programs can
offer opportunities, they differ dramatically in cost and complexity. By using a comparables-based
methodology, this paper represents a significant step forward in attempts to quantify the scale and
economic cost of food waste across Ontario, Alberta, Quebec and British Columbia. Our analysis
estimates food waste recycling programs such as AD and composting add $218-$307 per tonne of food
waste diverted, equivalent to $80-$115 per Canadian household. This analysis demonstrates that food
waste recycling measures, supported by a food waste ban in landfills, represent the least cost-effective
solution for reducing GHG emissions in the waste sector.
Methane emissions resulting from food waste in landfills are not only an environmental liability but
also represent a low-hanging fruit opportunity. Landfill sites today have accumulated decades of food
waste that generate 30 megatonnes of CO2e per annum while decomposing. Today, a growing amount
of those emissions, currently 11 megatonnes C02e, are abated via landfill gas capture equipment.
Despite over 3.5 million tonnes of food waste destined for Canadian landfills every year, a ban on food
waste in landfills will have little impact on these emission levels over the next decade. For near-term
emissions reductions, these emissions can be captured through Landfill Energy Extraction Facilities
(LEEF), with the best-in-class sites in Canada reducing methane emissions by over 80%. Every 1%
increase in Canadian landfill gas collection efficiency abates the equivalent GHG emissions of diverting
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80,000 tonnes of food waste. Were all landfill sites to reach 80% landfill gas capture quality standard,
then Canada’s annual GHG emissions would decline by an additional 15 megatonnes CO2e per annum.
Consequently, this would minimize potential additional abatement gains from food waste diversion
from landfills due to GHG emissions additionality. All that is lacking is the right policy framework and
financial stability to make this major emissions abatement strategy in the waste sector a reality.
In our market economy, firms are always trying to restrict or to eliminate competitors. Firms always
desire for governments to adopt policies which hurt their competitors. AD facilities are very expensive
to operate and one way of placing impediments on competitors is to have governments impose a ban on
food waste and organics going to landfills. Such a policy will certainly aid the bottom line of AD facility
operators. This policy is good for AD facility operators but is bad for the Canadian economy. There is no
economic rationale for the elimination of competition in the GHG reduction industry. Instead,
policymakers can make best use of limited economic resources by balancing the greatest GHG reduction
opportunities at the lowest possible economic and environmental cost.
The following paper begins by attempting to define and quantify the scale of the food waste
challenge across ON, AB, QC and BC. It subsequently explores the current suite of policy options that are
being explored to address food waste concerns, whilst highlighting relevant pilots and case studies of
where these measures have been implemented. In the later sections, the paper provides an economic
and financial analysis of the comparative costs of various food waste reduction mechanisms, before
providing a set of policy recommendations.
The paper concludes by advising policymakers to prioritise food waste prevention in the first
instance, and subsequently to adopt a risk-averse, technology agnostic, evidence-based policy approach
towards both food waste recycling and recovery based methods.
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CONTENTS
EXECUTIVE SUMMARY .................................................................................................................................. 2
INTRODUCTION ............................................................................................................................................. 5
ORGANIC WASTE OVERVIEW ........................................................................................................................ 6
INCREASING FOOD WASTE DIVERSION ....................................................................................................... 10
ADDRESSABLE FOOD WASTE MARKET ........................................................................................................ 11
FOOD WASTE IN THE IC&I SECTOR ............................................................................................................. 14
SUMMARY OF FOOD WASTE GENERATION ................................................................................................ 16
FOOD WASTE MANAGEMENT OPTIONS ..................................................................................................... 18
SOURCE SEPARATED ORGANICS PROGRAMS ............................................................................................. 21
FOOD WASTE GHG ABATEMENT POTENTIAL .............................................................................................. 26
UNINTENTED POLICY CONSEQUENCES FOR LANDFILL GAS RESERVES ....................................................... 30
THE ECONOMICS OF GHG ABATEMENT FROM FOOD WASTE .................................................................... 34
PROPOSED PATH FORWARD ....................................................................................................................... 36
CONCLUSION ............................................................................................................................................... 37
REFERENCES ................................................................................................................................................ 39
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INTRODUCTION
The allure of “zero-waste” cities and provinces, where all materials previously deemed garbage
find a renewed use, has understandably captured the minds of policymakers, environmentalists and
entrepreneurs alike. While Canada-wide waste diversion rates are amongst the world’s best, the
problem is far from being solved and much of the low-hanging fruit has already been harvested. To
stimulate further waste diversion, Canadian policymakers are increasingly considering, and in some
cases implementing, phased selective bans at landfills for food waste and organics. This comes with
good intentions; food waste and organics continue to make up nearly one third of the waste destined
for landfills across Canada.
The justifications for food waste and organics bans at landfills are diverse and often
complementary. They range from methane avoidance measures at landfills and reduced greenhouse gas
(GHG) emissions in the waste sector, to circular economy resource efficiency targets, job creation and
infrastructure investment opportunities. Some bans also explicitly seek to enhance beneficial nutrients
capture for soil enrichment. While these are compelling reasons, policymakers have rarely examined the
comparative cost-benefits of food waste recycling initiatives, namely anaerobic digestion (AD),
composting and landfill energy extraction facilities (LEEF). This lack of economic analysis is a major
problem. Given global climate targets, policymakers are correct to ask
the question “what is the quickest path to a zero-waste and lowcarbon
economy?”. However, they must also factor in the political
economy of their policy choices. Given their finite resources,
policymakers underlying intentions are arguably better served by
posing the question “what available technologies and behavioural
changes can catalyze the greatest waste sector GHG emission and
food waste reductions opportunities, given limited public resources?”.
This paper contends that landfill bans of food and organic waste are among the least economical
solutions and riskiest strategies to mitigate waste at landfills and reduce waste sector GHG emissions.
Firstly, many of the food and organic waste sources are difficult to fully exploit. This is due to the need
to adjust consumer behaviour, geographic population density challenges, and infrastructure layouts in
multi-residential dwellings and commercial institutions. Diversion is essential to utilise alternative
solutions such as investments in anaerobic digestion (AD) infrastructure, which can capture the methane
What available technologies and
behavioural changes can catalyze
the greatest waste sector GHG
emission and food waste
reductions opportunities, given
limited public resources?
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produced. However, the economics of diverting food and organic waste to AD instead of landfills do not
currently stack up when viewed in their totality. Landfill bans implemented to enhance food waste
diversion, rank low on achievable near-term GHG emissions reduction benefits as compared to available
improvements in landfill gas collection systems. Furthermore, this paper contends that it is both risky
and imprudent to make further public-sector investments in food waste processing and recycling
facilities, such as composting and anaerobic digestion systems, at present. Such facilities can only
succeed once a cost-efficient and reliable food waste diversion system has been proven in currently
unaddressed food waste markets.
Given the lack of available public data and the costly experiences with AD projects in Canada,
the potential economic gains and GHG reductions that greater methane capture at landfill could offer
must be given greater consideration. This paper will therefore also provide a methodology for assessing
the respective policy costs of prevention, recovery and recycling. While the topics covered in this paper
are applicable across many North American jurisdictions, this paper focuses on Ontario (ON), Quebec
(QC), Alberta (AB) and British Columbia (BC), together referred to as “the Regions”.
ORGANIC WASTE OVERVIEW
In discussing organics and food waste bans, it is important to clarify terminology as a pre-requisite to
identifying and costing the policy options available.
Types of Organic Waste
Organics and Food Waste are primarily made up of three distinct categories of compostable and
biodegradable materials:
(1) Food waste, such as dairy, meats, breads and grains, or vegetable/fruit food scraps
(2) Industrial by-products such as biosolids, paper mill sludge1
(3) Leaf and yard materials2
These distinct categories are important because the majority of rogue methane emissions at landfills
are created from food waste and not from leaf and yard materials or industrial by-products. For the
1 Biosolids are excluded from the scope of this paper
2 As an important side note, where leaf and yard waste are processed properly such as in windrow composting,
some consulting groups assume no GHG emissions generation.
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purpose of this paper however, “organics” will refer to the combination of food waste and leaf and yard
waste. The following chart illustrates the estimated generation of food waste and leaf and yard waste
within the Regions at the residential (municipal solid waste or “MSW”), Industrial, Commercial and
Institutional (IC&I) levels. Across the group, Ontario and BC score the highest in combined organics
diversion, at 56% and 44% respectively.3 However, since 2010 Quebec has heavily invested in new
organics and food waste processing infrastructure, thus its diversion rates will have significantly
increased. In Alberta, an increase in organics diversion is also expected due to Edmonton’s recent food
waste processing infrastructure investment. Together, the four provinces produce an estimated 4.5
million tonnes of food waste annually as of 2010, and divert at least 20% from landfills.4
Food waste occurs in many forms and along a variety of points in the food value chain. Part of
the challenge for policymakers has been that a breakdown for food waste in Canadian markets is not
available. However, by using the United States as a comparable, we have inferred data for the Canadian
market. In the US, fruits and vegetables make up 42% of food waste, driven by their high rate of
3 Canadian Biogas Association. “Organics Materials Primer for Biogas”. March 2014.
4 Giroux Environmental Consulting. “State of Waste Management in Canada”. 2014.
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perishability. This is followed by milk and dairy, along with grain products, representing 26% and 19% of
food waste by weight.5
The majority of food waste occurs at the residential and the IC&I levels. In the United States,
residential food waste represents 43% of food waste while the combined areas of IC&I represent 38%.6
Without specific Canadian data available, this paper assumes Canada has a similar food waste profile.
As food waste breakdowns by weight are not available in Canada, food waste has been
quantified not in terms of volume, but instead by economic value. Following this methodology, the value
of food waste in Canada is estimated at $31 billion per year, once again driven by the residential
segment at 47%.7
5 ReFED. “A Roadmap to Reduce U.S. Food Waste by 20 Percent”. 2016.
6 Ibid.
7 VCM International. “$27 Billion Revisited – The Cost of Canada’s Annual Food Waste”. 2014.
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This figure excludes peripheral enabling costs of delivering food to market such as inventory,
infrastructure, transportation, disposal costs, and audits. When accounting for these factors, the true
cost of food waste is estimated at $107 billion in Canada.8 On a per capita basis, at 47% of food waste by
value, Canadian consumers lose $500-$1,500 by wasting food annually.
Be it by weight or financial value, the greatest contribution to
food waste is the residential segment and this represents a tremendous
lost economic opportunity. Given this fact, food waste prevention, or at
least recovery of food waste (such as for donations / food banks), must
be a top policy priority. Why then are Canadian policymakers focusing
on landfill bans for food waste, which do nothing to prevent the economic loss, rather than focusing
their efforts on prevention and recovery?
Organics Diversion Rates
Across the Regions, organics diversion programs successfully divert upwards of 1.9 million
tonnes from landfills every year. For all the provinces in the Region, organics diversion and total waste
generation is quantified by Statistics Canada. To understand total organics generation, this report
extrapolated Ontario’s waste audit data sets from the residential and IC&I sectors based on population
8 Ibid.
Despite its higher lost
economic opportunity,
Canadian policymakers have
neglected efforts to prevent
food waste from occurring,
instead opting to pursue lowvalue
food waste recycling
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size. In Ontario, the diverted organics volumes are broken down as 53% yard and leaf waste and 47%
food waste. Furthermore, additional organic wastes in residential and IC&I waste streams were as
follows: residential stream (30% food waste, 11% yard and leaf waste), and IC&I (15% food waste, 2%
yard and leaf waste).9 Since data for the other provinces was not readily
available, the same breakdown ratios of waste stream composition and
organics stream were assumed for Alberta, BC and Quebec. Across the
Region, yard and leaf waste (YLW) has achieved a much higher diversion
rate than food waste. The authors contend that this can be attributed
to a range of factors, including easier capture potential (mostly only
single home dwellings), more straight-forward residential behavioral modifications, and existing viable
end markets for the compost product.
Existing Diversion Breakdown Across the Regions (Municipal Solid Waste and Industrial, Commercial,
and Institutional Sectors)10,11
Food Waste % Yard/Leaf Waste %
Alberta 948,345 210,657 98,733 13% 111,924 61%
British Columbia 672,595 378,139 177,230 33% 200,909 >90%
Ontario 2,517,357 1,058,272 496,000 26% 562,272 >90%
Quebec 1,690,518 253,000 118,578 9% 134,422 35%
5,828,815 1,900,068 890,541 1,009,527
Organics
Generated
Organics Diverted
(2010)
Estimated Diversion by Type
INCREASING FOOD WASTE DIVERSION
From a policy perspective, diversion of food waste is desirable via prevention, recovery, or
recycling. For food waste recycling, meaning composting and AD, these reasons include efforts to reduce
greenhouse gas emissions, enhance nutrients capture, improve landfill lifetime conservation, and more
generally, political support for the “zero-waste economy”. As a result, policymakers across Canada are
attempting to close the gap between food waste diversion rates and other diversion programs, such as
those for “blue bin” materials (plastics, glass, paper) and yard and leaf waste.
9 Canadian Biogas Association. “Organics Materials Primer for Biogas”.
10 Ibid.
11 Giroux Environmental Consulting. “State of Waste Management in Canada”.
The yard and leaf waste market
is much simpler than that of
food waste because almost all
of it is generated in single-family
homes, outdoors, and does not
have food waste’s “yuck” factor.
11
There can be a temptation to compare food waste collection programs to recyclables programs
or leaf and yard waste programs. But while all resource recovery and landfill diversion programs can
offer opportunities, they differ dramatically in cost and complexity.
As compared to other diverted materials, increasing food waste
diversion volumes is fraught with major challenges. Principally
these involve the diversity of the food waste generation sources
and the food waste material itself. Other issues such as program costs and financially bankable GHG
benefits are discussed later in this paper.
Traditional Recyclables
“Blue Bin”
Yard and Leaf Waste
Food Waste
“Green Bin”
Characteristics
• Often co-mingled,
requiring separation
• Individual plastic types
difficult to identify
• Seasonal, “brown
bag”
• Mostly single-story
homes with yards
• Odorous, rodent prone
• The “yuck factor”
• High moisture content
challenges economics
Challenges from
sources
• Multi-story residential
units don’t always have
chutes for recyclables
• Challenges mostly
addressed given high
(<90%) diversion
rates achieved
• Lacking multi-story
residential supporting
infrastructure
• IC&I incentives lacking
Cost/Revenue
Drivers
• Materials recovered
sold and reintroduced
into supply chain
• Fees from producers
subsidize program costs
• Compost
sales/giveaways
• Offsets municipality
fertilizer
requirements
• Yard waste bag
royalties / sales
• Biogas sold via electricity
or natural gas, or flared
• High contamination,
odor control, leachate
management =
expensive infrastructure
ADDRESSABLE FOOD WASTE MARKET
The volume of food waste generated across Canada and its low capture rate represents a
significant economic opportunity. However, achieving high diversion rates for food waste has numerous
challenges. These are due to the distinct characteristics of waste produced by different parts of the
population, variations in dwellings and the differing requirements of businesses. Given these realities it
is debatable whether a policy signal, such as an organics and food waste ban at landfills, is an efficient
mechanism to achieve policymakers’ goals of reducing waste at landfills and reducing waste sector GHG
emissions. Nova Scotia’s ban is a case in point. Despite a complete organics and food waste ban set in
While all resource recovery and
landfill diversion programs can offer
opportunities, they differ
dramatically in cost and complexity.
12
1997, a 2013 audit revealed that nearly half of the province’s organic waste generated is still going to
landfill.12
Canada’s leading food waste diversion campaigns, often referred to as “Green Bin” or “Green
Cart” programs, are most economically compelling in large urban
areas. These areas’ relatively high population densities reduce
transportation and collection costs. But across the Region twothirds
of Canadians live in cities with less than 500,000 inhabitants.
If we assume that food waste generation per capita is similar
regardless of where Canadians live, this means that 65% of
residential food waste is located in rural or small-medium sized
cities, totalling 1.7 million tonnes of the total residential sector’s 2.56 million tonnes per year within the
Region. These areas do not enjoy the same economic advantages from density and scale as the largest
urban areas would.
It is also worth noting here that the shear relative population size differences between Ontario
and Quebec, versus Alberta and British Columbia, suggest that contributions from food waste to
Canada’s overall GHG footprint play a more impactful role in Ontario and Quebec. Therefore,
demographics as well as economic and GHG reduction opportunities will play a role in the relative policy
priorities for each of the provinces. Especially when factoring in future population growth.
12 Compost Council of Canada. Organic Management in Nova Scotia – Clear Bags, Material Bans, Financial Support.
Sept 23, 2014.
An estimated 65% of residential
food waste is located in rural or
small/medium-sized cities – Areas
without the same population
density and scale advantages for
food waste collection, transfer and
processing.
13
Source: Statistics Canada. 2017. Population and Dwelling Count Highlight Tables, 2011 Census
Beyond size and location of Canadian inhabitants, the types of dwellings pose additional
challenges when considering food waste diversion market opportunities. Existing apartments are rarely
equipped with multiple garbage chutes which would allow residents to dispose of their food waste
without walking down stairs or using elevators. Considering the inconvenience and the “yuck factor” of
food waste, achieving high food waste diversion for residents of apartments will be more difficult than
single family homes. Evidence from a voluntary scheme in New York City, shows that only a small
fraction of apartment buildings has signed up for the optional food waste collection program that began
under Mayor Bloomberg13. Similarly, in Ontario only 7 of 37 municipalities have implemented some form
of food waste programs at multi-unit residential apartments.14 Thus, considering that apartments
represent 30% of dwellings in the Region, the challenges of achieving high near-term food waste
diversion targets are noteworthy, irrespective of landfill organics and food waste bans.
13 Rueb. Emily S. “How New York is Turning Food Waste Into Compost and Gas”. New York Times. June 2, 2017.
Available from https://www.nytimes.com/2017/06/02/nyregion/compost-organic-recycling-n…
14 Ontario Ministry of the Environment and Climate Change (MOECC). “Discussion Paper – Addressing Food and
Organic Waste in Ontario”. Document # 013-0094. 2017.
14
Source: Statistics Canada. 2017. Type of Dwelling Highlight Tables. 2016 Census.
Taking inhabitant demographics into consideration, achieving quick wins in increased food
waste capture will be difficult. While 2.56 million tonnes of residential food waste per year represents a
large market, the near-term addressable market should arguably be discounted. This is due to the fact
that around 65% of inhabitants live outside large urban areas and 30% of residents live in apartment
buildings. If policymakers fail to make a distinction between these groups, a complete landfill organics
and food waste ban within a few years could burden these markets with high food waste diversion costs
and expensive food waste processing capacities. In smaller urban environments and rural regions,
building capital intensive organics and food waste processing infrastructure, without a demonstrated
way to economically recover food waste is risky. Conversely, what may be more feasible in these
Regions in the near term, while also applicable to larger urban areas, would be a renewed policy focus
and funding provision for food waste prevention and recovery. This is discussed later in this paper.
FOOD WASTE IN THE IC&I SECTOR
The industrial, commercial and institutional sectors (IC&I) are the second largest generators of
food waste in the Regions, with an estimated 1.95 million tonnes of food waste generated annually. The
three major categories include grocery & distribution, restaurants and institutions (hospitals, schools,
etc.). The remainder is made up primarily of the government and manufacturing sectors. Together, the
first two categories, being grocery & distribution and restaurants, represent nearly 74% of food waste
generated.
15
Note: see Footnote for further information15,16
15 Data for the two preceding graphs extrapolated and estimated using the following three sources: (1) ReFED. “A
Roadmap to Reduce U.S. Food Waste by 20 Percent”. (2) Canadian Biogas Association. “Organics Materials Primer
for Biogas”. (3) Giroux Environmental Consulting. “State of Waste Management in Canada”.
16 Use of US data sets may overstate the percentage of food waste at Canadian restaurants because Americans
spend 48% of their food dollars in restaurants versus 39% in Canada (Restaurants Canada, Statistics Canada and
the National Restaurant Association - 2016).
16
As a whole, the IC&I sector has significant economic incentives to minimize food waste.
Difficulties in reducing food waste at the retail level can be attributed to the challenges of accurate
demand forecasting and supply chain management. Grocery chains and restaurants are exposed to
unpredictable consumer demand, such as their preferences based on prevailing weather, availability of
seasonal substitutes and size portions.17 Restaurants often attract customers with large portions,
despite many patrons being unable or unwilling to eat it all. Furthermore, the IC&I sector must rely on
front-line employees to identify and separate the food waste fractions from other waste. This is often a
difficult undertaking in a fast-paced restaurant or cafeteria, with limited space for additional waste bins.
While there are initiatives underway to motivate the IC&I sector to participate in sourceseparated
organics programs, these have their challenges. In the NYC pilot program currently only 300
restaurants, hotels and food manufacturers are mandated to participate in the program due to a lack of
nearby processing capacity.18 This signals that food waste diversion is a slow process requiring custom
policy incentives for each sector and as a result, it is risky to jump into landfill organics and food waste
bans. It would be prudent therefore to continue supporting pilot programs, monitoring existing, and
summarising their learnings for other cities and municipalities. Policymakers can then develop best
practises and appropriate enforcement mechanisms from these experiences.
SUMMARY OF FOOD WASTE GENERATION
Food waste generation across the Regions is estimated at 4.5 million tonnes per year for the
residential and IC&I sectors. This is broken down between the residential sector (2.56 million tonnes -
58%) and the IC&I sector (1.96 million tonnes - 42%) as earlier shown. Further breaking down food
waste into several subcategories demonstrates that food waste is broadly evenly generated across five
distinct sources. This creates additional complexity and thus cost, to achieving high diversion rates.
17 Interview with a Management Consultant who specializes in grocery store supply chain management
18 Rueb. Emily S. “How New York is Turning Food Waste Into Compost and Gas”.
17
Food Waste Volume by Source (in 1000s of Metric Tonnes)
900 mt
20%
845 mt
19%
770 mt
17%
615 mt
14%
890 mt
20%
385 mt
8%
115 mt
3%
Residential Residential
Residential
***
***See Footnote 16 regarding Restaurants figures.
It is understandable that policymakers are seriously debating the merits of introducing organics
and food bans at landfills to “kick start” additional diversion. However, pre-emptively banning food
waste from landfills without a demonstrated understanding of the total cost of a diversion program, and
without having a range of proven effective policy mechanisms to enforce such a ban, has multiple risks
and may lead to public perception of an iteration of unwelcomed indirect taxation.
To date, schemes in Ontario and British Columbia have demonstrated high diversion potential in
the large city residential segment. However, no province has yet achieved similarly high diversion rates
across the other food waste sources (small/medium-sized cities + IC&I) despite being comparable in
market size. Prudent investing would make demonstrated diversion potential in these markets a precondition
to making new food waste recycling infrastructure investments.
If the Regions cannot demonstrate viable pathways to enhance food diversion, then they run
the risk of financing stranded public and private investments in new organics processing infrastructure.
This has been the case in the Guelph and Ottawa regions. Guelph has had significant overcapacity at its
organics processing facility due to a shortfall of organics from Waterloo. However, Waterloo residents
have been footing the bill because Waterloo guaranteed a volume to Guelph. By committing to volumes
18
not yet proven,19 and instead assuming that Waterloo residents would actively divert food waste,
Waterloo has burdened its residents with unnecessary costs at upwards of $600 per tonne of food
waste.20 A similar problem occurred in Ottawa, which signed a fixed-volume contract to a private facility
and was stuck paying for disposal of organics and food waste which the city was not generating. The
fixed volume contract cost Ottawa residents $100 per tonne of food waste diverted to the compost
facility. However, Ottawa fails to collect 80,000 tonnes, it is still responsible for the total $8 million per
year in fixed fees thus driving up the per tonne processing cost.21 The other major risks are policy
distractions from food waste avoidance, high food waste diversion program cost management, and
premature technology lock-in for food waste GHG mitigation. These are further discussed below.
FOOD WASTE MANAGEMENT OPTIONS
In 2016, ReFED, a US not-for-profit research organization, issued a detailed report on the status
and opportunities of food waste in the United States. In this study, ReFED researched and quantified
dozens of opportunities to reduce food waste, primary by prevention, recovery or recycling. Prevention
opportunities included greater public education, waste tracking, clear date labeling, and improved
inventory management, while recovery solutions included donation tax credits, liability education and
regulation, and value-added processing. The final category, recycling, was driven by large-scale and local
composting, anaerobic digestion (AD), and water resource recovery systems with AD.
Strategy Examples
Prevention
Education, std. labelling, tracking & analysis, smaller plates,
spoilage packaging, inventory/cold chain mgmt.
Recovery
Donation tax incentives, std. donation regulation, matching
programs, system transport/storage/handling
Recycling
Composting, anaerobic digestion, wastewater treatment plan codigestion
(sewage sludge with food waste)
19 Waterloo’s actual food waste collected amounted to 9521 tonnes in 2011, then fell to 9060 tonnes in 2012
20 Outhit, Jeff. “Green bin costs soar. Are they worth it?” Waterloo Region Record. July 23, 2013.
21 Scholey, Lucy. “Audit shows Ottawa 'getting hosed' in green bin deal: Councillor”. Metro News. October 8, 2015.
19
The following table summarizes the results from each of the three categories for the United
States. On a high-level, the Canadian market represents 1/10th of the population size in the USA.
Therefore, its is assumed that equivalent opportunities in Canada would likely drive approximately 10%
of the identified GHG reductions and diversion potential.
ReFed Report on Food Waste Diversion Potential in the USA – Summary ($ in USD)22
Annual Diversion
Potential (Mil
Annual Economic
Value ($B)
Capital Investment
Required ($B)
GHG Reduction
(Mil tons)
Prevent 2.6 $ 7.70 6.2 9.7
Recover 1.1 $ 2.40 8.7 3.4
Recycle 9.5 $ 0.12 2.9 4.8
From the table, we see that while recycling, meaning composting and AD, has the ability to
divert the highest tonnage, its annual economic value is only a fraction of prevention and recovery.
Similarly, the GHG emissions avoided from recycling are only half of the GHGs that could be avoided by
prevention, despite prevention only enabling ¿ of the tons diverted of recycling. For policymakers, the
ReFed analysis demonstrates that the economic implications of food waste recycling are far less
compelling than the alternatives. Consequently, AD and composting are less likely to spur unsubsidized,
long-term economic growth.
ReFed Report on Food Waste Diversion Potential in the USA – Financial Analysis23
Ton GHG/Ton Food
Waste Diverted
Economic Value per
Ton ($000)
Investment
Economic Payback
Period (Yrs)
Prevent 3.73 $ 2,962 0.81
Recover 3.09 $ 2,182 3.63
Recycle 0.51 $ 13 23.97
The recycling option, meaning composting and AD, ranks last amongst
the alternative food waste reduction opportunities, from a financial and
economic perspective. It also fails to deliver the greatest reduction of GHG
amongst the three policy outcomes. Per ton diverted, food waste recycling has 1/6th of the benefit of
22 ReFED. “A Roadmap to Reduce U.S. Food Waste by 20 Percent”.
23 Ibid.
The economic value of
recycling food waste is
virtually zero, leading to a
payback period on the
initial investment of nearly
24 years, as compared to 1
and 4 years for both food
waste prevention and
recovery, respectively.
20
food waste prevention and recovery. The economic value of recycling food waste is virtually zero,
leading to a payback period on the initial investment of nearly 24 years, as compared to 1 and 4 years
for both food waste prevention and recovery, respectively. This should not be interpreted as a
justification to do nothing with food waste once prevention and recovery options are exhausted.
However, this analysis does demonstrate that policymakers would benefit from prioritizing prevention
and recovery strategies and allocating their limited financial resources accordingly.
Furthermore, policymakers must be careful not to lock themselves into specific technologies
when pursuing recycling options. The experience of Guelph keenly
demonstrates how food waste recycling can burden taxpayers with
underutilized infrastructure for decades to come. A ban on food waste at
landfills specifically locks out landfill gas capture and beneficial use
technologies from investing in further technological gains. It is not uncommon
for modern landfills to achieve landfill gas collection efficiency in excess of
85%.24 Furthermore, most AD infrastructure is not yet built to meet market requirements. If
AD/composting infrastructure is built to meet the volumes of all food waste, future prevention and
recovery programs will inevitably conflict with the economic incentives of these recycling options.
With limited taxpayer dollars, the economic argument clearly indicates that taxpayer dollars
provide a much larger economic and GHG benefit in food waste prevention and recovery, with a much
shorter economic payback period compared to recycling food waste through composting and AD
systems. In the United Kingdom, a program called WRAP began in 2007, cutting food waste by 21% over
five years and savings consumers over $20 billion dollars.25 Metro Vancouver is moving forward on a
similar “Love Food Hate Waste” campaign. In drafting this report, the author could not identify any
Canadian market report which tracked food waste generation and prevention. Instead, Canadian studies
have thus far focused almost entirely on growth in organics and food waste diversion. If food waste
generation is not actively being measured, then it is reasonable to conclude that prevention and
recovery of food waste are not being actively managed either. Only by quantifying and tracking food
waste generation through enhanced data gathering systems, can policymakers be informed in their
24 The EPA’s WARM model assumes that landfills achieve a 90% gas capture rate after final cover.
25 Metro Vancouver. “The food waste problem”. Available from
http://www.lovefoodhatewaste.ca/about/Pages/default.aspx
Policymakers must be
careful not to lock
themselves into specific
technologies when
pursuing food waste
recycling options.
21
decision making because they will have a reliable, fixed baseline upon which to estimate program
economic benefits and track and measure results. This should be seen as a precondition to dramatic
policy direction changes.
SOURCE SEPARATED ORGANICS PROGRAMS
Source separated organics programs (often referred to as Green Bin or Green Cart programs)
have been actively deployed in municipalities across Canada and the initial infrastructure to process
organics and food waste have been constructed. This experience provides policymakers with reliable
data points upon which to calculate evidence-based total program costs. These infrastructure assets can
include composting facilities, anaerobic digestion facilities with gas flaring (such as in Toronto), or
anaerobic digestion facilities with beneficial reuse of the captured gas. But regardless of which asset
class, current data suggests that almost all of these food waste diversion initiatives have proven to be
uneconomical capital project undertakings.
The minimum breakeven tip fee for processing food waste at anaerobic digestion facilities has
been calculated at $110/tonne by a Canadian independent consulting firm.26 This has multiple validation
points. The city of Waterloo has a 10-year contract with Guelph valued at $23 million to process 20,000
tonnes of food waste annually. This works out to $115/tonne of food waste at Guelph’s composting
facility.27 Although Waterloo only manages to collect 9,100 tonnes, thus over double the rate on a per
tonne basis to Guelph, the $115/tonne could arguably be representative of market rates. It should be
noted that this figure does not seem to include collection, transfer and delivery costs to Guelph.
Toronto’s 2016 budget lays out approximately $25 million for collection and transfer for the
Green Bin (food waste) recycling program. Given that 138,000 tonnes of food waste were collected in
2016, we therefore tabulate the food waste program cost at $181/tonne.28 It is important to also note
that Toronto’s Green Bin scheme costs triple the rate for garbage, and double the rate for recyclables.
This is because recyclables generate sales from recovered materials worth $11 million annually for the
city, thus reducing their net cost per tonne.
26 Morrison Hershfield. Residual Waste Management Options for the Regional District of Nanaimo. 2016.
27 Outhit, Jeff. “Guelph defends “good deal” to process green bins”. Waterloo Region Record. Aug 3, 2013.
28 Toronto’s Green Bin also takes diapers. It is unclear whether diaper weight is included in this figure.
22
Tonnage Gross Expense ($Mil) Net Cost per Tonne
Garbage 525,000 $ 29 $ 55
Recyclables 216,000 $ 29 $ 83
Green Bin - Food Waste 138,000 $ 25 $ 181
Toronto - Collection and Transfer (2016 Budget)
Breakeven operating costs of composting and anaerobic digestion facilities must also account
for facility capital cost, depreciation & amortization, and interest expenses. When Nanaimo had
engineering and consulting firm Morrison Hershfield complete a study on residual waste management
options, the study indicated that the approximate capital cost for organics processing would be $600 per
tonne of capacity. This means that a 50,000t facility would cost $30 million. However, evidence from
existing facilities across the country suggest this is overly optimistic and that approximately a 50%
premium or $913 per tonne of capacity is more representative. The following chart summarizes the
financials of major publicly funded organics and food waste processing facilities in Canada.
23
Location Facility Type
Capacity (in
Tonnes)
Capital Cost
($ Mil)
Capital Cost per
Tonne
Toronto – Disco Rd AD – flaring only 75,000 $78 $1,033
Toronto – Dufferin 2 AD – flaring only 55,000 $74 $,1345
Guelph* Composting 30,000 $32 $1,067
Edmonton AD 40,000 $37 $925
Varennes AD 35,000 $31 $885
Surrey* AD + Composting 115,000 $68 $591
AVERAGE 58,000 $53 $913
*Guelph and Surrey accept seasonal yard and leaf waste as well.
Other major capital expenses which increase the cost of food waste processing facilities, are for
odour control and leachate treatment. Furthermore, the processed food waste at anaerobic digesters is
often transported to composting facilities for further processing, adding additional costs.
Despite these costs, it would seem that Europe has taken a major leap towards the adoption of
AD infrastructure, assumingly to process organic waste. However, this is a dangerous misconception.
Europe does lead the world with its broad base of AD projects across the European Union (EU), totalling
over 17,000 AD projects as of 2015.29 However, only a minority of biogas plants operate on organic
waste. Germany, which represents 62% of the total number of biogas plants in operation in the EU,
generates only 5% of its biogas from organic waste. While some countries generate upwards of 20-45%
of their biogas energy from food waste, they are relatively small contributors to the overall biogas
portfolio. In fact, only 14% of the total biogas generated in the EU in AD systems stems from organic
waste and municipal waste.30
29 European Biogas Association. Annual Report 2015.
30 European Commission. Optimal Use of Biogas from Waste Streams. December 2016.
24
Operational
Biogas plants
(2015)
% of Total
Biogas
Plants
Share of Biogas
Generated from
Organic Waste
Germany 10846 62% 5%
Italy 1555 9% 20%
France 717 4% 45%
Switzerland 638 4% unknown
Czech Republic 554 3% 8%
UK 523 3% 47%
Austria 444 3% 16%
Sweden 282 2% 45%
Total - EU 17376
Some of these facilities earn additional revenues from renewable electricity production or else
renewable natural gas, which lowers their break-even tip fee requirements. However, it is important to
recognise that this lower cost is essentially a cross-subsidy, as biogas plants often receive lucrative feedin
tariffs to generate renewable electricity. In Ontario, the electricity sold by AD units receives a rate of
$0.14-$0.20 per kilowatt hour.31 In the USA, similar green energy subsidies are available for renewable
natural gas projects. In California, the incentives can boost the price of renewable natural gas from
waste organics to upwards of $30/MMbtu under the Federal RIN D3 incentives and the California Low
Carbon Fuel Standard.32,33 This is upwards of 5-7 times the market rate for traditional natural gas. Thus
whether it is illustrated as high tip fees, or alternatively higher natural
gas prices, organics processing is a costly capital undertaking that will
be paid by Canadian consumers for decades. To avoid such costs,
policymakers should follow a cautious roll-out of food waste diversion
initiatives and avoid, where possible, being locked into a premature
technology approach for food waste recycling.
Capital costs of new food waste recycling infrastructure can be extrapolated to forecast what
the required minimal tip fee would be to pay for the capital loan principal payment and interest
expense. The following chart indicates the fixed costs for a 60,000t food waste processing facility with a
31 IESO. Feed-in Tariff Program. Fit Archive - Communications.
32 Historical D3 RIN pricing ranges from ¢276 per RIN (2016). There are 77,000btu biogas per RIN, thus US$35.88
per MMbtu.
33 Progressive Fuels Limited. PFL Weekly Recap. Oct 2-6, 2017. Available at
http://www.progressivefuelslimited.com/web_data/PFL_RIN_Recap.pdf
Germany, which
represents 62% of
the total number of
biogas plants in
operation in the EU,
generates only 5%
of its biogas from
organic waste.
Policymakers should follow a
cautious roll-out of food waste
diversion initiatives and avoid,
where possible, being locked into
a premature technology approach
for food waste recycling.
25
20-year lifespan with three capital cost points that reflect the ranges of actual as-built costs of existing
organics processing facilities.
Capital Cost per
Tonne
Total Capex
Annual Loan Principal
Payment
Annual Average Interest
Expense
Annual Fixed Cost per
Tonne
$600 $36,000,000 $1,800,000 $720,000 $ 42
$900 $54,000,000 $2,700,000 $1,080,000 $ 63
$1,300 $78,000,000 $3,900,000 $1,560,000 $ 91
Given the annual minimal fixed cost per tonne ranges from $42-$91/tonne, fixed costs alone,
already exceed typical landfilling rates. That is excluding incremental collection, transfer and processing
costs. Additional operating expenses such as labor, electricity, equipment replacement and
maintenance, which would be in excess of facility revenue from compost sales, would also add to the
financial burden. Moreover, as shown in Toronto, the collection and transfer costs for food waste
significantly exceed the cost of regular garbage or other recyclables.
Adding together the three elements of food waste management (transfer and collection,
processing/operating costs, and fixed costs), the research indicates that further deployments of
currently available technologies for processing food waste would be a huge burden to taxpayers.
Transfer and
Collection
Costs
Processing/
Operating
Costs
Subtotal –
Collection and
Processing Costs
Infrastructure
Depreciation +
Interest Costs
Total cost per
tonne
Garbage
$55 $20 - $5034 $75-$105 included. $75-$105
Food Waste
$181 $100-11035 $291 $42-$91 $333-$382
Food Waste
Incremental
Cost to
Landfilling
$98-$126 $50-$90 $176-$216 $42-$91 $218-$307
In all, source separation and processing of food waste can cost upwards of $218-$307 per tonne
as compared to traditional landfilling options. An Ontario report for the City of London affirms this
costing analysis, indicating a cost of $270-$340 per tonne diverted for a 25,000t SSO facility.36 For all of
34 Waste Connections of Canada.
35 Morrison Hershfield analysis – excludes capital but includes profits from energy/product sales. The lower $100
per tonne based on fees paid by Ottawa to Orgaworld.
36 Corporation of the City of London. Organic Materials. April 2017.
26
the Region’s 4.5 million tonnes of food waste, representing an estimated $1.0-$1.5 billion in additional
costs to taxpayers, or approximately $80-$115 per household annually,37 were all food waste diverted
via composting and AD recycling. Such a high incremental cost to Canadians would be politically
unjustifiable unless the net environmental benefits prove compelling. But as the next section shall
demonstrate, they are not.
FOOD WASTE GHG ABATEMENT POTENTIAL
Diversion of food waste is often justified on the grounds of its associated GHG emissions
abatement potential. Food waste that is locked in an anaerobic environment, such as in a landfill or AD,
produces biogas, a mixture primarily made of methane and carbon dioxide. Methane is known to be a
short-lived GHG emission with an estimated 25 times the warming potential of carbon dioxide. Methane
at landfills represents the vast majority of waste sector emissions, since food waste has been
accumulating at landfills over decades. Thus, there are two main ways to mitigate methane emissions in
the waste sector: (1) divert food waste from landfills to avoid future GHG emissions, and (2) improve the
gas collection efficiency at landfills. Unfortunately, policymakers’ ongoing focus on diversion results in
the latter option often being under-explored much to the detriment of the waste sector’s GHG
emissions profile.
GHG Abatement from Food Waste Recycling
Within the Regions, approximately 4.5 million tonnes of food waste is generated annually. This paper
assumes that waste prevention campaigns across the Regions can be introduced that are similar to
those in the United Kingdom and Vancouver. The U.K. campaign indicated a +20% reduction in food
waste from prevention and recovery, thus a similar target is set for the Regions. This leaves 3.6 million
tonnes of food waste for recycling at composting and anaerobic digestion facilities. Currently 0.9 million
tonnes of food waste per annum is diverted via composting and AD within the Regions. Deducting the
existing diversion and food waste prevention opportunities, the food waste addressable volume across
varying city sizes and dwelling types, is approximately 2.7 million tonnes.
37 Total households in the Region (AB, BC, ON, QC = 12.1 million)
27
Assuming the proposed landfill organics bans are implemented along the proposed 2022
timelines (5 years), the following chart depicts the current state versus future state of GHG abatement
from food waste recycling. The GHG abatement curve must factor in GHG emissions additionality.38
Given that the landfill gas collection average across Canada is currently 38%,39 not all GHG emissions
savings can be claimed by new food waste diversion initiatives. In some regions, landfills are regulated
to achieve 60-75% gas capture,40 meaning that additional GHG savings in food waste are even lower.
Finally, high performing landfills, traditionally incentivized by an ability to sell the captured methane
either as a direct fuel, electricity, or renewable natural gas, further reduce the GHG abatement potential
from food waste reduction campaigns. The graph illustrates that
food waste recycling via composting and anaerobic digestion has
the ability to reduce GHG emissions by 0.8-2.5 million tonnes
CO2e with current landfill gas capture rates. However, the
coinciding GHG emissions savings drop dramatically to 0.2-0.6
million tonnes CO2e for 2.7 million tonnes of food waste
diversion (3x current rate) if landfill gas capture achieves 85% efficiency, which is a demonstrated and
38 Additionality assesses whether a project or activity generates incremental GHG emissions reductions that would
not have occurred in the absence of the incentive.
39 Environment and Climate Change Canada. National Inventory Report 1990-2015: Greenhouse Gas Sources and
Sinks in Canada. 2016
40 60% landfill gas capture in Ontario, 75% landfill gas capture in British Columbia
Since food waste been accumulating
for decades at landfills and will still
be decomposing for decades to
come, new diversion mandates have
minimal net GHG reduction potential
in the waste sector.
28
achievable target. This is an important takeaway. However, once landfill gas projects all achieve high gas
capture, which has been demonstrated repeatedly across Canada and the US, the concept of
additionality for food waste GHG reduction opportunities via anaerobic digestion or composting
significantly reduces these technologies’ GHG reduction potential.
Reduced GHG Emissions From Landfill Diversion Based on Rate of Landfill Gas (LFG) Capture41
Based on the organics diversion costs provided earlier, the following chart depicts the net cost
per tonne C02e abated by recycling food waste in compost or anaerobic
digesters. Earlier in this paper, the existing portfolio of food waste
recycling options were estimated to cost taxpayers an additional $218-
$307 per tonne of food waste compared to landfilling. Based on the three
levels of landfill gas collection efficiency below, the cost abated from food
waste recycling ranges from $109-$1352 per tonne of CO2e.42 Even if all-in
incremental organics diversion costs achieve $100 per tonne (half the
41 Key Assumptions provided by Delphi Group: 125m3 biogas per fresh tonne food waste; 55% methane content;
CH4 density = 0.47kg CH4/m3; CH4 GHG in CO2e/tonne food waste = 1479kg (vented), 0.77kg (combusted)
42 Assumes a biogas yield of 125m3/fresh tonne and 55% CH4 content.
The cost abated from food
waste recycling ranges from
$109-$1352 per tonne of CO2e.
This means that achieving
long-term sustained reductions
in food waste at landfills will
remain a burden to taxpayers
and above market rates for
CO2e emissions reductions.
29
demonstrated rate), the GHG cost always exceeds Canada’s 2022 carbon tax goal of $50 per tonne
CO2e. This means that achieving long-term sustained reductions in food waste at landfills will remain a
burden to taxpayers and above market rates for CO2e emissions reductions.
Cost per Tonne of GHG Emissions Abatement Factoring The Additionality of Landfill Gas Capture
Current Regulation High Performers
38% 60% 85%
$100 $109 $169 $451
$200 $218 $338 $901
$300 $327 $507 $1,352
Landfill Gas Collection Efficiency
Incremental Organics
Diversion Cost ($/tonne)
Further reductions in greenhouse gas emissions from food waste recycling are possible in
anaerobic digestion systems and landfill energy extraction facilities (LEEF) alike. This would be driven by
beneficial use projects, such as biogas to electricity or biogas to renewable natural gas projects.
However, to provide an affective comparison we would also need to factor in methane leakages and
comparative capital costs for each type of methane gas utilization system. That, in addition to
geographic grid intensities, would delineate the relative competitiveness of each technology.
Other GHG Considerations
The calculated emissions and costs for GHG abatement above neglects an important
consideration for food waste: transportation emissions. Food waste is often high in water content,
anywhere in the range of 70-90% in a raw, fresh tonne. Source separated food waste also contains
contamination such as plastics or paper, which has no biogas generation potential. Therefore,
transportation distances from food waste generation sources to processing and recycling facilities is a
factor when considering the overall GHG emissions reduction potential.
If the recycling opportunity is composting or anaerobic digestion, the facility only produces
methane destruction GHG credits. Conversely, if the biogas is used as a renewable natural gas to offset
30
diesel truck fuels, incremental inbound transportation emissions are negligible when compared to the
resulting RNG GHG emissions abatement. This is a particular issue for the Region’s rural and small-tomedium
sized city residents which make up 2/3’s of the Canadian population. Few of these areas will be
able to justify the economics of infrastructure investment for large-scale food waste processing and
recycling and thus would often be limited to composting or AD flaring systems. In addition to methane
offsets, the carbon value in the compost of the recycled food waste has added environmental benefits,
such as improving the quality and carbon sequestration potential in soils. However, those benefits can
be eroded if the distance from the compost facility to the compost application is significant.
UNINTENTED POLICY CONSEQUENCES FOR LANDFILL GAS RESERVES
The accumulation of decades of food and organic waste at landfills has created a significant
repository of decomposing organic and food waste matter. When this occurs in an oxygen-free
environment, biogas, a mixture primarily made up of methane (CH4) and carbon is created. Landfills
generate 30 megatonnes CO2e of methane from the accumulated waste across Canada of which 11
megatonnes (38%) is captured, combusted and/or beneficially used.43 The remaining 19 megatonnes
CO2e of CH4 is a considerable environmental GHG emissions source. Canada’s existing landfill gas
emissions cannot be ignored. Traditional landfills produce 30% of their landfill gas during their 20-30
year lifetime, but then will continue to produce landfill gas (70% of total lifetime generation), over the
subsequent 100 years. This liability also represents a significant economic opportunity to capture this
gas and use it either to generate renewable electricity or as renewable fuel. To achieve this, Landfill
Energy Extraction Facilities (LEEF) should be promoted further.
LANDFILL PHASES AND LANDFILL GAS GENERATION CURVE44
43 Environment and Climate Change Canada. National Inventory Report 1990-2015: Greenhouse Gas Sources and
Sinks in Canada. 2016
44 Steinhauser, Eric S. “Designing Landfills for Custodial Care: Is it Practical” Sanborn Head & Associates. May 23,
2017.
31
LEEFs are a proven technology that can cost-effectively capture methane and abate GHG
emissions. A study conducted by McKinsey indicated that LEEFs have a much lower GHG reduction cost
than 1st and 2nd generation biofuels.45 In fact, electricity from landfills is considered the lowest cost GHG
abatement strategy among renewable energies. By neglecting LEEFs for more expensive and less mature
food waste recycling technologies, policymakers risk increasing the cost of a low-carbon economic
transition and arguably reducing Canada’s ability to meet near-term GHG reduction targets in the waste
sector.
Canada’s landfills can provide massive GHG emissions reductions that far outweigh the GHG
abatement from new food waste diversion initiatives.
Enforcing Canadian landfills to achieve the Ontario
mandated 60% gas collection efficiency (also referred to as
landfill gas capture), has the same effect of diverting 4.4
million tonnes of food waste from landfills annually.46 In
other words, every 1% increase in Canadian landfill gas collection efficiency abates the equivalent GHG
emissions of diverting 200,000 tonnes of food waste. By examining the Canada-wide best-in-class landfill
45 McKinsey & Company. Pathways to a Low-Carbon Economy - Version 2. 2009
46 Assumptions (provided by Delphi Group): 125m3 biogas per fresh tonne, 55% CH4 content, CH4 density = 0.47kg
CH4/m3; CH4 GHG in CO2e/tonne food waste = 1479kg (vented), 0.77kg (combusted), 38% existing LFG capture
(for additionality); LFG 1% capture increase = 190,000 tonnes CO2e abated
Every 1% increase in Canadian landfill
gas collection efficiency abates the
equivalent GHG emissions of
diverting 200,000 tonnes of food
waste from landfill annually.
32
gas capture systems, we can see that gas capture rates of approximately 85% have been achieved. One
such best-in-class site is the Lachenaie facility in Quebec. If all Canadian landfills achieved this rate, the
waste sector emissions would be reduced by 25 megatonnes CO2e, representing a total reduction of
over 80% of the waste sector’s methane emissions.47 This can and has been demonstrated where private
sector incentives are aligned with opportunities to produce revenues to pay for the additional
equipment and capital investment required.
A commonly heard argument from AD facility developers is that if landfill bans were to be
implemented, it would lead to greater availability of food waste for the development of new AD
infrastructure. While this may occur, AD developers would also require new waste collection streams,
changes in consumer behaviour and new policy enforcement mechanisms to promote waste diversion.
Further, while AD facility developers argue that landfill bans of food and organic waste, are essential for
the composting and AD industry to secure feedstock and thus to find financing for their facilities, the
same logic can be applied to landfills. If food waste is no longer comingled in waste at landfills, future
projections of biogas generation and capture will involve higher financial “stranded asset” risk, as food
and organic waste are the key sources of methane. This makes LEEF investments increasingly
unattractive to landfill site owners and policymakers should be greatly concerned by this. The GHG
emissions abatement potential from composting and AD flaring is far less than the GHG abatement
potential from mandates for improved landfill gas capture. Additionally, food waste diversion’s GHG
47 Currently landfills reduce waste sector emissions by 11 megatonnes CO2e via existing landfill gas capture
33
abatement potential is further reduced if landfills move towards best practices in landfill gas capture
technologies.
Thus, while landfill food and organic waste bans may bring about new investments in anaerobic
digestion (AD) infrastructure, it conversely reduces the economic appeal of candidate investments in gas
capture and beneficial reuse at existing Canadian landfills. These landfills have 19 megatonnes C02e of
CH4 of proven gas reserves, meaning that far more emissions can be reduced by incentivising LEEF
investments than by promoting food waste recycling programs.
Other Recyclables – Not to Be Forgotten
Food waste greenhouse gas emissions receives significant attention because methane emissions
at landfills are readily quantifiable. It must not be forgotten that other recyclables, namely aluminum,
glass, paper, plastics and other metals almost always have a greater GHG emissions effect on a per ton
of material basis. The US EPA WARM Model provides the following information regarding relative GHG
emissions for all classes of materials, based on source material reductions, recycling or composting.
EPA WARM Model: Per Ton Estimates of GHG Emissions for Alternative Management Scenarios48
(MTCE = Metric Tonnes of CO2e)
Material
GHG
Emissions per
Ton of
Material
Source
Reduced
GHG
Emissions
per Ton of
Material
Recycled
(MTCE)
GHG
Emissions per
Ton of
Material
Landfilled
(MTCE)
GHG Emissions
per Ton of
Material
Composted
(MTCE)
Aluminum Cans -1.34 -2.48 0.01 NA
Glass -0.14 -0.08 0.01 NA
Food Waste (non-meat) -0.21 NA 0.19 -0.04
Food Waste (meat only) -4.12 NA 0.19 -0.04
Mixed Paper (general) -1.84 -0.96 0.11 NA
Mixed Metals -1.01 -1.19 0.01 NA
Mixed Plastics -0.52 -0.28 0.01 NA
48 U.S. Environmental Protection Agency. Versions of the Waste Reduction Model (WARM). Available from
https://www.epa.gov/warm/versions-waste-reduction-model-warm#WARM Tool V14
34
Aside from prevention (source reductions), re-use of these other recyclables always provides a
greater GHG reduction benefit than food waste composting. For these other recyclables, GHG emissions
savings from recycling range from 0.08-2.48 metric tons CO2e per ton of food waste. Comparatively,
landfilling food waste generates 0.19 of metric tons C02e while composting reduces GHG emissions by
0.04 metric tons C02e. This illustrates that greater recycling of traditional “blue box” recyclables will
have a more impactful reduction on waste sector GHG emissions. In Ontario, these high-value nonorganic
recyclables are only being recycled at a 63% rate.49 Thus, programs to continue to increase
diversion non-organic wastes from landfills, which provide a greater GHG emissions reduction, should
remain a greater focus of policymakers. If any bans should be considered, it should start with the
landfilled materials with the highest lifecycle GHG emissions with demonstrated recycling potential.
THE ECONOMICS OF GHG ABATEMENT FROM FOOD WASTE
There are two main technologies which have proved useful in achieving GHG reduction levels.
One major technology is the building of Anaerobic Digestion (AD) facilities and composting facilities. The
other major technology is the building of landfill energy extracting facilities (LEEF). The best available
evidence points to the superior efficiency of LEEF over AD. However, optimal public policy would be to
allow these two technologies to freely complete. The market will determine which of these two
technologies provide the least costly reduction in GHG. The policy of banning of food wastes and
organics from landfill will greatly disadvantage LEEF and essentially make this technology not
economically viable.
In our market based economy price (including carbon pricing) plays a crucial in determining
what should be produced and how it should be produced. The price system allocates resources to their
best and most efficient use. Goods that consumers want command high prices and high prices attract
firms to produce such goods. Firms that produce goods in the most efficient and least cost way can offer
high prices for inputs such as land, labour and capital. Economically efficient firms attract the land,
labour and capital to produce the products that consumers desire. Prices provide the signals to firms of
what and how to produce and prices also provide the incentive for firms to follow the information
inherent to these signals. Firms that follow these price signals produce the greatest output at the lowest
cost and produce the highest profits. As such our market economy based on the price system results in
49 Stewardship Ontario. 2016 Stewardship Ontario Annual Report. Available from
http://stewardshipontario.ca/download/2016-stewardship-ontario-annual-r…
35
the efficient allocation of resources. Goods are produced in the cheapest and most efficient way
resulting in the greatest output for any given amount of resources.
If capital and labour costs are relatively high in AD facilities, these facilities will have to charge a
high price for the processing of food wastes. If capital and labour costs are relatively low for LEEF then
the costs of processing wastes will be relatively low resulting in relatively low tipping fees (i.e., low
prices for waste elimination). Despite LEEF likely always having some methane leakages, this can be
addressed by a carbon tax levy.50 With free and open competition, the superior technology will win over
the inferior technology. The least cost technology will win out in free and open competition resulting in
the efficient allocation of resources and as such resources will be used in their highest and best use.
Efficient allocation of resources results in the highest level of output produced and the highest level of
living standards for Canadians.
The optimal public policy is to let AD and LEEF freely compete with one another. Subjective
regulatory rules that are not backed by sound evidence should not be adopted which might eliminate a
potentially superior technology. Food waste bans essentially replace the price system with a regulatory
rule and by-pass the recently introduced carbon tax system. From the point of view of economic
efficiency, a policy of banning food and organic wastes from landfills is sub-optimal. There is no reason
to prevent the free and open competition of all technologies with the proviso that all technologies meet
certain pre-determined maximum levels of GHG emissions.
In our market economy, firms are always trying to restrict or to eliminate competitors. Firms
always desire for governments to adopt policies which hurt their competitors. AD facilities are very
expensive to operate and one way of placing impediments on competitors is to have governments
impose a ban on food waste and organics going to landfills. Such a policy will certainly aid the bottom
line of AD facility operators. This policy is good for AD facility operators but is bad for the Canadian
economy. There is no economic rationale for the elimination of competition in the GHG reduction
industry. Instead, policymakers can make best use of limited economic resources by balancing the
greatest GHG reduction opportunities at the lowest possible economic and environmental cost.
50 Landfills are currently excluded from the carbon tax regime because it is a regulated industry. Unfortunately, any
landfill emissions abated above the regulated threshold of landfill gas capture (60% for large landfills in Ontario)
are not monetizable, providing limited incentives to landfills to enhance gas capture.
36
PROPOSED PATH FORWARD
The following set of recommendations reflect concrete opportunities to drive down GHG
emissions and volumes of wasted materials. Without a sequential, risk-adjusted implementation plan,
premature organics and food waste bans at landfills may burden Canadian taxpayers for decades to
come. Policymakers seem to believe that by banning food waste from landfills, the food waste problem
will solve itself. Unfortunately, Nova Scotia’s 1997 attempted organics ban proved otherwise.51
Furthermore, continued improvements in landfill gas capture negate the GHG emissions benefits from
food waste recycling via additionality, so much so that the cost per tonne of GHG reductions through
food waste recycling exceeds Canada’s long-term carbon tax plans.
The Regions would benefit from select pilot programs in various city sizes, dwelling types and
establishments (IC&I) to assess what are the most cost-efficient and effective strategies to minimizing
food waste. In parallel, landfills must be given the economic opportunity to monetize and combust the
existing landfill gas reserves. Unless the existing gas is monetized, Canada’s waste diversion initiatives
will fail to generate meaningful reductions in the waste sector’s total GHG emissions. For policymakers
to be in a well-positioned situation to selectively ban organics and food waste from landfills based on a
fair, economic and environmentally balanced formula, a number of steps must first occur. Food waste
sources must be better understood, diversion strategies should be tried and tested, the costs of
alternative food waste processing and recycling infrastructure must be reduced, and landfill gas capture
optimized. These stages should all be treated as essential pre-requisites to effective policymaking.
TOPIC RECOMMENDATIONS
1. Quantify the addressable food
waste markets and pilot lowcost
food waste diversion
opportunities
• Pilot food waste diversion options for IC&I, as well as multiresidential
and small city/rural residents
• Implement food waste prevention and recovery initiatives
• Set baselines for food waste generation per capita so that
prevention, recovery and recycling campaigns are delineated
2. Promote food waste recycling
technology development and
provide guided policy signals
• Identify and test technology applications that could lead to
reduced processing / recycling costs
• Review existing infrastructure actual capital / operating costs
51 Compost Council of Canada. Organic Management in Nova Scotia – Clear Bags, Material Bans, Financial Support.
Sept 23, 2014.
37
and examine potential for co-located AD infrastructure at
wastewater treatment facilities
• Set maximum food waste recycling program costs to avoid
uneconomical investments and programs
• Cautious roll-out of new infrastructure based on strategic
location and demonstrated food waste diversion achievement
3. Address remaining
opportunities in existing
recyclables streams
• Quantify GHG emissions and volumes from remaining
recyclables in waste streams
• Implement 100% extended producer responsibility
• Support new end market applications to monetize increased
volumes of recyclables
4. Drive down GHG emissions
from existing landfill gas
reserves
• Design incentives / regulations for higher gas capture
• Provide gas pipeline approval process and carbon credits
monetization avenues above regulated landfill gas capture
• Phase-in limited landfill organics bans based on landfill gas
capture efficiency, diversion rates achieved and availability of
alternative cost-effective food waste recycling infrastructure
CONCLUSION
Food waste is a complicated problem. This paper attempted to bring to light the factors that are
significant hurdles in achieving high food waste diversion from landfills, such as economic costs,
scattered and diverse waste sources, and various GHG abatement solutions. Achieving high food waste
diversion is no simple undertaking. To achieve the +60% recycling rates of paper, plastics, glass and
metals alone has taken decades. Food waste’s diverse and distributed generating sources pose similar
challenges. The Regions have demonstrated the potential to divert from single residential homes, albeit
at a significant cost. Data on waste diversion from apartments, small-medium cities, and the IC&I sector
is not yet dependable and widespread, yet mandates for organics and food waste bans at landfills are
dependant on such programs. This paper provided a high-level cost-benefit analysis on food waste bans.
The preliminary results indicate an incremental cost of $218-$307 per tonne of food waste recycled via
anaerobic digestion or composting. This translates into an additional burden on taxpayers in BC, AB, ON
38
and QC of around $80-$115 per household annually, or over $1 billion in additional waste management
costs annually.
The real problem facing food waste diversion is Canada’s lack of economically viable methods
and technologies to collect, transfer and process the majority of food waste generated. As proven with
recyclables, achieving materials diversion rates of upwards of 60% are possible without landfill bans.
Real results in food waste recycling require investments in new end-markets, new technological
approaches, and a realistic comparison of all options, including high-efficiency landfill gas capture
projects. While such technologies continue to evolve, the economics dictate that food waste’s best
economic and environmental impact potential lays in food waste prevention and recovery, and highefficiency
landfill gas capture systems. In addition, if Canada wants to see meaningful near-term waste
sector emissions, reducing food waste and reducing waste sector emissions must involve intentional
capturing and monetizing the methane emissions from landfills in energy or carbon markets. Through a
combination of policy incentives to prevent food waste, or to recover it prior to falling into the waste
stream, together with landfill gas capture initiatives, policymakers can pick the low hanging fruit whilst
maximising the economic and GHG reduction payoffs.
39
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[Original Comment ID: 211496]