Two items follow:…

Two items follow:
1. A short cover letter
2. An analysis of the Food and Organic Waste Framework and Policy Statement draft
Cover Letter
Ian Drew, Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Resource Recovery Policy Branch
40 St. Clair Avenue West, Floor 8
Toronto, Ontario M4V1M2
Dear Mr. Drew,
This letter accompanies a response to the Food and Organic Waste Framework and Policy Statement. The Zero Waste Oxford committee commends you and those others working on these for timely work which also unifies thinking about food, organic materials, energy and poverty in Ontario. Without that broad practical and philosophical base the framework would be less useful. Our comments discuss at greater length the following points:
•The urgency and importance of food recovery not just to avoid waste but also to eliminate poverty and food insecurity through a food hierarchy;
•The good science and policy of linking the production to synthetic gas through the rescue of 100% methane from bio-digesters to enrich soils and provide alternative fuels while vastly reducing green-house gas emissions (a process to apply to extant and problematic dump sites too);
•The significant gains to be achieved in the industrial, commercial and institutional sectors which import, produce and generate the bulk of Ontario’s garbage while recovering little. These gains would be through reduction, transformation of their practices, producer responsibility for the recovery of all resources - recyclable or recoverable and the cessation of single use thinking.
•Education is important, not only because primary, secondary and post-secondary education occurs in institutions but also because it provides the means to conduct research and to train people in new technologies and habits, both in business practice and as residents, thus reaching all in Ontario;
•The need for support for infrastructure which would mean respecting the work and investments made by municipalities, encouraging pilot projects and innovation in the public sector, recognizing that waste disposal now and in the future is a public service worthy of provincial financing;
•The importance of targeting most beneficial uses and practices in light of long-term considerations of cumulative human health impacts, the environment and a circular economy.
The opportunities in the Framework for flexible responses to necessary and clearly delineated outcomes are the mark of modern thinking which is open to improvements in technologies and knowledge over the proposed 10-year life-span of the policy.
The accompanying document contains a number of anecdotes and instances which show the public’s interest in the elimination of food waste, that people are prepared to take action and are doing so, and that to scale up efforts around food and round organic waste will meet with broad approval. The pace of change can be quick in an environment where people are anticipating it. To act decisively, consultatively, and effectively on the proper uses and distribution of food as well as the most beneficial uses of recovering resources while moving to zero waste will help restore public confidence in the Ministry of the Environment and Climate Change as an agent of change and a protector of our interests.
Zero Waste Oxford welcomes this opportunity to engage in consultation and would be delighted to share additional knowledge with the MOECC on Food and Organic Waste as well as on how we move to a Waste-Free Ontario.
Sincerely,
Bryan SmithTed Comiskey
Co-chairCo-chair

2. Analysis
A Response to the Proposed Food and Organic Waste Framework
By
Zero Waste Oxford

Zero Waste Oxford is pleased to respond to the proposed framework for the disposal of food and organic waste. Even the title is a good sign: It separates, as should we all, food from organic waste. Beyond that it makes clear that the process of food recovery needs to be done with care from the outset, elevating the importance of food in our thinking as a society. When food insecurity, malnutrition, even hunger are present in the same places as overabundance, obesity and diet-induced diabetes, it is clear that food needs to have a high priority. That the Proposed Food and Organic Waste Policy statement discourages “the direct discharge of food waste or organic waste to a sewer” is consistent with a hierarchy that values food recovery and a society that encourages equity of access to food. Not only is this “not to be considered for the purposes of achieving targets”, the use of garburators or other grinding devices, particularly as applies to other organic wastes than food have potentially significant negative impacts on waste-water systems which will be costly to municipalities, the environment and human health. Conversely, recovery of organic materials as a resource is highly desirable and the opportunities for developing hierarchies are present in the document. It will be useful to spell them out. Organic waste is heavy, and has high volumes, both of these reasons enough to avoid transportation of it over long distances and especially when mixed with other wastes which it has a tendency to contaminate. Separation seems imperative either of organic waste from all other forms, or of any that it can contaminate and reduce the recovered value. An examination of the targets in Part B shows that percentages and timelines have been set. While these are aggressive, the percentages should be higher and the delays in implementation shorter. In particular, targets for multi-residential (which is in some senses a commercial enterprise – an apartment building represents commerce between renters and owners) and the IC&I sector are too low and too slow.
Zero Waste Oxford is particularly interested in the reduction of organic waste, as
of all other kinds, in the recovery of resources from it, and in laws of physics
which tell us that matter and energy are part of the whole. Thus, the integration
of energy savings into the movement and processing of organics as well as the
practical possibilities of energy production from them are of vital importance. The notes following are the result of a process engaged in actively by Zero Waste
Committee members on a day that also saw two workshops, for hospitality
industry players and for the general public on planning of effective zero waste
events. I am pleased to note that the meeting location was able to accommodate
those three sessions without disposable plastics or paper, that few organic wastes were produced, and that the session materials were delivered mostly online to a public very interested in acquiring them and their expertise.
Zero Waste Oxford is pleased that the Statement of Provincial Interest does the
following:
• Connects this framework to existing and forward-thinking legislation including the Resource Recovery and Circular Economy Act, 2016 which gives it added force and value
• Has opportunities for revision of the statement “within 10 years after it is
issued” but recommends flexibility in the regulations to engage in continuous improvement as systems are tested and applied and as science advances through research and discovery in Ontario and the world
• Places clear responsibility on “specified persons or entities” in order to
encourage training and high levels of performance, as well as transparency
and accountability
• Offers flexibility in the application in that the “not all policies are applicable
to every person, entity or activity” and encourages “mutual understanding
and cooperation” though the provision of mechanisms to dissuade incomprehensible actions with negative impacts will be appropriate
• Offers a plan for implementation that respects the geographical size,
demographics and diversity of the province. This respect for diversity in the
provincial interest statement also means that Oxford is a good candidate as

a leader and a centre for innovation in food and organic waste uses
because it, in fact, mirrors that diversity through its size and urban-rural
mix. Item 4.2 of the Proposed Provincial Policy Statement recognizes the
potential for negative economic, environmental and human health impacts
of the imposition of a wholesale policy of curbside collection of organics
where population densities are low. This too is a good thing.
• Considers the possibility that “there is a conflict between this Policy
Statement and a provincial policy statement … or prescribed instrument…or
provision” and suggests that which “provides the greatest protection to the
natural environment and human health governs”. Additionally, should
these tie (in an assessment tool which Zero Waste Oxford would offer
assistance in the development), referring that decision to the most recent
legislation on the issue, the Resource Recovery and Circular Economy Act, is
again a good process.
• Is focussed on outcomes which will allow municipalities and consortia to
use various scientifically sound and socially acceptable means to achieve
them.
• Allows the province to “issue guidance material and technical criteria from
time to time” in order to “support the policies and those engaged in their
“implementation and interpretation”
• Addresses some issues around packaging, standards for their reuse and
producer responsibility for the shift away from one-use, trash-bin-destined
packaging for food and any other product
• Will measure success in rescue, reuse and the reduction of greenhouse
gases
• Includes a glossary, though a larger one may be needed for IC&I producers
and generators of waste, “operators-in-charge” and others in training to
work in the organic waste sector, and the public as education, training,
implementation, measurement, and science advance
• Contains a hierarchy which places people near the top, though clearer
wording of the first item to include references there to people would make
it more palatable.

1. Reduce Food Waste

It is in the context of a meeting where waste was severely controlled that all
committee members were pleased to see that the “Province is [to] work with
partners to develop promotion and education tools to support food waste
prevention and reduction”. The preceding workshop had addressed the reduction of food waste with hospitality professionals and residents alike. The statement “preventing and reducing food waste also helps mitigate environmental impacts associated with food that is grown, processed, transported and offered for sale or sold to customers – only to be thrown out” is a rich collection of ideas. Firstly, food which is “grown […] only to be thrown out” seems absurd in a province where a significant portion of its adult population and children are food insecure. It is true, however, that food crops, grown on contract, sometimes are left in fields when contracts are fulfilled. Flexibility in contracts, food donations with credits for that, and gleaning might well be solutions. For food rejected in processing, we are all aware of the quite recent effort by some supermarkets to sell “ugly food” with superficial imperfections, and know that in processing, many of these visible imperfections can be dealt with through slicing, chopping, and pureeing as foods are transformed into meals or components for sale or delivery.
While transportation of food can result in some spoilage, especially of tender
fruits or vegetables, appropriate and sustainable packaging can help for the
movement of food. The reduction in the time and distances travelled by food will
also improve its chances of successful arrival. Oxford County’s work at increasing
the quantities of local food consumed by residents should reduce food waste,
improve the local economy, result in better nutrition, increase the local food
supply and thus help food insecurity, and offer fresher-looking and better tasting
food during the months when farm to table in a day is possible. It should be noted that this includes root crops which can continue to be harvested until the land freezes as well as extended season crops in greenhouses, especially where passive solar heat is utilized. Zero Waste Oxford applauds this, part of the Community Sustainability Plan ( See link - http://www.futureoxford.ca/General/SustainabilityPlan/index.htm ) and urges the Ontario government to increase the consumption of food grown in the province in all institutions financed by it as well as to persuade others to follow suit.
Food is offered for sale in multiple forms, some of them involving a lot of packaging. A reduction on packaging on food should mean less manipulation of them in the packaging plants and therefore a higher survival rate of food, although care must be taken to package and ship foods so they will not spoil, and for retailers and farm outlets to offer food in attractive ways which do not shorten their shelf life or reduce their nutritional value, or even the quantity of food available. Broccoli flowerets, for instance, may seem to be the best way to present them, and mean that stalks do not add weight to transport until you realize that the inner flesh of the stalks is a nutritious and appealing food which some prefer to the heads. Though their use might be different in some cases, no part of a food should be systematically wasted.
Consumer waste of food is a result of portion size as presented in retail outlets as well as of consumer habits of stocking up heavily on foods once a week or less. According to recent polling by Nutrition Action among American shoppers, our food shopping habits are apparently becoming more Europeanized, meaning that more frequent foraging at the grocery store will replace occasional expeditions down aisles with giant buggies. As a stable rural community, Oxford County has multiple farm gate and farm market locations, all of which add proximity to the social and economic value of local purchases. As part of a food waste reduction strategy, the Province needs to encourage more markets offering Ontario produce.
On a broader scale, retail shopping establishments, malls, restaurants and food processors have a large impact and as waste generators need to work to educate themselves, their staff, their clients and others to reduce waste at source, to separate waste, and to spurn wasteful packaging. Collectively, these organizations and individuals should develop systems and set targets above
provincial ones in response to public demand, reputational advantages, savings
and potential incentives.
The Zero Waste Oxford Committee members would count themselves among the “many in Ontario [who] want to see increased awareness with the issue of food waste, ultimately leading to behavioural changes and creating a culture of food waste avoidance”. Further, the members would prefer a culture of respect for food that would suggest that none should be wasted.
While there is a need for “standardized promotion, education and guidance
materials”, it is with an understanding of the specificity of each person or family’s relationship and traditions for food that these need to be produced. The
educational community is clearly an opportunity for multiple reasons. The fact
that children arrive at school without breakfast is a reality and research has
shown that this affects their learning. Additionally, exposure to a variety of
wholesome foods, participation in their preparation and conversation about them before the start of the school day is valuable in their nutrition and language development. Many people bemoan the almost complete disappearance of Foods courses in the high school curriculum, and while it is optional as are food preparation courses on an industrial scale in some schools, this means insufficient exposure to foods for the majority of students. The Zero Waste Oxford Committee, representing a rural and urban mix, is nonetheless aware of enhanced opportunities to know foods in elementary and secondary schools as well as at colleges and universities and would advise that these be “standardized” across the province, but again, with openings for adaptations for geographic and demographic differences. These we could add to current Oxford initiatives, formal and informal, especially if current perceived or real barriers to food initiatives in schools are reduced. If we examine European models, it is obvious from a few visits to lunch rooms in French schools that their students eat much better quality food than do ours. It would vastly improve nutrition and reduce food waste if, like the French interdiction on food waste from supermarkets, Ontario’s schools could be the location of better food in terms of its quantity (not the same as excess), quality and presentation so as to appeal to all social and economic classes. That lunches in schools need to be free is also obvious to anyone examining poverty in Ontario.
Zero Waste Oxford is anxious to begin with partners in further “developing and
delivering workshops and skill-building workshops which bring together
participants from all levels within the [education] community”. Again, education
does not merely refer to children and teens, but should include students in post-
secondary institutions, and adults in both formal and informal education. The
training of adults entering the food and hospitality industry occurs in Oxford
County (and nearby) and is an opportunity for the sharing of skills and knowledge among those already engaged in these, and with those who may need, want or desire such workshops, training and even certification. There are opportunities for “green jobs” here; for food recovery and transformation; for gleaning and rescue; education and training; improved quality of life, nutrition and economic vitality.
“Developing guidelines and training to support waste prevention” in educational
institutions is but one place where this could take place. There are other public
institutions where this is taking place but could be improved. Further, private
educational, long-term care and residential institutions have more than their fair
share of food waste and waste of other organics. They need to be included in the
prevention of waste. “Waste reduction for teachers and school board staff” is
again a part of the puzzle, but should be extended beyond the education sector.
Educators do have a privileged role in the incorporation of “waste reduction and
resource recovery principles into teaching activities, especially as it relates to food and organic waste” though not exclusively to these forms of waste. This would mean that all schools would need systems by which to audit, plan, improve, audit, and reward waste prevention and reduction with an enhanced Eco-Schools initiative built into the school plans and championed by more than one staff member. Zero Waste Oxford, while aware that the municipal boundaries of Oxford are not the same as either school board or post-secondary institutions would advocate on being a pilot for this.
The “province [is] to work with the Government of Canada on preventing food
waste” and this is a good thing. The reduction of organic waste in landfill sites will assist in the reduction of harmful methane gas emissions. Bringing food waste to zero is a goal for sooner rather than later; recovering and reprocessing organics as soil amendments promotes more fertility thus more food production as well as absorbency of water and heat, both valuable in combatting climate change effects; rendering fat from abattoirs and industrial kitchens is already a profitable industry which, expanded, could save municipal waste water systems from “fat whales”, “grease ‘bergs” and other such sewer blockages and thus the costs of their removal; the extraction of 100% of methane from biomass digestion could offer Ontario added opportunities to match Oxford’s goal of 100% Renewable Energy in the Future Oxford Community Sustainability Plan (See link - http://www.futureoxford.ca/General/SustainabilityPlan/index.htm ) . Since the Canadian government regulates food safety through the Food Inspection Agency, review of best-before versus expiry dates and public education around them will assist our Province. Further, an awareness that “improved access to affordable food improves health and food safety” means that urban health can improve, that the rural Food Belt can see improvements in local health while contributing to that of remote communities by providing Ontario produce in higher quantities to them. To do so, the federal government would have to create or reinstate incentives for food providers in Northern Communities to bring in fresh fruit and produce as well as transformed food products from agricultural Ontario areas. This is an area where Oxford could
partner and pilot programs.
The “province is to work with partners to support innovative approaches and
tools to rescue surplus food”. Oxford’s innovation cluster would be a perfect spot for provincial, academic, non-governmental and/or non-profit, municipal figures to develop “innovative approaches and tools” then share them in enlarging ripples – from pilot to general adoption – with other NGOs, community
organizations, social agencies, food and hospitality players, producers,
wholesalers and retailers. Some examples of informal collaborations follow:
• At the instigation of a member of the Woodstock Environmental Advisory
Committee, the village of Sweaburg in an adjoining lower-tier municipality
engaged in the Great Pumpkin Rescue to the benefit of yet another community, the Town of Ingersoll. Despite being close to the land, many local residents believed that pumpkin and squash are merely decorative, not edible, produce. These were rescued, taken to a collective dinner for the hungry, food insecure and lonely, processed into food as vegetable and as soup, served and offered in raw and cooked form to those who now understood their food value.
• Similarly, crops have been sown for years in Oxford destined to produce
exportable food or revenues to support developing countries with food and
nutrition needs among others. Certainly, these kinds of efforts can be expanded through further community education and involvement.
• In an urban collection of small town-houses in Oxford, a woman ‘inherited’
a friend’s large collection of tomato plants of different varieties. Their production, especially at the end of the summer far exceeded her needs or her ability to can for the winter. She initiated a neighbourhood tomato- picking party. Some who arrived wondered why the Roma tomatoes looked so different than the Beefsteaks, the Pantano Romanesco from the Valencia, the Black Zebra from the Green Zebra, the Cherokee Purple from the Brandywine Pink, the Caspian from the Hillbilly, (etc.). This provided her an opportunity to talk about the specific characteristics and uses of varieties of tomatoes to her neighbours, who then returned with recipe books to write out instructions for using them, to share recipes and talk about the value of food. Later, an informal food sharing collective developed as each made large batches of various recipes then offered
some to the originator of the wealth of tomatoes and her neighbours. It is
important to note that some of these neighbours lack food but also that
they lack opportunities for agency – making decisions around food that are
appropriate to their heritage, needs and tastes. The tomato cooperative
also became a bread-sharing initiative among “copains” breaking bread
together.
• While the Supper Club where over 100 meals are served weekly is an
interim and partial answer to food insecurity and serves also as a food bank
to deal with food emergencies, the urban neighbourhood is in an ongoing
state of emergency where the cost of living is such that food quality, nutrition, variety and quantity are often sacrificed. Food rescue is a part of the Supper Club’s means of providing sufficient quantities of appealing and nutritious food. Zero waste through reuse, recycling and composting are watchwords of the kitchen and dining room. It is notable that this group acts in anticipation of parts of the Proposed Food and Organic Waste Policy Statement which relate to “soiled paper” and “additional paper fibre products”.
• The City of Woodstock is also the site of training for employment and job-
readiness both through the high-skills major in hospitality at a local public
high school and at a community restaurant run by Operation Sharing as one
of their many, notable interventions in food insecurity, homelessness and
poverty in Oxford County. Food waste reduction can be addressed here.
• A Thamesford-area farm is an example of the conversion of post-Halloween
pumpkins and of black walnuts dropping from ornamental (sic) trees into
premium pork via dextrously hoofed wild boars of significant food and
economic value.
These examples all occur on the informal level and, while they could certainly
be spread and shared, there are sustainable solutions on larger scales to be
explored, piloted and put into production. It is clear that there is a desire to
meet Bob Geldof’s goal of “Feed the world” alive in Oxford County even after
the memory of this concert has largely faded. That desire can turn into
community and economic activity. The rescue of surplus food on a larger scale
will require work by food producers and their farmers’ unions, food processors,
retailers to deliver food and capacity for its storage, distribution and use to
organizations across the province currently collecting, rescuing and providing
food to food insecure sectors of the population. The Proposed Provincial Policy
Statement will need to have mechanisms fleshed out for doing this and
provide incentives to food rescue organisations which will sustain their
activities over time.
Given the levels of food insecurity in Ontario, of hunger and malnutrition, it does
not seem likely that there will be excess food production in the near future. It is
more important that the food either be preserved or be distributed while fresh
and nutritious to those who need, want or desire it. In urban and rural settings,
plantings of food-producing trees on boulevards and roadsides instead of mere
ornamentals can assist in the prevention of tree diseases and the alleviation of
effects of climate change through biodiversity and the provision of shade and soil retention. Additionally, these can be made available for gleaning through formal and informal networks which could and should be fostered there and in rural Ontario. Should Ontario ever produce so much food that it exceeds our
population’s needs and the demand for export for sales, the hungry in the
developing world may want it as an interim solution as they too develop food-
production capacity and those in emergency zones when catastrophic natural or
human disasters strike will likely gladly accept it.
Ontario’s laws protecting food donors are not well understood. This means that
much food is wasted from restaurants, coffee shops, supermarkets, variety stores, farmers’ markets, home gardens and other sites. Education around this legislation needs to expand. Parallel to that there need to be additional measures which provide incentives for the sharing of food across economic sectors, the development of food transformation, the growth of food processing capacity, local ownership of food production and processing facilities (to protect the Province, the industry, consumers and workers from decisions made beyond our borders and for reasons which prioritize external factors over local approval and need). Food remaining at the end of sales period, often a day, can be discounted, diverted to soup kitchens, converted into more valuable goods, in a hierarchy which would value human consumption first, then animal feed (pet or livestock) followed by composting or biomass digestion.
While nobody on the Zero Waste Oxford Committee voiced opposition to
research at academic institutions in the Humanities, Applied or Pure Sciences, in
this area where the “Province [is] to support academic research aimed at reducing and recovering food and organic waste” there is an expression of impatience in light of immediate needs for dramatic waste reduction and drastic food recovery for projects of long duration which might delay implementation. There should be no barrier set up by research or innovation to useful practice. Who would tell a hungry child facing recurring food insecurity that she needs to wait for the end of an academic study in one or two years for the psychologically damaging condition to be remedied. Timely “investments in innovation” and action research are welcomed as is the work of “knowledge mobilization programs” and networks in which various NGOs previously mentioned along with Social Planning Council – Oxford and its Ontario-wide equivalent SPNO. Admittedly, this “ready, fire, aim” approach to food recovery will move the baseline even as data is being collected, but by doing so will produce higher standards of current practice on which to base the ways in which Ontario will take local and “international standards and surpass them” as Wendy Ren has claimed, and rightly has done so, around the Waste-Free Ontario Act.
2. Recover Resources from Food and Organic Waste
This section is also viewed as largely helpful and hopeful by Zero Waste
Oxford, although a clearer definition of “organic waste” could assist in building
a vital circular economy. Economies of scale and other factors mean that “resource recovery costs in the IC&I sectors are generally lower than in the
residential sector”. Because improvement there means large volumes and
means spillover effects of education and practices, this will assist in homes
also. Thus, IC&I wastes need to be targeted by the Province in the very first
rounds of action and regulation. Food recovery in the industrial, commercial
and institutional sectors can save large volumes of food and needs to be acted
on swiftly. Similarly, organic packaging content, such as paper, cardboard
needs to be recovered for reuse, replaced by reusable containers, recycled
into other products and eventually (and if compromised by food adhering to it
or soaked into it) composted. Inorganic food packaging is a serious problem as
well and needs to be converted rapidly to reusable before recyclable and to
eliminate single-use, mixed and polluting products. That “specific actors” are
identified in the Proposed Policy Statement as being in the IC&I sector under
the principle of enhanced aka 100% producer responsibility for food and
packaging is good. Similarly, other organic wastes need to be treated in
accordance with a hierarchy of refusal, reduction, replacement, reuse, recovery, recycling and redirection. Energy inputs, employment, innovation and technological developments need also to be calculated. A multi-criteria assessment tool needs to be utilized to determine the promising methodologies to be adopted in order to satisfy economic, environmental and community priorities.
In order to move quickly, it seems imperative that the “different thresholds
[for resource recovery] for establishments [be] based on their sector and
facility size, quantity of food and organic waste generated” be set first and
highest for those with the highest quantities and percentages of waste
currently. This will produce immediate results and set Ontario on a path to a
circular economy and social equity. It is in the economic interests of “the IC&I
sector to support resource recovery and waste reduction” with notable savings
available through deferred expenditures when waste is reduced. Under these
circumstances, IC&I actors are not spending money merely to discard
products. In the area of resource recovery, there are potential earnings. This
should make this financially attractive as well as morally imperative. As such
the bar for “reasonable efforts” under Ontario Regulations 103 and 104 can be
set higher. “Education and awareness activities on how to source separate”
are important to avoid the contamination of food, rendering it unsuitable for
human and even animal consumption. This needs to be fast out of the gate,
encouraged with incentives, audited and rewarded, and where violated,
subject to suitable fines to repair the loss of food to Ontario and world
populations, the real and potential damage to the environment and other
factors. The “deliberate contamination of source separated streams” cannot
be condoned.
It is not clear in this document what is meant by “the breadth of food and
organic waste covered by the regulation” but it is clear that all food and
organic waste needs to be recovered and put to not merely “beneficial use”
but most beneficial. This requires “measures to promote the quality of
recovered organic material” and to constantly improve it. While the need for
data collection and reporting is evident if progress is to happen, these
requirements of IC&I establishments are benign or advantageous to them and
certainly beneficial to the residents of Ontario. The externalization of costs
associated with recovery, improvement of practices and data collection to the
public is to be avoided under a regime of 100% “producer responsibility”.
That the “Province [is[ to ban food and organic waste from ending up in
disposal sites” is a good step in a broader ban on all landfilling. The
incineration of food is counter to a circular economy, air quality standards,
good sense and an equitable province. The incineration of food waste is costly
in terms of its volume and weight for transport, its liquid content (and thus the
problems with complete combustion) as is that of organic waste. The time for
implementation is now, despite the difficulties of places such as Peterborough
with capacity at compost facilities. This can be alleviated by the rapid
development of small-scale sites, even temporarily, with significant reduction
of organic waste disposal centrally, through processing and resale of organic
products and so forth. Mulching produces a salable product. Vermicomposting
produces liquid or solid soil amendment at a faster rate than windrow
composting. Incentives to municipalities for these and for consortia of them
are likely appropriate to boost potential for recovery and end markets. In
Northern Ontario, the treatment of food wastes is altered by the presence of
bears, the distances waste might travel, smaller population densities, etc. Thus
the expansion of implementation will also be geographical. Large urban
conglomerations need to lead in the short term (and maintain the pace in the
future), smaller urban centres need to expand their current practices in the
diversion then reduction of quantities followed by percentage increases as the
absolute volumes move to zero. Rural Southern Ontario is uniquely well
situated to deal with organic wastes in biomass digesters, windrow composting, farm-field application of suitable and unpolluted soil amendments. For the last of these, purity and freedom from chemicals and pharmaceuticals are important.
As previously suggested, “thresholds for compliance” need to be narrow.
Disposal sites need to refuse “a load of mixed waste” though there remains
the danger of truckloads wandering the countryside in search of less thorough
inspection sites, illegal dumping at pits and quarries (as currently happens
often, regrettably) and other violations of various laws. Alternatively, disposal
sites could have onsite sorting facilities and technologies for which the waste
generator would pay at the disposal site. “Illegal dumping of waste” needs to
be vigorously combatted and eliminated in the short-term with a scheme
where the fines will be more than adequate to provide the necessary
enforcement and administration staff as well as equipment. This means that
the waste hauler would have to be considered the generator for the purposes
of entry to a disposal site, pay up, and where there is a difference between the
hauler and generator, bill the latter. Where source separation regimes are in
place and technologies available, municipally-run disposal sites should have
the right to set premiums for accepting such loads above their actual sorting
costs in order to provide incentive to generators and haulers to practice source
separation and thus reduce contamination and downgrading of valuable,
recoverable resources. The production of biochar which has limited beneficial
uses is perhaps allowable in the interim if the interim is short, but because of
the potential for release of climate-changing gases and disease-causing
particulate emissions should cease. Other sources of biochar are available
from the use of above-ground carbons for heating where biochar application is
proven to be necessary.
It is with relief that the Zero Waste Oxford Committee greets the provisions to
“support resource recovery of food and organic waste in multi-unit residential
buildings”. The extremely newsworthy example of a 1960s apartment building
in Scarborough achieving 85% diversion without major retrofitting and through
the efforts of a building superintendent tell us that this is achievable and not
costly. In terms of long-term sustainability for the province this is a necessary
requirement for current buildings. Full cost analysis will show the economy of
it, once the externalization of costs is factored in. Changes to the building code
for all renovations, additions and new constructions will make this more cost-
effective and wide-spread in urban Toronto’s vertical landscape. In Oxford,
several stakeholders have expressed distress that the current Building Code
has not already been modified to include means to reduce the mixing of food
and organic wastes with other detritus.
It is in a similar vein that the Zero Waste Oxford Committee views the plan “to
develop best management practices to support effective use of public waste
receptacles”. In the same way as the Building Code needs to standardize
modern practice in construction, there needs to be a significant standardization of waste receptacles to permit effective resource recovery. In fact, there will need to be regulations requiring all public, commercial, institutional sites have suitable public waste receptacles which lead to diversion. This too needs to apply especially to fast foods, food courts and such as they are a frequent point of contact for the public helping to form our habits and according to CBC reports egregious offenders.
For the public, “a behavioural sciences approach [to] help change behaviour and encourage proper recycling” sounds Orwellian or like social marketing in its extreme Maoist version, but the use of clear labels, evocative symbols and words, the power of colour and reinforcement of messages and good behaviours can be practical. The “intention-action gap” as described by the Pope of the Eastern Orthodox Church in “Don’t Even Think About it” is not easy to close when “there is a long distance from the head to the heart and even longer from the heart to the hand” but Canada’s experience in the reduction of smoking
through a change in social perceptions of its acceptability is a model. If we can
cause people to protect their and others’ lungs, we surely can cause people to
protect our land, air and water, and should do so.
3. In order to achieve the goals of the Waste-Free Ontario Act and the
Strategy, if is necessary to “support resource recovery infrastructure” using
“modern regulatory approaches to review existing approval processes and
requirements for resource recovery systems”. Those systems, however,
need to measure impacts not merely risks. The thresholds discussed earlier
are too low if risk can be considered to be mitigated when a toxic load is
added to the environment while elsewhere a compensatory measure like a
tree-planting by Girl Guides uses unpaid labour and publicly funded
seedlings. It is good that “Ontario currently has regulatory requirements in
place to ensure that resource recovery systems have the appropriate
approvals and are following standards and practices that are protective of
human health and the environment”. It is unfortunate that this consultation occurs in the context of significant and well-founded public doubt over the application and enforcement of “practices that are protective of human health and the environment” in Grassy Narrows, Sarnia, and multiple other industrial towns investigated by the Toronto Star’s team which identified that “dirty dollars” have in fact rewarded contravention of current regulations. Further, to measure “cumulative human health impacts” would require that the standards be set by public health officials, not currently the case as they are not regulatory agencies. The assessment of “new approaches and processes to facilitate approvals” will be appropriate when they are more rigorous than they currently
appear. There is a need to restore public confidence.
This same principle of assessing new approaches applies as well to the
approval of new technologies and innovations. In order to meet and even
exceed international standards, it will be necessary for Ontario to accept
scientifically valid and proven technical reports and systems for the disposal
of organic and other wastes. This will get Ontario out of the current trap of
working only with past technologies and minor improvements to them. On
large-scale projects, thorough caution is an economic and environmental
necessity. On small-scale projects, the setting of standards for set-backs
and approvals where there is low risk of any negative impact for food or
organic waste treatment is sensible. Vermicomposting or the use of fungal
accelerants when reasonably contained can and will work. See also the
example of the former previously cited. Oxford is a good place to consider
these in light of the social acceptability of composting in general, of green cones in parks and public spaces, of red wigglers in Beachville and of alternatives to landfill expressly.
The implementation of a one-year standard for ECAs after 2017 allows for
rapid initiation of projects and subsequent revisions of standards as needed. This is wise. Systematic screening of them, the return of incomplete applications, and consideration of air and noise issues around them are all valid considerations. As previously noted, however, these processes need to consider not merely risk and mitigation, but overlapping and long-term cumulative human and environmental health impacts. How many such sites can operate in one area? What other contiguous sites might have contributing and negative impacts? What are the consequences over time? Who experiences the impacts versus who measures the risks and impacts? What is socially acceptable? There needs to be a process in place to work through these. Again, that process needs to use a multi-
criteria assessment tool but allow a rapid screening-out of any and all projects with negative impacts.
“Resource recovery systems that include composting and anaerobic digestion” offer possibilities for renewable energy but capture rates need to move from the approximate 50% at those few landfills which do so, to 100% at much better managed and landfill-free sites. The “Operator-in-charge” will need to have high standards of training as currently do waste-water systems managers. The opportunity for training of others on these sites is an obvious advantage in terms of constant availability of expertise, collaborative planning and thinking, succession planning, and the potential for multiple sites in operation in one geographic area. That training, as the draft suggests should “be developed and in some cases required for small scale and low-risk food and organic waste processing sites”. It should be noted that incentives should precede requirement if a qualified operator-in-charge is available to advise those doing small scale and low-risk sites. In a slightly different context, but again as relates to waste disposal, the people of Richmond near Napanee believed that their local operator was running a low-risk site. They were wrong, sadly. Zero Waste Oxford would not want a repetition of that. Participation of the Province in the development of the training will be necessary to assure that the training program, documents and standards align with the intentions of the Waste-
Free Ontario Act and Strategy, and propel us forward. If the design and delivery of the training program is to be “undertaken by a third party” that person or corporation needs to be independent of waste operators, their consultants and even those who developed the standards and training in the same way as international accreditation by ISO standards demonstrate independence, integrity and credibility.
4. Promote Beneficial Uses
That the “Province support healthy soils with strong standards and clear
requirements for the use of soil amendments, while protecting the
environment and human health” seems like a good idea and aligns with
Oxford County goals in the Community Sustainability Plan (See link - http://www.futureoxford.ca/General/SustainabilityPlan/index.htm ) . Since “Farms feed cities” the importance of standards for soil safety need to be set very high in order to prevent contamination such as has happened in Eastern
Ontario through the movement of pollutants disguises as and in “excess soil”. That means that the province should “review regulatory approaches related to soil amendments” not merely with compost and digestate but also with biochar. Residents, municipalities, landscapers and horticulturalists all need access to information about soil amendments and should likely be provided opportunities for training about safety and most beneficial uses. Some clarification will be necessary around this item not only in relation to the application of nutrient to farm fields under current agricultural practices and regulations, as well as in relation to increased application of compost, digestate, biochar and sewerage to crop lands or other places. The infiltration of contaminants into lands, water courses, and ground water need to be prevented as there is little if no remedy. The prevalence of pharmaceuticals and plastics in water are warnings that we must not exacerbate these problems further.
It seems, generally speaking, a good idea that the “Province promote the
use of soil amendments as part of the Agricultural Soil Health and
Conservation Strategy and Oxford County would be a place where research,
innovation and knowledge-sharing might start and emanate from. Fertility, friability and the retention of water are all valuable possibilities of the use of composted organic materials in lands within the Food Belt. Off-farm uses are not unusual. People already buy putting soil, top soil and even organic fertilizer such as Milorganite (processed sewage from Milwaukee) at the supermarket.

[Original Comment ID: 211627]