January 11, 2018…

January 11, 2018
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, ON M4V1M2
Dear Mr. Drew,
RE: Proposed Food and Organic Waste Framework - EBR Registry Number: 013-1814
Thank you for the opportunity to provide feedback regarding the proposed Food and Organic Waste Framework. I am extremely supportive of the efforts taken by the Province in the last two years to engage waste prevention and drive resource recovery.
Community-Neighbourhood Based Organics
Challenges exist in many municipalities to collect and manage organics. Some municipalities assist local residents by providing depots for centralized organics collections and/or backyard composters (BYC). Residents face many challenges with these types of activities including:
•Residents may haul their organic materials to a municipal site but this requires a suitable vehicle, as well as valuable time.
•Many homeowners have tried to maintain their own BYC but find it too time consuming and difficult to keep up.
•Backyard composting will attract pests if it is not properly maintained.
•BYC requires a balance in a variety of organic materials. The location and construction of a typical backyard compost can make creating and maintaining this balance challenging.
•Some materials are unsuitable for backyard composts, such as large branches, weeds, and invasive species; which Community-Neighbourhood Composting can effectively compost.
When waste is removed by collection trucks from residential areas it supports the concept of “out of sight, out of mind” and has impacts on greenhouse gas emissions and road infrastructure costs. In order to reconnect residents with their waste streams (organics specifically), and motivate effect waste prevention and reduction activities, local community-neighbourhood organics initiatives should be undertaken. This will reduce the ecological impact of organics collection and processing (mitigating climate change), build local economic capacity (development of business and non-profit enterprises), and keep nutrients cycling within the geographic areas they are generated.
Support Resource Recovery Infrastructure
In order to realize the ambitious outcomes envisioned in this Framework it will be pivotal for the government to move quickly to remove some of the current barriers to ensure new capacity can be developed to accommodate new organics activities for a variety of municipalities.
I strongly support streamlining the approvals process and reviewing existing requirements. In my previous role as the Manager of Waste at the County of Peterborough we had to abandon many attempts to modernize and improve organics collection for residents due to existing ECA barriers. It is imperative that the government explores options to reduce approval timelines for new community-neighbourhood based facilities and make changes to current approvals.
I recognize that this waste stream poses potential environmental risks, and therefore needs appropriate controls, however the frameworks should consider some additional options including:
Exemptions:
A number of activities that the Ministry of the Environment & Climate Change currently regulate should be considered exempt (with appropriate boundaries), such as collection facilities (e.g. community depots), and small community-neighbourhood compost facilities.
Use of Qualified Professionals:
For existing organic facilities, ensuring that approval amendments can happen in a timely manner is especially important to allow adaptations to changing markets, improved collection technologies, and/or incoming materials. The current process of potentially waiting 300 days (the current median) for an approval or amendment is simply not practical.
Allow for community-neighbourhood operated facilities to develop without the requirement of a formal Environmental Compliance Approval but with sign-off by a qualified professional. A sign-off letter from a
Qualified Professional confirming the outcome meets Ministry criteria could be provided to the Regional Office with operation specifications and compliance monitoring plans.
This process needs to be transparent and the Qualified Professional must have the appropriate knowledge and skills and insurance.
Environmental Activity and Sector Registry:
Another way to utilize existing MOECC infrastructure to allow for community-neighbourhood organics programs would be to broaden the Environmental Activity and Sector Registry (EASR) system. It could be opened to consider and streamline support for certain compost facilities that have a relatively consistent risk profile.
These facilities are well understood by the government and the types of conditions placed on many of them are already relatively standardized. The EASR system, where deemed necessary, could allow for a range of assessment to manage any risk exposure.
Thank you for the opportunity to provide feedback and feel free to contact me if you have any additional questions.
Sincerely,
Laurie Westaway
Wasteaway, Owner
Trent University Waste Management Instructor, School of the Environment
Current Member of Ontario Food Collaborative
Previous, Manager of Waste at the County of Peterborough
Former Chair, Green Communities Foundation
Former Board Member, Municipal Waste Association

[Original Comment ID: 211940]