This is a collection of…

This is a collection of comments and questions from College and University Sustainability Professionals from across Ontario.
Comment 1
Part A: PROPOSED FOOD AND ORGANIC WASTE ACTION PLAN Section 16:
“Province to support development of renewable natural gas including consideration for linkages to food and organic waste”
Instead of promoting the development of renewable natural gas, it would be better to focus our efforts on breaking our dependence on natural gas of any kind.
RNG’s carbon footprint is considerably lower than conventional natural gas. However in the long run composting has the opportunity to sequester more carbon and return more nutrients to the soil than anaerobic digestion.
Part B PROPOSED FOOD AND ORGANIC WASTE POLICY STATEMENT
Comment 2
Under “Part III: Policies” 1.2:
Instead of “should consider prioritizing” the language “shall prioritize” should be used.
A high priority needs to be placed on waste reduction and reuse. Often activities that could achieve these goals are ignored in favour of composting or anaerobic digestion.
Incentives and disincentives from the government should also align with this hierarchy.
Comment 3
Under “Targets” 2.3:
The language “iii. Additional paper fibre products” is unclear.
It is not immediately clear what types of products this is referring too.
If this is referring to unsoiled recyclable paper fibre products this item should not contribute towards achieving the organic and food waste reduction and resource recovery target.
This could promote large amounts of recyclable products to be sent to anaerobic digesters or composters instead of being recycled like they should be.
Comment 4
Under “Targets” 2.4:
We need more information on how the waste reduction and resource recovery targets will be calculated and measured.
The most important piece of information to know that has not been included is if this target will be calculated based on a baseline year, the previous year or the total organic and food waste produced in that year alone.
Here are a few example scenarios and calculations to showcase how different these calculations could look. The scenarios were specifically chosen to showcase some of the issues and features of these different methods.
Examples of sample calculations using the Baseline year method:
In 2019 we calculated that we produced 2000 tonnes of organic and food waste.
It is now 2025 and we need to calculate if we reached our target.
Scenario 1
We produced 1400 tonnes of organic and food waste this year and we sent 800 tonnes of that to a composting facility and 200 tonnes was donated to a local food bank.
Our reduction contribution to the target would be
(2000-1400)/2000*100%=30%
Our recovery contribution would be (800+200)/2000*100%=50%
30%+50% = 80%
This gives a Food and Organic reduction and recovery rate of 80% measured against our baseline year (2019).
Scenario 2
We produced 3000 tonnes of organic and food waste this year and we sent 2000 tonnes of that to a composting facility.
Our reduction contribution to the target would be
(2000-3000)/2000*100%=-50%
Our recovery contribution would be 2000/2000*100%=100%
-50%+100% = 50%
This gives a Food and Organic reduction and recovery rate of 50% measured against our baseline year (2019).
Examples of sample calculations using the benchmarking against a previous year method:
Scenario 3
Last year 2024 we produced 2000 tonnes of organic and food waste this year we produced 1800 tonnes and sent 1000 tonnes of that to a composting facility.
Our reduction contribution to the target would be
(2000-1800)/2000*100%=10%
Our recovery contribution would be 1000/2000*100%=50%
10%+50% = 60%
This gives a Food and Organic reduction and recovery rate of 60% measured against the previous year (2024).
Scenario 4 (The following year)
Last year 2025 we produced 1800 tonnes of organic and food waste this year we produced 1790 tonnes and sent 1000 tonnes of that to a composting facility.
Our reduction contribution to the target would be
(1800-1790)/1800*100%=0.5%
Our recovery contribution would be 1000/1800*100%=55.5%
0.5% + 55.5% = 60%
This gives a Food and Organic reduction and recovery rate of 60% measured against the previous year (2025).
If the target is calculated every year based only on how much organic and food waste a location produced that year, it would be better if waste reduction efforts were not included in the target calculation for two main reasons:
1. It is very difficult to determine how much food and organic waste was prevented from being produced in any given year.
2. Calculating the target this way means the target is affected more by the amount of organic and food waste that was landfilled or incinerated rather than how much waste was theoretically prevented. It penalizes not eliminating or recovering waste as opposed to rewarding reduction. As a result this gives you a continuing incentive to keep reducing and recovering more and more waste year after year.
An example to showcase this change in emphasis:
An institution produced 2000 tonnes of organic and food waste in 2025, sent 1000 tonnes of that material for composting and managed to calculate that they prevented 1000 tonnes of food and organic waste being produced that year (i.e. if their reduction efforts were not in place they would have produced 3000 tonnes.)
Scenario 5:
The reduction efforts are not directly included in the calculation
Total O&F waste diverted / total produced.
1000/2000*100% = 50%
They achieved a 50% food and organic waste reduction and recovery rate.
Scenerio 6:
The reduction efforts are also included in the calculation
The reduction contribution
Total F&O waste prevented / Total F&O waste that would have been produced without the reduction efforts.
1000 tonnes / 3000 tonnes *100% = 33.3%

The recovery calculation changes slightly from the calculation in the above scenario.
Total O&F waste diverted / Total F&O waste that would have been produced without the reduction efforts.

1000/3000*100% = 33.3%

They achieved a 66.6% food and organic waste reduction and recovery rate.
In the first scenario the reduction efforts indirectly contributed 16.7% towards achieving their 50% rate. In the second scenario the reduction efforts contribution roughly doubled to 33.3%
The Scenario 2 calculation looks very similar to the sample target calculations that use a baseline or previous year benchmarking number.
We also have concerns about how this organics waste information will be verified. Specifically how we will be calculating how much food and organic waste we produced in a given year.
It is feasible to calculate how much organic and food waste was recovered.
(To help with that, it could be mandated that organic and food waste pickup be billed by actual weights as opposed to volume conversion or estimates.)
However, it could be extremely difficult to determine how much organic and food waste was sent to landfill or an energy from waste facility with the rest of the garbage. Is this something that will be done through 3rd party verified audits? Waste audits from waste haulers should not be used, as this presents too great of a conflict of interest in order for this to be considered a viable option.
Targets based on food and organic waste generated per person is another idea that might be worth exploring, especially for places like schools and multi-residence buildings.
Comment 5
Under 3 “Reduce Food Waste” in the “Promotion and Education” section:
The introductory paragraph mentions a “change in behavior”, but it would be good if it also mentioned a need for a change in our attitude towards and values surrounding food and providing and necessary knowledge for people to make changes.
Comment 6
Under “Recover Resources from Food and Organic Waste” 4.18:
Please provide specific examples of some potential financial measures that could be taken.
Comment 7
Under 5 “Compostable Products and Packaging”:
These items must be clearly labelled or it will be impossible to correctly inform consumers on how to sort these items.
And
In 5.1 “should ensure” should be changed to “shall ensure”
And “These products shall be visibly labeled with that certification.” should be added.
Currently compostable products can be completely indistinguishable from products that are not compostable. One of our institutions is currently experiencing issues where they have some items that are 100% compostable but since they are not labelled a majority of these items end up being thrown out.
We also have institutions where we have products that are labelled as compostable, but these items are not accepted for organics collection. These products need to be certified and labelled with that certification.
An example of a certification and label that is already in use by manufacturers and municipal sorting guides is the BPI compostable product certification.
http://www.bpiworld.org/products.html
There should be more discussion about which standards are acceptable to use and making it clear in labels which composting processes accept these products. For instance, most of these certified products will not compost in a reasonable time in a backyard composter.
Comment 8
Under “Measuring Success”:
In the first bullet point, remove the words “or volume”
Weight is a better indicator of progress towards this goal than volume.

Questions
Question 1
Will there be opportunities to apply for funding for social marketing campaigns?
Question 2
Is using the gas produced from anaerobic digestion considered to be a form resource recovery?
In the glossary in the resource recovery definition an anaerobic digestion example is given.
“The recovery of nutrients, such as digestate from anaerobic digestion, is considered resource recovery.”
Is the gas from anaerobic digestion not included in this example because that would be considered making energy from waste and therefor isn’t considered resource recovery? Please clarify.
Question 3
The government currently helps pay for the transport costs to redistributed food by supporting Second Harvest. Should industry be footing this cost instead?
Question 4
Perhaps outside the scope of the organic waste framework, but could institutions be required to have a minimum target for local food procurement?
More General Comments
CSAs (Community Supported Agriculture) programs are one strategy for reducing food waste at the farm level, as this allows for a more direct supply chain, by bypassing grocery stores and food terminals. This can help farmers anticipate and plan how much food to grow each season.

[Original Comment ID: 211985]