Comment
The Environment and Sustainability Committee (ESC), of the Ontario Association of School Business Officials (OASBO), represents school boards across the province. The ESC provides an opportunity for school board environmental professionals and partners to support school communities by sharing information and best practices related to environmental or sustainability issues and concerns from a purchasing, operations, and program perspective.
The ESC has drafted comments, together as a committee, in response to the Proposed Food and Organic Waste Framework, as posted on the Environmental Bill of Rights (EBR) website.
The ESC believes that there should be consideration given to school boards as a different category of waste producers either within or outside the ICI sector. As it stands now publicly funded school boards are treated the same as all commercial properties, large institutions such as universities and hospitals and industrial buildings. School boards represent almost 5000 publicly funded schools across the province, which are located in residential areas. The food waste that is generated in schools is almost entirely from residences in the form of the children’s lunches which are disposed of at school. The cost of this disposal then becomes an expense for the school boards, and private organics collection in most jurisdictions is cost prohibitive for boards. While there are several municipalities across the province that have seen the value in extending the residential organics program to schools, there are more that refuse to offer the services to schools because they fall within the ICI sector, which by regulation, falls outside of their mandate. It is the recommendation of the ESC that publicly funded schools be treated similarly to multi-residential units and that municipalities be required to offer school boards the option to participate in municipal organics and leaf/yard waste collection programs on a cost sharing or cost recovery basis. This collaboration across government organizations will not only result in increased diversion of organic waste from the schools, but will also reduce administration impact and costs to both organizations. Furthermore, the education component that comes from mirroring the diversion program in the schools is extremely beneficial to the municipal residential program as the children become accustomed to that type of organic waste stream and encourage their families at home to do the same.
The current cost to outsource organic waste collection at schools is cost prohibitive for most boards. The private organics collection programs are not common amongst the ICI sector which drives the cost of collection up. In addition, there are significant initial start up costs to procure all of the necessary bins and materials for the classrooms and other shared spaces in the schools where organics collection will occur. However, when there are partnerships established with municipalities there are significantly lower costs as the schools are located in residential areas and the trucks that are collecting organic waste from the residences can pull into the school and collect the material. This model is much more financially viable for school boards, and also enhances the municipal program. In addition, the board can procure the same bins the municipality is providing to the residences at a reduced cost due to volume discounts.
The Ministry of Environment and Climate Change has identified the need to create standardized materials across each sector, and to collaborate with the appropriate sectors. The ESC is a group of experts that support and implement promotion and education in Ontario schools on a variety of environmental issues. In addition, utilizing the Ontario EcoSchools existing curriculum linked waste reduction and diversion activities, guides and other materials would be another great resource. Ontario EcoSchools publicly shares these materials for free, and they are already being utilized in over 1700 certified EcoSchools across the province.
In Section 4 of the policy statement (page 48) the Ministry has identified that generators in the IC&I sector account for a significant portion of food and organic waste sent for disposal in Ontario, however, it goes on to identify that only those IC&I locations that produce greater than 300kg / week of organic waste would be required to source separate food and organic waste for disposal, and any that fall under that threshold “should” source separate.
Based on a preliminary look at data shared from several boards across the province we are estimating that on average a student produces between 0.12 - 0.4kg of organic waste per week. If we assume the average elementary school has 500 students this would result in 60 - 200 kg of organic waste per week. If the average secondary school has 1000 students this would result in 120 - 400 kg of organic waste per week. Based on this information a school would need to have over 750 students to reach the 300kg/week threshold. For most school boards that would completely eliminate all elementary schools and leave only some secondary schools required to participate. We strongly feel that this threshold is much too high for all of the IC&I sector, but especially for school boards, and that by leaving the threshold at this level will be a missed opportunity for the Ministry to ensure organic waste doesn’t go to landfill. A large portion of the waste that is generated in schools is organic waste, audits at schools have shown that 60% or greater are organic waste that could be diverted. Diversion rates for schools that participate in organics programs can be in excess of 80%!
The ESC is willing to work with the Ministry to provide access to waste audit data and other information that we have collected over the years. In addition, Ontario EcoSchools conducted a waste audit study at several schools in the province two years ago to determine if there was a measurable difference in waste diversion in certified and non-certified EcoSchools.
The Ministry has identified the need to conduct regular waste audits and support data collection for the information. They have identified the requirement to “support waste audits” - would this support be in the form of financial support to fund the costs of waste audits? This is also a large expense for boards to remain in compliance with the current regulations.
Page 41 identifies that leaf and yard waste is to be included in the definition of organics collection. For many boards municipalities will not collect leaf and yard waste from schools, even if they currently collect organic materials. This creates an additional costs for the boards to have the material removed from the school site. It is our recommendation that it should be included in the organics program and collected by municipal partners or other agencies collecting residential organic material.
School boards are being encouraged to foster partnerships with outside agencies to utilize schools outside of school hours, or to use vacant space within schools - creating community hubs in our schools. Unfortunately, these permit users are not as well educated and trained as our students and staff on waste diversion programs and we often see considerable contamination of diversion programs, as well as wasteful behaviours in general (i.e. using disposable materials instead of reusable, or materials that are garbage instead of recyclable). This has a detrimental effect on the school’s waste diversion numbers but is outside of the control of the occupants of the school. It is the ESC’s recommendation that some thought be given to language that includes not only the education sector to implement these programs, but also that all users of these spaces must adhere to the waste diversion programs that are put in place, and that it is their responsibility to be made aware of what is available.
[Original Comment ID: 211991]
Submitted February 9, 2018 2:10 PM
Comment on
Food and organic waste framework
ERO number
013-1814
Comment ID
770
Commenting on behalf of
Comment status