Proposed Food and Organic…

Proposed Food and Organic Waste Framework
EBR Posting 013-1814
Overview
The Province should be commended for recognizing that food and organic waste make up a significant percentage of the waste going to landfill in Ontario. Food and organic waste currently make up one third of the waste stream. The Province has recognized that reducing the amount of food and organic waste going into the waste stream provides an economic and health benefit to the residents of Ontario. The recognition by the Province that food is a resource that can be used to feed people works directly with Oxford County’s goal to eliminate poverty in Oxford County. The removal of food and organic waste results in environmental benefits in the reduction of greenhouse gas from landfill and lessens the reliance on landfills in Ontario. Removing food and organic waste from the landfill allows the turning of food and organic waste into valuable products and energy that recognize the benefit of a circular economy.
Oxford County commends the development of two complementary components of the proposed Framework:
Part A - Proposed Food and Organic Waste Action Plan which outlines the strategic commitments to be taken by
the Province to address food and organic waste; and
Part B - Proposed Food and Organic Waste Policy Statement under the Resource Recovery and Circular Economy Act, 2016 which provides direction to the province, municipalities, producers, IC&I sector, waste management sector, and others to further the provincial interest in waste reduction and resource recovery as it relates to food and organic waste.
Comments
Oxford County commends that the Province has developed the following guiding principles for the proposed Framework including:
•Enhancing existing partnerships with stakeholders and building new relationships.
•Building on progress made in Ontario and learning from other leading jurisdictions.
•Collaborating across all levels of government to avoid duplication.
•Supporting an outcome based approach.
•Using evidence to guide decision making.
•Using regulatory and non-regulatory tools.
•Creating conditions that support sustainable end-markets.
•Increasing the use of innovative technologies.
•Enabling efficient and effective recovery systems.
•Recognizing the administrative impacts and costs to collect and recover organic materials.
•Increasing accountability.
The proposed Framework supports the vision set out in the Strategy for a Waste-Free Ontario: Building a Circular Economy. It supports the Oxford County goals of zero waste and eliminating poverty through the following objectives:
•Reduce food and organic waste by preventing food from becoming organic waste.
•Recover resources of food and, organic waste in particular, from multi-unit residential buildings and from the
IC&I sector. Rescuing food and feeding people.
•Support resource recovery infrastructure.
•Promote beneficial uses of recovered resources.
Part A: Proposed Food and Organic Waste Action Plan
Part 1: Reduce Food Waste
•The Province has identified that it needs to develop promotional and educational tools to support food waste prevention and reduction. The Province needs to work with food producing groups, municipalities, the IC&I sector and non-profits to develop educational tools and materials that are effective and consistent in order to engage the various audiences in Ontario. This promotion and education material must lead to developing a culture of food waste avoidance. Municipalities such as Oxford County will require funding from the Province to effectively promote and educate.
•The Province has identified the need to enhance and incorporate waste reduction and resource recovery activities within schools. Only by engaging Ontario’s school population, can the goal of the behavioural change creating a culture of food waste avoidance be attained.
•The Province has recognized that any programs implemented in Ontario must compliment programs offered by the Federal government. The Province must also recognize that its proposed programs must also compliment the current or proposed programs in its municipalities. Municipalities typically run waste management programs such as waste collection, recycling collection and organics collection that realize efficiencies though integration of these programs. Requiring strict changes to food and organics collection and processing could have effects on remaining programs.
•The Province has proposed to work with partners to support innovative approaches to rescue surplus food. The Province needs to work with producers, wholesalers, retailers and food service providers to promote a culture of 100% food usage. The Province needs to provide financial incentives to encourage the rescue of surplus food and redistribution. The Province, through its promotion and education program, needs to make the residents of Ontario aware of the programs available to collect surplus food and programs that redistribute this food. The Province also needs to put in place guidelines that, while protecting the health of Ontarians, also makes it easy for surplus food to be redistributed.
•The Province needs to continue to fund academic research that has the goal of producing food that is high quality, easy to store, and conserves our soil, water and air.
•The Province has recognized that, to measure progress of waste reduction and resource recovery, there must be a data collection mechanism in place. Municipalities have been required for many years to report their waste production and diversion activities. The requirement for the IC&I sector to report their waste production and diversion will improve transparency and accountability. It will also help direct the resources needed with regards to promotion, education and enforcement.
Part 2: Recover Resources from Food and Organic Waste
•The Province has proposed to amend the 3Rs Regulations to include food and organic waste and increase resource recovery across the IC&I sector. Oxford County recognizes that some of the best opportunities to increase resource recovery and building a circular economy are in the IC&I sector. By requiring the IC&I sector to follow requirements to collect waste and report waste disposal and diversion similar to what is required by municipalities, it gives the potential to capture and reuse a significant portion of the waste stream that is currently being disposed of through the landfill.
•Under the Environmental Protection Act, the Province is proposing to implement a food and organic waste disposal ban which would regulate the disposal of food and organic waste at waste disposal sites including landfill, thermal treatment sites and transfer stations. The Province needs to recognize that municipalities will require an appropriate timeframe for the implementation of the ban to allow them to implement food waste and organic waste collection and processing programs or technologies. The Province will also need to develop a compliance and enforcement component which will be consistent in its interpretation and enforcement of the ban. There also needs to be clear definitions of what is considered disposal, thermal treatment and a transfer station. The Province will also need to have a clear definition of what food and organic waste is and what would be considered a “total ban”. The Province will also need to address the movement of food and organic waste to jurisdictions outside of the province of Ontario. How would disposal of food and organic waste to landfill or other treatment outside of Ontario be handled?
•The Province has committed to supporting resource recovery in multi-residential buildings in Ontario through the Ontario Building Code. The Province will need to consult with municipalities with regards to the proposed changes, implementation and enforcement as the Ontario Building Code is typically enforced at a municipal level.
•The Province is proposing to develop best management practices to support effective uses of public waste receptacles. The documentation will have to have sections directed to the different demographics such as Large Urban, Medium Urban, Small urban, Large Rural, Medium Rural and Small Rural. Documentation will need to be clear and consistent to avoid confusion as to where to deposit materials. By having documentation and expectations that are consistent across the province, the public will find it easier to place their recyclables in the proper receptacles.
Part 3: Support Resource Recovery Infrastructure
•The Province has proposed to use modern regulator approaches to review existing approval processes and requirements for resource recovery. Oxford County recognizes the Province’s Proposal to use regulator approaches that are modern and efficient as commendable. The Province, though, has had difficulty implementing streamlined and efficient approval processes in other regulatory areas. The proposal will require significant consultation with municipalities, collection contractors and processing to ensure the process goes smoothly and quickly. With the proposed food and organics ban to disposal, the Province will need to be willing and open to alternative collection and processing options for organic material. The Province, in its approval process, will need to take into account land use compatibility, environmental and health implications, regulatory oversight, training and operating guidelines and impacts on nearby communities.
Part 4: Promote Beneficial Uses
•The Province has recognized that food and organic waste can be recovered and re-integrated into the economy. Oxford County, with its diverse agricultural background, has many opportunities for organic waste to be processed into compost, digestate and other soil amendments that would be beneficial to Oxford County agriculture. Oxford County recognizes that any soil amendment process would need to align with the province’s proposed excess soil use regulation and Nutrient Management Act.
•The processing of organic waste on Oxford County farms supports the development of biogas digesters and the production of renewable natural gas and other low-carbon energy substitutes. The Province will need to provide financial support to encourage the development of these processing facilities and the production and use of biogas. The Province will need to support the use of these green products such as compost and biogas.
Part 5: Timelines
•The timelines to implement the proposed Action Plan are significant and ambitious in some cases. Oxford County would like to see an emphasis on the implementation of the 3R’s Regulation to include food and organic waste recovery in the IC&I sector. The majority of the food and organic waste currently being disposed is from the IC&I sector.
Part B: Proposed Food and Organic Waste Policy Statement
Part 1: Preamble
•The proposed policy statement supports the provincial vision of a circular economy and is an important tool in moving towards zero waste and zero greenhouse gas emissions in waste management. The Policy Statement proposes to further the aims set in section 2 of the Resource Recovery and Circular Economy Act, 2016. The policies within the proposed Policy Statement will be complemented by future policy statements as required to support the aims.
Part 2: Reading the Policy Statement
•The Province has agreed that the Policy Statement must be reviewed and considered for amendment within 10 years of issue. The Province must consult all stakeholders, including municipalities, before issuing new policy statements and amending any existing policy statements. The Province will need to take into account the geographic and demographic differences in Ontario. A policy that might work in one municipality may not be workable in another. There needs to be some discretion when applying a policy.
•The Province will need to recognize that the requirement for municipalities to amend official plans, zoning by-laws, other by-laws and prescribed instruments to ensure consistency with policy statements will require a significant time commitment from municipalities.
Part 3: Policies 1, Ontario Food Recovery Hierarchy
•Oxford County agrees that the Ontario Food Hierarchy should be: reduce, prevent food waste at the source, feed people by safely rescuing and redirecting surplus food, recovering food and organic waste for beneficial use. Rescuing food and feeding people plays an important part in Oxford County’s goal to eliminate poverty in Oxford County.
Part 3: Policies 2, Targets
•Oxford County agrees that targets need to be established to assess progress in addressing food and organic waste. The Province has determined the target dates based on municipality location and size in the policy. This approach does not take into account that the municipality, as defined by the policy, may not be reflective of the actual municipal level of government responsible for waste management. The Province will need to be clear in its definition of what would be acceptable processing of food and organic waste as it relates towards meeting targets.
Part 3: Policies 3, Reduce Food Waste
•Oxford County recognizes that preventing food from becoming waste is a major component of addressing food waste in Ontario. Through Provincially sponsored promotion and education programs, the consumers in Ontario will need to be made aware of the true amount of food they actually waste and the associated costs of this waste. The Province should promote retail establishments, restaurants, food processors and manufacturing establishments to focus on preventing and reducing consumer food waste. Education and promotion should be directly aimed at consumers to prevent and reduce food waste.
•Retail establishments, retail shopping, restaurants, hotels, motels and food processors in addition to be required to report their waste disposal and diversion numbers, will be required to use best practices when dealing with food waste. In the case where food might not be useable to the establishment, programs need to be utilized to rescue the food for use with disposal as a last option.
Part 3: Policies 4, Recover Resources from Food and Organic Waste
•While the Province recognizes that many urban municipalities have recovery programs for food and organics, the Province must also recognize that what works in an urban environment may not work in an urban/rural environment such as Oxford County. Driving large trucks down Ontario’s rural roads to collect food and organic material is neither environmentally or financially sustainable. Many of the current source separated organics programs in place do not meet the targets of zero food and organic waste to disposal. The proposal to require municipalities, that have existing programs in place, to maintain them could cause issues for municipalities that would like to implement technologies that have better capture rates than the current programs in place. Municipalities should be allowed to changes programs if it is shown that there is an improvement in the capture of food and organic waste. Emphasis should not be put on source separated organics as the preferred method of collection if the municipality can show that a process of technology exceeds the outputs of a source separated program. The idea of supporting residential resource recovery through other methods needs to be treated fairly and on, at least parity with, source separated programs. The Province needs to show its support for alternative methods financially and through efficient streamlined permitting processes.
•Oxford County recognizes that the largest generators, and largest opportunities to recover food and organic waste in Ontario, is the IC&I sector. The requirement for only the establishments in the IC&I sector that produce more than 300 kg of food and organic waste to have source separation programs in place seems too high. 300 kgs/week of food and organic waste per week equates to over 15 tonnes of waste per year which is still a significant amount. The Framework policy does not explain how the 300 kg/week limit would be calculated, verified and enforced.
Part 3: Policies 5, Compostable Products and Packaging

•Oxford County agrees that the use of compostable products and packaging is favourable to using disposal products and packaging. Oxford County emphasizes that promotion and education should be focused on avoiding the use of products and packaging, if possible. Producers of the products and packaging need to be held responsible for educating the consumer on the proper resource recovery program available for their products and packaging.
Part 3: Policies 6, Support Resource Recovery Infrastructure
•Oxford County, as a municipality, already supports and will continue to support planning resources that encourage increased resource recovery. Oxford County will continue to support private industry in building facilities with technologies that encourage resource recovery.
•Oxford County as a municipality will, wherever possible, coordinate approval processes with other government approvals to facilitate timely approvals for resource recovery systems.
•Oxford County agrees that mixed waste processing is one method that can support resource recovery where the viable materials can be marketed or land applied in Ontario. The mixed waste processing should not be limited to source separated materials if it can be shown that the processing method meets the targets of the province.
Part 3: Policies 7, Promote Beneficial Uses
•Oxford County, with its large agricultural background, recognizes the benefits of organic matter in farming practices. The use of compost as a soil amendment is supported and encouraged by Oxford County. The use of compost in environmental remediation, as well as, mining and aggregate reclamation projects is acceptable with reference to the proposed excess soils use regulation.
Part 3: Policies 8, implementation
•The Province needs to work closely with municipalities to develop guidance and support mechanisms for resource recovery in Ontario. Municipalities are very familiar with what works in their municipalities when it comes to waste management.
•The province needs to have the expectations of collection and reporting with the IC&I sector to the same level they have expected from municipalities for years.
•The province needs to regularly consult with municipalities and to review the policies on a regular basis.

[Original Comment ID: 211992]