ESSEX-WINDSOR SOLID WASTE…

ESSEX-WINDSOR SOLID WASTE AUTHORITY
COMMENTS TO ENVIRONMENTAL REGISTRY POSTING 013-1814
FOOD AND ORGANIC WASTE FRAMEWORK
JANUARY 15, 2018

NOTE TO MOECC - These are staff comments only at this time due to the tight timeline and January 15, 2018 deadline for comments in response to the posting on the Environmental Registry. The Essex-Windsor Solid Waste Authority Board does not have a meeting until February 2018. It will be at that time that the Framework and these comments will be presented to them. If there are any changes to these comments resulting from that February 2018 Board meeting they will be forwarded to you.
Preface: It is understood and accepted that GHG emissions pose a problem to the environment and these emissions should be reduced. One potential source of GHG emissions is food waste in landfills. Food is only a potential source of GHG emissions if the methane generated by the landfill is not captured but instead is allowed to vent to the atmosphere. Most modern landfills have gas collection systems which reduce or eliminate methane venting to the atmosphere. Further, it is understood and accepted that it is best if food waste can be reduced or not generated at all and for that amount that does end up as waste that it be diverted from landfill. That being said, the amount of food waste still going to landfill from those municipalities falling under the criteria contained within the Framework does not represent a significant quantity that would generate quantifiably measureable GHG emissions. The MOECC and the Province are urged/encouraged to first target those large emitters of GHG and then aim to compel municipalities to comply with the Framework at a time further in the future.
FINANCIAL BURDEN TO SMALLER MUNICIPALITIES
1.Delay implementation for municipalities. This is a financial burden to municipalities, therefore wait for municipalities to fully transition their blue box programs to full EPR as opposed to layering on another cost. This comment does not imply that municipalities should be using possible, and not yet definite, future blue box cost savings to pay for costs associated with managing food waste. Rather, waiting will provide municipalities the time to better plan and budget for costs associated with food waste collection, processing and initial capital costs.
2.Budget impact to smaller municipalities. Smaller municipalities would be more negatively impacted with the addition of collection and processing costs. Although the framework calls for “collection” (meaning drop-off depots) and not “curbside collection” for smaller municipalities, this most likely is not practical as instructing residents to deliver food waste to a depot would probably be not well received and will result in low participation resulting in people “hiding” their food waste in their yard waste organics or coming up with other means by which to not participate.
3.Municipalities in southwest Ontario have stagnating tax bases and are still struggling or recovering from recent recession events. Additional costs added to their budgets will exacerbate their current budget situations. This is different than in the central part of the Province and in the nation’s capital region where the tax base can support increases in municipal budgets.
4.Financial assistance for initial capital costs (e.g. carts) and operating costs would prove beneficial and may even encourage those municipalities not compelled to collect by the Framework to establish programs. A good example of this was the blue box program when it was first initiated. Since funding was available, municipalities that were not compelled to have programs under the Regulation did establish programs since capital and operating funding eased the financial burden and made the delivery of the program more affordable.
FOCUS ON OTHER SECTORS FIRST
5.Focus on non-municipal sectors first. Delay implementation for municipalities. Implement the program in the ICI sector first since there is more food waste in this sector compared to the municipal sector. Most of the large municipalities already have programs so the amount that would be diverted from the smaller Ontario municipalities would be negligible in the bigger picture.
6.Focus on non-municipal sector first re: seeking to reduce GHG emissions. The posting to the Environmental Registry states that in 2015 GHG emissions from the waste sector accounted for approximately 5% of Ontario’s total GHG emissions from all sources. This would mean that municipal collected food waste represents an even smaller percentage. While it is acknowledged that reducing GHG from all sectors is important it is suggested that the focus be on the larger non-municipal generators of GHG emissions. Further, modern municipal landfills negate the effect of GHG emissions by capturing the methane generated and either converting it to an energy source, and if this is not possible, flaring it in order to negate the effects.
MOST MUNCIPAL FOOD WASTE IS ALREADY BEING DIVERTED
7.Most of the large volumes of municipal food waste is already out of the waste stream. Since the largest of Ontario’s municipalities already have programs the amount available for diversion from the smaller municipalities is negligible when calculating GHG emissions.
DISPOSAL BAN
8.Disposal Ban – When considering all of the comments in this submission it would then be advisable to delay/defer any implementation of a municipal disposal ban. A phasing in beginning in 2022 may not be practical/reasonable as it does not provide enough time for municipalities to: (a) amend or terminate current waste collection contracts since collection fleets will need to be modified in some municipal systems or applications to accept 2 streams in one vehicle from the current single stream; (b) either construct or arrange with another party for processing of their resident’s food waste
9.Disposal Ban – Undertake further study and analysis to examine the practical application of such a ban at curbside, municipal transfer stations and landfills.

INFRASTRUCTURE AND END MARKETS
10.Infrastructure and End Markets – Having the ICI sector implement Food Waste Reduction programs first will allow for the creation of the infrastructure and sustainable end markets for the product. This can then allow for an easier entry for municipalities since it can then be analyzed whether or not further reduction of food waste is feasible/advisable depending on the availability of processing facilities and end markets.
11.Infrastructure – Without additional processing facilities across the province, the processing facilities currently in existence can dictate a price due to lack of competition. Municipalities will end up being price takers without a choice of options. This will of course result in higher costs to municipalities.
12.End Markets – Some municipalities currently are unable to find markets for all of the compost material that they create resulting from their yard waste organics collection programs. Material is either sold at low prices or even given away resulting in a net cost to the municipalities. Without sustainable end markets for the product created by any food waste process, further costs will need to be absorbed by municipal budgets.
STAGED APPROACH FOR MUNICIPALITIES
13.If, after considering all of these comments, the Ministry and Province wish to implement municipal Food Waste Collection Programs then implement them first among the high population/high density municipalities only (e.g. Windsor and London) and delay the implementation for the smaller municipalities until it can be shown that the additional food waste being added to the infrastructure and processing system in the province from the larger municipalities can be managed at reasonable cost. The smaller municipalities can then learn from the larger municipalities and perhaps piggy back on to their method of managing their residents’ food waste.
FOOD WASTE TO ENERGY
14.Natural Gas and Renewable Natural Gas (RNG) – The Framework document talks about food and organic waste being a potential source of RNG. This conversion process will be less attractive from a financial perspective as long as natural gas prices remain low as they have been historically (the past 8 or 9 years or so).

Ilija (Eli) Maodus
General Manager
January 15, 2018
emaodus@ewswa.org
519-776-6441 x1226

[Original Comment ID: 212007]