On page 8, the Introduction…

ERO number

013-1814

Comment ID

787

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

On page 8, the Introduction section of the proposed Framework states that it “strives towards the achievement of the following objectives”.
1.Reduce food and organic waste: Preventing food from becoming waste is a critical first step and has the greatest positive impact on the environment, the economy and society. Rescuing surplus food when it occurs further reduces food waste and ensures that edible food does not end up as waste.

Incentivization may be necessary, as very few in the transport, wholesale, and retail markets (in eastern Ontario) currently appear to be involved in preventing food from becoming waste.
2.Recover resources from food and organic waste: Increasing resource recovery, in particular, from multi-unit residential buildings and the IC&I sector will help the province reach its zero waste and zero greenhouse gas emission goals.

In my experience, the owners of multi-unit residential buildings (MURBs) have intensely resisted renovating to accommodate source-separation of waste streams (i.e. blue-box, and now organics). An extraordinary effort in educating the citizens of the province on the do’s and don’ts of waste separation is required.
As to the IC&I sector, schools, colleges, and universities should and must be included in food waste reduction and resource recovery.
3.Support resource recovery infrastructure: Turning food and organic waste into valuable products recognizes the economic benefits of a circular economy. It is important that Ontario has sufficient infrastructure capacity and innovative technologies to process food and organic waste into valuable resources, such as nutrients, and renewable natural gas.
Given the current length of time required for an Approval to be obtained from the province, many things must change. Without additional Approvals Reform (not to mention incentivization for the private sector), it is not likely that infrastructure capacity will match the required tonnage prior to the Phase-in dates proposed. Since municipalities are already in debt or heading toward it, private industry and/or PPPs will be required to fulfill the massive increase in infrastructure capacity.
Regional compost production facilities with the following attributes are a business-model must:
a.year-round transportation routes without half-load restrictions;
b.appropriately-sized land-holdings in a rural setting;
c.dependable supply of electricity;
d.year-round access to carbonaceous bulking agents;
e.on-site leachate treatment;
f.on-site landfill for disposal of the non-compostable content in the organics feedstock; and
g.adjacent cash-cropped farmland to utilize the compost production.

4.Promote beneficial uses of recovered resources: Supporting end-products and sustainable markets for organic materials is critical. This includes supporting beneficial uses which promote crop growth and enhance carbon storage. Promoting end-products like renewable natural gas, electricity and biofuels can help replace carbon-intensive fossil fuels.
According to the 2015 waste generation numbers quoted, an infrastructure capacity increase of about 2.2 million tonnes is required prior to a landfill ban on organics. Assuming enough facilities could be envisioned, capitalized, approved, constructed, and commissioned by 2025, is there enough farmland in Ontario to utilize all that compost?
And who would measure the GHG required to get the compost from the production plant to the fields?

[Original Comment ID: 212011]