Ian Drew, Senior Policy…

Ian Drew, Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division: Resource Recovery Policy Branch
40 St. Clair Avenue West , Floor 8
Toronto Ontario M4V1M2
Subject: Comments for the MOECC Food and Organic Waste Framework [Correct? Ontario Ministry of the Environment and Climate Change]
Dear Mr. Drew:
With regards to the Ontario Ministry of Environment and Climate Change’s (MOECC) proposed Food and Organic Waste Framework, please accept the following comments on behalf of the Canadian Water Quality Association and the Canadian Institute of Plumbing & Heating.
Both of our organizations applaud MOECC’s comprehensive approach to managing the multitude of challenges presented by the generation of organic wastes, and residential food scraps in particular.
While the Framework primarily explores the truck-based green bin/solid waste program’s benefits and approaches, MOECC must not ignore the increasing challenges this poses for already mandated and increasingly intensified multi-residential developments within the municipalities, or the underutilized conveyance, collection and recovery infrastructure we have for carbon in the wastewater system.
As others will address more technically, significant benefits are possible by allowing for the disposal and capture of carbon in food scraps in the wastewater collection and treatment system. Our associations know better than any others that food scraps are primarily water-based, can be quickly and conveniently converted into a liquid slurry for easy transport through existing below-ground conveyance systems. One of the best tools to begin that process is the well understood in-sink food waste disposer, initially invented nearly 80 years ago with performance standards developed by plumbing associations in the 1960’s, and now nearly a standard appliance in many areas of North America. Further, this technological concept has essentially been incorporated into the modern dishwasher.
Green bin programs have proven to be a very difficult challenge in high rise, intensive developments, documented both in their collection rates and access. When we build intensive, dense developments, wastewater conveyance concerns are resolved in the design stage with the design of under the ground critical infrastructure managed early in the design phases. In many other regions, that infrastructure operates effectively with very high rates of household installations (e.g., 80% in California).
With the preponderance of underutilized AD infrastructure already installed at our wastewater treatment plants, one of the best ways to optimize these systems is with the input of extra carbon (as found in food scraps) to maximize the energy source. Carbon recovery being a key objective of the framework will have some enhanced benefits via this strategy.
This will also assist greatly in the province’s and national drive toward making municipal infrastructure including Ontario’s water resource recovery facilities (WRRFs) closer to a NetZero footing by being able to produce and use their own biogas. This resource recovery strategy is a truly win-win-win option as it manages the carbon already in the system, prevents the off-gassing of critical methane and other greenhouse gas emissions from municipal infrastructure, and captures that resource to turn to energy, decreasing the strains of the energy grid.
In closing, unnecessary restrictions based on historical myths instead of current evidence-based decision-making of certain products or systems could, would or may affect future decisions on NetZero considerations, carbon/energy recovery plans, or climate change adaptation strategies. International trends support the integration of in-sink food waste disposers as an essential tool for municipalities of all sizes, and provide a plethora of successful models for the Province.
We wish to engage with the Ministry to explain further our thoughts and work, address the context of Canada’s drive toward NetZero, and present both of our organizations’ roles in the perspective, process and plans for final adoption of the Framework and its successful implementation.
With respects,
Kevin Wong.
What is CIPH?
The Canadian Institute of Plumbing & Heating (CIPH) is a not-for-profit trade association. Founded in Montreal in 1933, the Institute is a vibrant organization committed to providing members with the tools for success in today's competitive environment. More than 260 companies are members of this influential Canadian industry association. They are the manufacturers, wholesaler distributors, master distributors, manufacturers' agents and allied companies who manufacture and distribute plumbing, hydronic heating, industrial, waterworks and other mechanical products. CIPH wholesalers operate more than 700 warehouses and showrooms across Canada. Total industry sales exceed $6 billion annually.
What is CWQA?
Founded in 1956, the Canadian Water Quality Association (CWQA) is the voice of Canada's residential, commercial, industrial and institutional water treatment industry. Our industry is a vital and growing part of Canada’s economy in communities across the country. Our industry directly and indirectly supports more than 10,000 jobs, paying more than $500 Million in wages. We generate $3 billion in annual economic activity, and provide over $720 Million in federal and provincial revenues each year. CWQA directly represents more than 200 small and medium-sized businesses across Canada and we train, certify and advocate for over a 1000 companies in Canada. CWQA members include small business dealers/retailers, wholesale distributors and manufacturers of water treatment components and systems, constituting a sector where Canada is recognized as a global leader and a critical innovator.

[Original Comment ID: 211899]