EBR Registry Number: 013…

EBR Registry Number: 013-1814: Food and Organic Waste Framework
York Region Environmental Alliance (YREA) is a not-for-profit, registered charitable organization (#84559 0553 RR0001). Incorporated in 2002 to initially campaign against the cosmetic use of pesticides, YREA has continually expanded its mandate to address ecological issues that impact our health, the health of our environment and the planet. We have a strong record of working cooperatively to influence public policy and community behaviour through initiatives and campaigns.
Presently YREA seeks funding to establish a non-profit social enterprise venture based on the production and sale of biochar. We will also explore how biochar can be integrated into carbon credit/cap and trade scenarios for municipalities and farmers and begin local research on the potential of biochar additive in animal feed and litter.
We commend the Province of Ontario for undertaking this Food and Organic Waste framework.
Our comments and suggestions are based on our areas of focus and concern.
FOOD WASTE
Although this is not our area of expertise, the 'best before' date, to our minds, has generated more food waste since its inception and we question why this even needs to be applied to canned goods that have been known to be safe after decades if their seals haven't been broken.
FOOD PACKAGING
YREA has been concerned about excess/unnecessary food packaging since 2008 when we wrote to major grocers regarding this issue. Although there have been improvements such as compostable, recyclable takeout containers at prepared food counters and less fresh produce wrapping, there is still a great deal of unnecessary plastic and polystyrene in the food system. Some conscientious producers are switching to cellophane (which is compostable) and polypropylene bags (coded 5 which use 65% less plastic then a clamshell) yet these items would be placed in the paper stream by an automated sorting system and contaminate it. We suggest:
•Manual sorting rather than automated, so that less recyclables are contaminated and more green jobs are created.
•Mandate that rolls of produce bags be made of compostable material so they could then be used in kitchen green bins. This one measure alone would eliminate untold amounts of plastic.
•Explore the potential of expanding cellophane packaging which is plant, not petroleum based and composts in home and municipal systems within 10 days.
We agree that education is key. The public might not be aware how to differentiate plastic from cellophane. Easy enough to do the rip test. Cellophane tears, plastic doesn't. Cellophane lined paper coffee bags are compostable once the metal closure is removed as are some paper bread bags with cellophane windows.

FOOD COURT/FAST FOOD WASTE
When Cadillac Fairview was retrofitting the Eaton Centre, YREA strenuously and repeatedly advocated with their Sustainability Coordinator of the time that the food court change to reusable dishes instead of Styrofoam and gave successful examples from other parts of the world. This did come to pass and we are pleased to see this action expanding to other shopping malls. However, many fast food outlets greenwash by having separate bins for waste, paper, cans/bottles but have been observed dumping all their waste in one garbage bin. This needs to stop and we suggest:
•the Province mandate that all fast food outlets stream their waste properly.
•the Province mandate reusable dishes in all retrofit and new food courts in shopping malls.
As a member of Ontario Zero Waste Coalition, YREA has been strongly opposed to incineration with all its associated health and environmental hazards as a way of dealing with waste.
BENEFICIAL USES OF RECOVERED RESOURCES - BIOCHAR
Although biochar, produced via pyrolysis is considered to be carbon neutral and carbon negative when sequestered in soil, the small scale, low tech units, said to emit the equivalent pollution of a wood burning stove are not in the same class and might well give biochar a bad name. Also of concern should be the proliferation of these unsophisticated units and their collective impact on the environment. It is important to clearly differentiate the various biochar production systems.
We are heartened to see provincial endorsement of the production of biochar through pyrolysis, and YREA's biochar plans would entail the use of forestry waste. Municipal directives would be useful so that instead of decomposing and releasing carbon, a good proportion of this waste would intentionally be diverted to the creation of this end-product. Since 2013 YREA has been researching its uses. As one example, it can be an important additive to compost with its ability to:
•Accelerate the composting process by increasing temperature
•Reduce GHG emissions
•Reduce ammonia loss
•Serve as a bulking agent for compost
•Reduce odour
The problem of compost odour would be reduced and the amount of waste received could be increase with the use of biochar compost additive.
We look forward to the facilitation of approvals; registration of biochar product and technology emission certification instead of the years it took in the early days of development of this industry.

[Original Comment ID: 211967]