January 15, 2018…

January 15, 2018
Ian Drew
Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Resource Recovery and Policy Branch
40 St. Clair Avenue West, Floor 8
Toronto, Ontario
M4V 1M2
Dear Mr. Drew:
Re:City of Guelph Response to EBR Number 013-1814 – Policy Proposal Notice: Food and Organic Waste Framework
The following comments are in response to the Minister’s invitation for further dialogue on Ontario’s Environmental Bill of Rights Registry No. 013-1814, Policy Proposal Notice: Food and Organic Waste Framework. We would like to take this opportunity to thank the Ministry for the invitation to participate in this important discussion and applaud the government’s continued efforts to drive resource recovery.
With diversion as its core strategy, the City has approximately 100 employees providing comprehensive waste management services to the citizens of the City of Guelph (the City). The City has invested in a state of the art waste collection fleet, material recovery facility, organic waste processing facility and provides public drop-off and household hazardous waste drop-off services as well as various reuse and diversion programs. These programs are planned, integrated and award winning, providing cost effective solutions to taxpayers of the City. Moving forward, municipal governments have a key role to play in waste reduction and resource recovery.
General Comments
Vision, Guiding Principles and Objectives
The City is pleased to see a strong focus on reducing food and organic waste at the source, which has the greatest positive impact on the environment, economy and society. Guided by the Ministry’s vision towards zero food and organic waste and zero greenhouse gas emissions from the waste sector, the Framework needs to establish realistic and achievable goals and actions.

The Ministry identified a number of guiding principles that were considered for the development of the Framework. The City recommends the Ministry consider the following elements missing from the Guiding Principles:
•“Enabling efficient and effective food recovery systems”. Insert the word “food” into this principle to delineate the ideas that recovery of food for reintegration is of higher priority than waste recovery.
•Principles of food waste “prevention and reduction” are missing from the list, although they are the backbone of the Framework. Consider adding “creating a culture of food waste prevention and reduction” to align with the Framework and be consistent with the Ontario Food Recovery Hierarchy.
The City is supportive of the objectives listed in the document:
1.Reduce food and organic waste
2.Recover resources from food and organic waste
3.Support resource recovery infrastructure
4.Promote beneficial uses of recovered resources
Part A: Proposed Food and Organic Waste Action Plan
The Action Plan identifies strategic actions to be undertaken by the Ministry to address food and organic waste. The City requests that the Ministry consider the following recommendations highlighted under the respective actions:
Action 2: Province to enhance and incorporate waste reduction and resource recovery activities within schools
The City supports waste reduction and resource recovery activities within schools; however, a significant amount of work will be required to provide uniform access to diversion programs in all school boards across the province. At present, waste reduction and diversion programs including access to green bin programs vary between schools depending on the individual school board and administration. The City recommends the Ministry develop standard guidelines for successful implementation of three-stream waste programs in Ontario schools. This may include development of training modules or guidance materials for independent contractors (e.g. waste management and cafeteria staff) to support successful implementation, as well as incorporating food waste information into the school curriculum to engage teachers and students.
Action 7: Province to develop data collection mechanisms for measuring progress in waste reduction and resource recovery of food and organic waste
The City is encouraged by the Ministry’s proposal to develop data collection mechanisms to
establish a baseline related to food and organic waste in Ontario. Data on the amount and composition of food and organic waste generated in Ontario is limited, particularly in the multi-residential and IC&I sectors. It is recommended that the Ministry consult with key stakeholders on data collection approaches and build on existing efforts to gather data needed to track resource recovery and waste reduction under the new policy framework. The City encourages the Ministry work collaboratively with cross sector departments including Public Health to establish health related metrics that correlate with food waste reduction; gathering data on behaviour change; food literacy; and, food security.
The City would like to know when the Ministry will be providing guidance on methods used to collect food waste data. In the MOECC webinar on the 1st December 2017, the Ministry were asked about how the 70% diversion targets would be measured and what baseline data would be used, the Ministry said they would be providing guidance once the framework has been agreed. How quickly will this guidance be provided? The City would also be interested to learn what the penalties might be if you fail to meet the targets laid out in the proposed framework.
Action 9: Province to ban food and organic waste from ending up in disposal sites

The City would like to know when the consultation for implementing a ban will begin. It is our hope that the consultation process will be thorough and engage with a variety of stakeholders from a broad range of sectors before the Ministry makes any decisions in this area.

Action 10: Province to support resource recovery of food and organic waste in multi-unit residential buildings
How will the Ministry provide support to buildings that have already been built? Will there be any funds available to municipalities or private owners to be able to retrofit buildings to make the collection of organics and food waste more accessible? There should be mention of this in the Framework.
Action 12: Province to use modern regulator approaches to review existing approval processes and requirements for resource recovery systems
The City commends this objective and hopes that the Ministry can deliver on this commitment to streamline the approvals process for new facilities. This will benefit resource recovery infrastructure greatly.

Action 13: Province to require standardized training for owners and operators of resource recovery systems that undertake composting and anaerobic digestion
The City would like to understand who will be undertaking the design, development and delivery for this standardized training. How many third parties will be licenced to conduct the training and what will be the training costs? The City is supportive of training programs as it will raise the level of understanding within the industry, provide a level playing field, and provide a greater knowledge base for those that work within the sector.
Part B – Policy Statement
The Policy Statement is established under the Resource Recovery and Circular Economy Act, 2016 and provides direction to the province, municipalities, the IC&I sector, owners and operators of resource recovery systems and others, to further the provincial interest in waste reduction and resource recovery as it relates to food and organic waste.
1.Ontario Food Recovery Hierarchy
The City supports an integrated approach to food and organic waste management with the use of a hierarchy to prioritize actions towards a sustainable model of waste reduction and resource recovery. It is important to note that most food recovery hierarchies include an additional layer to “Feed Animals” between Feeding People and Resource Recovery. We would suggest that the Province consider adding this level, as it is included in other food waste hierarchies such as the one used in the United Kingdom and U.S Environmental Protection Agency (EPA) . It may be helpful for the Ministry to add a visual diagram with hierarchies (inverted pyramid) to the Framework document.
2.Targets
The City supports the Ministry setting separate targets for single family, multi-residential and IC&I sectors as current diversion performance varies widely between these sectors. However, the diversion targets and timelines to meet the prescribed targets need careful consideration. Details on organics diversion performance are limited, making it difficult to set accurate targets. Targets are ambitious and it is challenging for stakeholders to comment on the feasibility of meeting these targets without a baseline or clear understanding of how the Ministry intends for targets to be calculated. Each sector (municipalities, IC&I, multi-residential) is unique, and thus the ability to meet targets will vary by sector. The City recommends the Ministry establish sector specific working groups (municipalities, IC&I, multi-residential) to provide guidance on targets, key metrics/data collection standards, and baseline year/calculations.
3.Reduce Food Waste
As outlined throughout this response, the City supports the Ministry’s actions to prevent food waste in the first place. Preventing and reducing food waste requires a significant shift in mindset and behavior change. The root cause of food waste in the residential sector is insufficient food literacy. The Ministry should connect with partners such as the Ontario Food Collaborative, Food Policy Councils, local health boards, and others, to work on developing and delivering tools for engaging the residential sector.

4.Recover Resources from Food and Organic Waste
The City already has a curbside green cart program. The City is currently looking at how we can increase our participation and performance further from the multi-residential units we provide waste collection services within the City.
5.Compostable Products and Packaging
The City welcomes that this framework tries to address the area of compostable products. The City would like to see some language in this section that would focus the producers to look at disposal methods when designing their products. This would mean that when the products arrive at a composting facility they will break down in the time frames required to compost in the facility in question. Some work has been done by the Municipal Waste Association, Organics Committee, to provide a testing protocol and procedure for compostable products. The City encourages the Ministry to contact this organisation, look at some of the work that has been done and understand some of the challenges faced by municipal composting facilities related to compostable products.
Are the producers of compostable products expected to pay stewardship fees or help pay for the infrastructure they are using or that require to be modified to accept their products? The City feels that if compostable products are allowed to enter the various green cart programs and the facilities are unable to handle them, then the cost of modifications should be paid for the by the producers of the compostable products. Alternatively, if these products are not compostable, then the producers should pay for the cost to dispose of in landfill.
5.1The City doesn’t agree with this item. The City feels there needs to be a new Ontario standard for products that would be compatible in organic waste processing facilities to process, similar to a testing standard agreed by the MWA organics committee.
5.2The City believes that municipalities, owners and operators will support new technologies if it is not detrimental to their own operating facilities. There is also a need to comply with the Ontario Compost Quality Standards for finished compost.
5.3The City is in agreement with this statement and would welcome any resources that help consumers make the correct decisions with respect to compostable products.
6.Support Resource Recovery Infrastructure
The City has no comments on this section.
7.Promote Beneficial Uses
The City has no comments on this section.
8.Implementation and Interpretation – Measuring Success
Conduct first review within five years of implementation
The City recommends the Ministry conduct its first review of the Policy Statement within five years of implementation. The proposed review timeline of ten years seems too long and does not align with timelines for proposed targets. A shorter timeline of five years would enable the Ministry to monitor progress and make adjustments to meet its overall objectives and goals.
The Ministry is encouraged to align its review timelines with other corresponding evaluations in Ontario (e.g., Ontario Education Curriculum review) to allow timely implementation of the actions under the Framework.
Establish robust key performance indicators within specified timeframe
The success of the Framework will depend on how well the Ministry can track performance measures with the ability to measure and monitor key performance indicators. The City recommends the Ministry establish robust performance measures, accompanied with practical and achievable key performance indicators (KPIs) within a specified timeframe to measure success towards a circular economy. This piece is lacking clarity and structure in the draft Framework.
CONCLUSION
The City asks that these comments and recommendations be taken into consideration in finalizing the proposed Food and Organic Waste Framework.
The City of Guelph thanks the Ministry for engaging municipalities on this important topic and look forward to continued municipal involvement in waste management in Ontario.
Sincerely,
Cam Walsh
Division Manager
Solid Waste Resources
The City of Guelph
T 519-767-0598 x 2053
F 519-767-1660
E cameron.walsh@guelph.ca
Catherine McCausland
Manager, Operations
Solid Waste Resources
The City of Guelph
T 519-767-0598 x 2054
E catherine.mccausland@guelph.ca

David Gordon
Contract Supervisor, Organics Waste Processing Facility
Solid Waste Resources
The City of Guelph
T 519-767-0598 x 2104
E david.gordon@guelph.ca

cc: Scott Stewart, Deputy CAO
Infrastructure, Development and Enterprise
City of Guelph
Peter Busatto, General Manager
Environmental Services
City of Guelph
Barbara Swartzentruber, Executive Director
Intergovernmental Relations, Policy and Open Government
City of Guelph

Chris Ballard
The Honourable Minister
Environment and Climate Change

[Original Comment ID: 211999]