RE: Proposed Food and…

RE: Proposed Food and Organic Waste Framework – EBR Registry Number: 013-1814
Please accept the following comments regarding EBR Registry 013-1814 on the Ministry’s Food and Organic Waste Framework on behalf of Administration at the City of Windsor. We appreciate the opportunity to provide input in the government’s efforts to drive resource recovery in Ontario.
We are aware of comments submitted on behalf of the Association of Municipalities of Ontario (AMO), the City of Toronto, the Regional Public Works Commissioners of Ontario (RPWCO) and the Municipal Waste Association (MWA). We are in full support, and echo wholeheartedly, their comments.
There are a few key points which we feel deserve re-iteration, as they are key concerns for our municipality.
Timeline
As mentioned in the submission by AMO, RPWCO, WMA and the City of Toronto, communities, such as Windsor, that will be required to design and implement a collection, transportation and processing system, will be hard pressed to do so and meet the prescribed targets in the 7-year timeline proposed. We would like to see consideration given to municipalities who are making clear progress toward compliance, but may not be able to meet targets within the timeline because of unique circumstances.
Promotion and Education
Promotion and education on food reduction should not only be a joint responsibility across the supply chain, but should be universal across the province. In this way, the same message reaches everyone in the province. Regardless of where you live, visit or move to, the same message applies.
Enforcement
Municipalities, in general, are readily compliant with government policies. There is concern however, with compliance and enforcement in the IC&I sector. While we are supportive of the municipal responsibilities and the IC&I sector responsibilities, we are unclear how enforcement will be managed.
Funding
Designing and implementing a collection, transportation and processing system requires a funding source. There have been some suggestions that allocating potential savings from Blue Box transition to full EPR could be used to fund these programs. However, there is no indication that those funds would be sufficient – particularly for the construction of a processing facility (if required). Secondly, there appears to be no coordination between the transition to EPR and the implementation of the organics program. It fact, it appears that the transition to EPR could be as late as the timeline set for organic diversion targets; which means that those funds will not be available to even begin implementation or organic diversion. For the Windsor area, it is very likely that a new processing facility will be required. Funding for capital costs as well as operating costs is of significant concern to our region. It is unclear, at this time, where that funding will come from.
Thank you for the opportunity to provide feedback, and please contact the undersigned if you have any additional questions.
Sincerely,
Anne-Marie Albidone
Manager, Environmental Services
aalbidone@citywindsor.ca
(519)974-2277 ext. 3123

[Original Comment ID: 212005]