Re: ERO # 019-4867 The…

Re: ERO # 019-4867
The proposal by the Ministry of Environment, Conservation & Parks (MECP) to support “energy recovery technologies” does nothing to promote waste reduction and only delays truly sustainable solutions to waste.
Energy recovery or Energy from Waste (EFW) technologies have been strongly contested for decades. It cannot be denied that toxic pollutants that escape into the air from these facilities are a serious health concern and a negative impact on land and water.
Protecting resources, particularly natural resources that sustain life - the air, land and water, must be a priority to the MECP. Therefore, no proposal for EFW technology would be fitting for Ontario, since the goal is to protect resources.
It makes no sense to use energy to mine, ship, and manufacture a product that is used once, only to be thrown away.
Destroying “valuable resources” to produce energy is illogical. More energy is saved by not making poorly manufactured products in the first place.
This EA focuses diverting “valuable resources” from landfill. However, at least landfilled materials can be mined in the future. EFW destroys resources forever!
Ontario's focus needs to be diverting valuable resources from "disposal", and holding producers responsible to do so.
EFW technologies ARE NOT “advanced recycling facilities”. EFW disposes of waste into the air.
An example of an “advanced recycling facilities” would be a collection and reprocessing facility for disposable diapers. We know that disposable diapers are a serious waste problem. While chemicals used in diapers seems to be proprietary information, problems with disposing of diapers is not.
The disposable diaper industry has had decades to implement sustainable solutions to diapers and “advanced recycling facilities”. Instead, this industry continues to make huge profits, while taxpayers subsidize its waste.
Over the years, municipal leaders have set up programs to divert materials from disposal to get “valuable resources” back to producers - who made promises to reuse or recycle those materials.
Sadly, most producers failed on this commitment and a large portion of materials, collected for reprocessing, are still disposed of, and taxpayers continue to pay for disposal and diversion.
Recently, a class of Grade 7 students examined Halloween waste and found that most of the packaging could not be recycled or composted. They then wrote to the producers to encourage more sustainable packaging.
It is commendable that municipalities, students and the public are taking action to divert resources, call out waste culprits, encourage sustainable products, or to simply stop buying products that do not meet reduction goals.
Government leadership, however, is needed to demand safer, more sensible, sustainable products and packaging, and to enforce programs.
Ontario leaders promised to hold producers responsible for the life cycle of their products – inspiring the use of quality materials that can be easily diverted for reuse, and take-back programs to encourage repeat customers.
Some companies have already taken steps to reduce waste or redesign products, e.g., compostable toothbrushes, shampoo bars, laundry sheets, beverage containers with no plastic rings or pull tabs, etc.
In Ontario, alcohol beverage containers are one of the most successful container take-back programs, because of financial deposit-return incentives.
In 2020, one national grocery agreed to eliminate single-use plastic bags, “removing 225 million plastic grocery bags from circulation annually – enough plastic bags to wrap around the world twice.” Others are following suit.
Unfortunately, too many other companies lag behind in adopting solutions and some continue to make untrue and misleading statements that make it difficult for consumers to reduce waste.
For example, one company was recently required to pay millions for making false and misleading claims that their single-use coffee pods could be recycled, when they are not in most places.
Other companies claim their packaging is “100% recyclable”. Yet, like the coffee pods, there are few, if any, collection and/or recycling facilities, because our government has not required producers to support the programs.
There are so many examples of irresponsible packaging. Just take a close look at what’s in the garage, like the Grade 7 students did.

It is misleading and untrue for the Ontario government to suggest that EFW technology is an “advanced recycling facility”. It is not!
EFW does NOT protect resources.
EFW does NOT promote waste reduction.

Please don’t open the door to EFW. Ontario has come too far and worked too hard to develop programs to protect resources and reduce waste.

The Ontario government must make good on its promise to release taxpayers from the financial burden of managing products and packaging, and take swift action to hold producers responsible to:
- reduce waste at the front-end;
- make products/packaging that can be easily reused, recycled or composted; and
- pay all costs to divert and reuse their products/packaging.