Submitted April 20, 2019
On March 6, 2019 the Ministry of Environment, Conservation, and Park (MOECP) released Reducing Litter and Waste in Our Communities: Discussion Paper, which expands upon commitments in Preserving and Protecting our Environment for Future Generations: A Made-in-Ontario Environment Plan. The paper poses questions that will help guide future decision-making to divert more waste from landfill.
The discussion paper sets out goals, actions and performance measures and outlines how the province will:
- decrease the amount of waste going to landfill
- increase the province’s overall diversion rate.
The discussion paper provides more details on the actions and commitments related to waste that were outlined in the Made-in-Ontario Environment Plan. The feedback on the discussion paper will help the province to move forward with a clear, comprehensive and outcome-based approach to reducing litter and waste in our communities while keeping this province clean and beautiful for future generations.
The discussion paper outlines eight key areas for action:
- prevent and reduce litter in our neighbourhoods and parks
- increase opportunities for Ontarians to reduce and divert waste at home, at work and on the go
- make producers responsible for the waste generated from their products and packaging
- reduce and divert food and organic waste from households and businesses
- reduce plastic waste going into landfills and waterways
- provide clear rules for compostable products and packaging
- recover the value of resources in waste
- support competitive and sustainable end-markets for Ontario’s waste
MOECP invited comment on the discussion paper, which were due on April 20, 2019. Our comments are prioritized by their ability to produce the most impact to drive waste reduction outcomes. RCO offers each recommendation in the spirit of maximizing results.
Disposal Levies Absent
Disposal levies are a broad public policy approach that has the capacity to address priorities of this discussion paper virtually simultaneously:
- improve waste reduction in the institutional, commercial, and industrial (IC&I) sector;
- reduce and divert food and organic waste;
- reduce plastic waste; and
- support competitive and sustainable end-markets.
Disposal Bans Beyond Organics Absent
RCO recommends the following products/materials be immediately considered:
- mercury-containing products with a focus on lamps;
- fibre-based materials such as boxboard, cardboard, and paper; and
Targets, Monitoring, and Reporting Strategies Absent
Any future waste reduction initiative implemented by the Government of Ontario must contain targets, reporting responsibilities, and mechanisms to track progress and impact.
Commitment to examine and improve its own procurement policies and practices is a direct and impactful method to prevent waste. Through its buying influences the Government of Ontario could expand producer responsibility by requiring vendor take-back services, reduce waste by changing product specifications, and expand recycling activities by forging unique private and public partnerships.
Food and Food Waste Lost to Disposal
RCO encourages government to prioritize action on organic waste by developing an implementation strategy with multiple short-term actions:
- Develop a province-wide disposal ban with short-term implementation timeframes.
- Government procurement requirements with all food-related vendors and service providers, as well as those that received funding, to reduce food waste.
- Focus on the IC&I sector; enforce reporting and source separation requirements from Regulations 102, 103, and 104; and proceed with a full review of these regulations to modernize and make them more effective.
Prioritize Waste Reduction in the IC&I Sector
The discussion paper acknowledges the stagnant waste diversion rate in the IC&I sector where more than 60 per cent of material generated is lost to disposal. Unlike the residential sector, services are privately provided location by location rather than door to door in tight geographic clusters, which negates opportunity to establish economies of scale, service efficiencies that aim to reduce cost, and improve tracking and reporting. This is exacerbated by a lack of tools and resources to identify and share best practices. Existing regulations aimed at the IC&I sector are ineffective and require a full review and revamp.
Expand Extended Producer Responsibility (EPR)
Producers have the most influence on the design and delivery of their products and services, and should be accountable for the environmental impacts of their goods past the point of purchase and use. RCO encourages the MOECP to prioritize and continue the transition of existing producer programs to the Resource Recovery and Circular Economy Act (RRCEA), including waste electrical and electronics, municipal special and hazardous wastes, and printed paper and packaging (PPP).
This transition is critical as it allows for numerous benefits:
- Greater and direct alignment between individual producer accountability with responsibility while allowing producers flexibility to manage their obligations.
- Shifts costs away from municipalities and their taxpayers.
- Provides opportunity to expand the list of targeted products and materials for each transitioning program, in particular, opportunity to expand the scope of obligations to include the IC&I sector.
- Designates new products and materials that are toxic and/or prevalent in the waste stream.
- Meaningful targets and consequences for non-compliance.
Blue Box Transitions
The MOECP has an important and unique opportunity to transition the Blue Box Program for PPP to full producer responsibility and should consider this transition directly through new designation under the RRCEA. This will provide opportunity for municipalities and producers to support a timely Blue Box transition and prepare operations and businesses for new roles and responsibilities under a full producer responsibility model.
Expanding Producer Responsibility for PPP in the IC&I Sector
By modifying regulation to include the IC&I sector the province could harmonize a list beyond residential sources and make common what Ontarians can recycle at work and at home. Expanded service also provides economies of scale and incent private sector materials managers to invest in collection and processing infrastructure within the province of Ontario because of the increase in supply. Ancillary benefits include expanding local economies and creating significant job opportunities.
Reducing Plastic Waste Going into Landfills or Waterways
Plastics are ubiquitous and utilized in almost all aspects of daily life. In that regard, it is important to note that plastic waste goes well beyond packaging and mitigation must consider commercial and industrial use. RCO considers the following necessary to make impactful improvements to plastic waste.
- Focus on the source
- Create sustained markets that demand post-consumer plastics
- Integrate circularity into government procurement
- Grow domestic recycling solutions
- Develop standards in co-operation with other provincial and federal governments
- Require resin specific targets for the PPP under the RRCEA
Thermal treatment of waste, while providing opportunity to extract embedded energy from materials, is a short-term and limited use of the inherent value of materials. If not narrowly used, highly regulated and monitored properly, thermal management could displace more valuable reuse and recycling applications. Consequently, it may demotivate the marketplace to innovate and invest in preferred post-consumer applications, and eliminate incentive to improve materials/product designs that integrate environmentally superior options at end of life.
Therefore, it is crucial to ensure that thermal treatment is considered disposal and does not count toward diversion targets made under regulation or claims made in voluntary reporting.
RCO recommends the MOECP undertakes the following activities prior to considering thermal technologies as a waste management strategy:
- Global scan of jurisdictions that permit thermal treatments of waste and examine impacts and costs with particular focus on waste diversion performance.
- Publicly list, for comment, materials that the MOECP considers safe and economically viable for thermal treatment with clear rationale for each.
- Conduct a full economic and environmental impact analysis:
- Full costing of infrastructure and operational, short- and long-term, for thermal treatment of materials.
- Potential short- and long-term effects on the recycling industry.
Prevent and Reduce Litter in Neighbourhoods and Parks
A province-wide co-ordinated day of action on litter could provide an important opportunity engage Ontarians broadly on the consequences of waste lost to disposal or litter, and its value if redirected into recycling applications. It is also an opportunity to rally support from all stakeholders, including municipalities, businesses, schools, environmental groups, and the general public to collectively work toward a common goal, particularly in our parks, and recreational and conservation areas.