Spending wisely on waste?
In 2004, Ontario committed to divert 60% of waste from landfill by 2008. I can’t find any evidence that we achieved this target; now we may be going backwards.
Attempts to divert organics from landfill, for example, have been plagued with odour problems. Many municipal and private composters have been prosecuted, and in some cases shut down, for odour discharges. Now, Ontario’s proposed new rules for composting and compost use will make organic diversion even more difficult and expensive. Which suggests that more wastes will end up in landfills.Lots of new requirements will increase costs. For example, most composting will have to take place indoors, in buildings expensively outfitted with positive air controls and odour removing technologies. Any rainwater that touches compost will be deemed to be landfill “leachate”, which must be collected, treated, and tested before discharge. Existing exemptions for retail sales of compost will be eliminated. Tolerance for foreign matter and trace elements in the compost will be even more limited than before, even though contamination of organic feedstocks is high.
This is an illustration of a larger problem. Ontario brags proudly about its municipal collection methods and how much waste they are diverting from landfill. But all they measure is how much goes into the blue, gray and green boxes. Unfortunately, the resulting waste streams can be so contaminated that they overwhelm the sorting capabilities of municipal processing sites. In turn, these sites ship contaminated feedstocks to recycling plants or composters, which must then landfill part of what they receive. It is yet another powerful example that measuring the wrong thing can produce counterproductive results.
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The MOE has responded to this post, as follows:
The compost industry has been plagued with odour problems, and many facilities have been ordered to shut down.
Response: The proposed Guideline provides best management practices and guidance that is intended to improve operations, including guidance developed with the specific intent to help address and minimize the risk of odour emissions at composting facilities. Improved best practices should help reduce number of facilities that are issued orders to scale back or shut down.
Ontario’s compost proposal will impose lots of new requirements, which will make composting even more difficult and even more expensive, which in turn, will result in more waste ending up in landfills.
Response: On the contrary, municipalities, the Composting Council of Canada and its members have all been calling on the ministry to develop a new compost framework that includes new standards, rules and better guidance for compost facilities similar to those included in the proposal. The compost industry has stated that Ontario’s current standards are a barrier to composting, and that revised standards would improve market opportunities. To date, all feedback from municipal stakeholders, private sector facility owners and operators and associations, such as the Composting Council of Canada, has been overwhelming supportive of the ministry’s proposal.
In addition, the best practices set out in the proposed guideline should already be incorporated in most successful compost facilities’ operations, and therefore should not impose additional costs on any successfully operating facility. The recommended practices should help new facilities develop appropriate structures, equipment, processes, etc., early on in the planning stage to avoid future problems. Indeed, we have been told that facilities without adequate structures, equipment, processes, etc., often have to include them later on at a greater cost in order to address operational problems.
Tolerance for trace elements in compost will be even more limited than before.
Response: This is incorrect. The limits for trace elements (i.e., heavy metals) for Category AA will remain the same as Ontario’s current compost standards. The metal limits for Category A and B will be less restrictive, but some restrictions on their application will apply. In addition, the allowable metal limits in the feedstock for all three compost categories will be less restrictive given the focus on product output.
Tolerance for foreign matter in compost will be even more limited than before.
Response: This is correct. The ministry is proposing to tighten the limits on foreign matter. Some feedback from members of the compost industry has suggested that facilities should be able to meet more restrictive foreign matter standards than currently exist; however, the limits included in the proposal may in fact be too restrictive. The ministry is keen to receive full feedback from stakeholders on the feasibility of the proposed foreign matter limits.
Existing exemptions for retail sales of compost will be eliminated.
Response: This is correct. The ministry is proposing to exclude compost from the general retail exemption in Regulation 347. If the ministry does not eliminate this exemption for compost, any composted material that is sold would avoid the ministry’s proposed new requirements (i.e., labelling requirements for Category A compost, and application restrictions and approval requirements for Category B and “failed” compost), which have been developed to ensure that compost is used in a manner that is protective of the environment and human health. Under the proposal, however. compost that meets the Category AA or A criteria can continue to be sold for retail without any approvals.
Ontario is using the wrong methods for measuring waste diversion (i.e., “how much goes into the blue, gray and green boxes”, rather than the amount actually diverted).
Response: The municipal diversion rate is not calculated based on “how much goes into the blue, gray and green boxes”.
Waste Diversion Ontario calculates the municipal diversion rate using the Generally Accepted Principles (GAP) methodology for measuring municipal residential waste flow. The GAP methodology is based on waste tonnages marketed for recycling by municipalities after these materials have been processed and separated, with the residuals removed. The WDO diversion rate also includes other residential material that is recycled, such as leaf and yard waste, waste electronics and household hazardous waste.
The GAP methodology was established under the auspices of a team that included provincial governments, municipalities, and industries across Canada, to come up with standardized principles and practices to measuring waste flow, in order to be able to compare the progress of municipalities in waste diversion.
Thanks, MOE, for your comment. Clear compost rules are certainly important – the question is, whether the proposed rules are the right ones, and how the expense of the new requirements will affect the MOE's stated objectives, such as encouraging diversion.
As to the method of calculating diversion, the MOE's method ignores the huge amounts that must be sent to landfill by those who receive the increasingly contaminated streams of "recyclables". Paper contamination, for example, has gone from 2% to 15% in one Ontario company's experience. The Container Recycling Institute published a paper on this problem just this month: see http://www.container-recycling.org/assets/pdfs/re...