PRESERVATION OF AGRICULTURAL LANDS SOCIETY
Comments Regarding the Waste Diversion Act
Dr. John Bacher, (PhD), Researcher, Preservation of Agricultural Lands Society (PALS)
March 30th, 2009
1. PALS Welcomes Review of Waste Diversion Act and is Pleased With Thrust of Policy Document
PALS is pleased to respond to the Ontario Ministry of the Environment (MOE) discussion paper regarding the Waste Diversion Act. We are particularly supportive of the documents emphasis on full Extended Producer Responsibility, an increased focus on waste diversion, and expanding diversion programs to include the Industrial, Commercial, and Institutional (ICI) sector.
2. PALS Has Long Experience With Waste Issues
At the outset, we would like to stress that PALS has been involved in waste issues for many years. From long experience, we are deeply concerned about both conventional sanitary landfills which bury organics below ground and cause leachate pollution, and incineration which dumps heavy metals including mercury into our air and water and onto our farmlands. The thrust of the Waste Diversion Paper is to get at the root of these problems, through a dramatic reduction in waste.
PALS' agree strongly with the discussion paper's observation that "waste cost us all, through higher prices for raw material, money spent on diversion and disposal, the environmental impact of disposing of waste, the health costs associated with hazardous materials, and the value lost when products are left to waste in disposal areas." One disturbing consequence of any continuance of incinerations is that mercury from incineration is one of the only pollutants in the Niagara River, which is the principal source of Lake Ontario's waters, that is still increasing. Province -wide, garbage dumps continue to be a vanguard of industrial urban sprawl into the countryside, unchecked by normal planning controls, and a continuing source of pollution to our precious ground waters.
3. Omission of Clear Bags
While PALS is pleased with the proposed new actions outlined in the document, we are concerned about one peculiar omission. This is the failure to have any discussion of the need for clear bags for the disposal of residual garbage, before the zero waste society is actually realized. As has been demonstrated in the Province of Prince Edward Island, where clear bags are actually mandated by provincial law for municipal collection systems, having clear bags for residual waste is the most effective way to ensure that laws concerning separation of organics and recyclables are actually respected. As a
2
result, residual garbage should be required by provincial legislation to be packaged in clear bags, in both municipal collection, the ICI sector and the new stewardship models which are being suggested in the waste discussion paper.
PALS Embraces Call For Extended Producer Responsibility
PALS strongly embraces the discussion paper's call for the approach of Extended Producer Responsibility to achieve zero waste. Through this approach producers will assume full financial and/ or physical responsibility for their products and packaging tin the waste stream. Those who produce and use products will bear the costs of recycling and proper disposal. Fees related to environmental management costs will be incorporated into the product costs rather than added to the retail price as a visible fee. With the negative impact on the market for recyclable products caused by the current economic difficulties, this approach is even more urgently needed than when the discussion paper was released.
EPR requirements should ensure that products and packaging be designed to reduce environmental impacts and that such costs are included in the product price. This is the best way to create a closed loop system that prevents pollution and waste.
It is important that producers design products and packaging for ease of recycling and the elimination of toxic components. They should take full responsibility for collection, recycling and the proper disposal of products at the end of their useful life.
PALS is pleased with the detailed way that the discussion paper has identified existing Extended Producer Responsibility models in Japan and Germany. We note that one of the consequences has been, that at 88%, Japan now has the world's highest rate of recycling for steel cans. Germany has achieved a similarly spectacular success in recycling 80% of its packaging. Both countries take the approach, which is properly recommended in the discussion paper. This includes requiring retailers to provide take- back services for products, incorporation of deposit return systems for certain products/and or packaging, and the provision of better consumer based education on the costs and impact associated with the products and packaging they purchase.
4. PALS Supports Proposals for IC&I Sector.
The discussion paper's revelation that the IC& I sector's role in generating 66% of Ontario's non-hazardous waste, while diverting only 12 %, shows the urgent need for the expansion of diversion programs here. Part of the solution is the having Extended Producer Responsibility for the manufacturers of the products that constitute this waste stream. There also needs to be provincial disposal bans at all private and public disposal facilities for designated materials such as Blue Box materials and electronics, which are now generated by both the residential and IC &I sectors. Where IC &I wastes
3
are disposed outside of the province, waste transporters and transfer stations should provide consistent reporting.
5. PALS Supports Provisions for Increased Recycled Content
PALS supports the various policies proposed in the discussion paper to create a demand for products which would contribute to stronger and more stable market demand, and eventually higher revenues for diversion programs
We also support proposals to abolish the inclusion of manufacturing scrap as recycled content, levying additional feeds on poorer performing materials and providing a graduated recycled content credit for Blue Box stewards to reflect the percentage of residential and IC&I post consumer content used in product manufacture and packaging.
6. PALS Hopes that Extended Producer Responsibility Will Start Soon.
PALS hopes that the province will quickly embark on a path to zero waste. Such a move will both strengthen our economy at a difficult time and provide a sane course towards environmental sustainability.