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October 28, 2008

A proposal for Ontario's new EPR direction

The current buzz in the Canadian waste and recycling industry is all about Ontario Environment Minister John Gerretsen's discussion paper Toward a Zero Waste Future (see extended entry below that reproduces our news announcement) which proposes to move the province away from the current blue box recycling model (in which industry "stewards" pay 50 per cent of net municipal curbside recycling costs) toward Extended Producer Responsibility (EPR) -- the Holy Grail of environmentalists who feel that society has emphasized the wrong "R" (recycling) in the waste management hierarchy, the first two being Reuse and Reduction (and even "redesign" in some savvy circles).

If Gerretsen does anything like what's proposed in the discussion paper, he will earn himself a rightful place as one of the most important environment ministers in Ontario history, taking the lifetime work of his predecessor Jim Bradley to the next logical level. (Hint: When the industry lobbying gets fierce, as it no doubt will when producers learn they are to pay for all the costs of managing their wastes, Gerretsen might want to steel himself for battle by having a drink or two with Bradley and listen to some of his old war stories.)

Waste reduction expert Usman Valiante waste no time coming up with a practical scheme to turn the EPR vision hinted at in the minister's discussion paper into reality. In a presentation (that you can download below) at the recent Fall conference of the Association of Municipal Recycling Coordinators (AMRC, whose name has just been changed to the Municipal Waste Association [MWA]), Valiante painted a picture of a new system that builds on the blue box history in Ontario and envisions Stewardship Ontario (the blue box funding organization) becoming a sort of equivalent body to that which operates the Dualles EPR system in Germany.

I thought readers might enjoy seeing Valiante's Power Point presentation directly for themselves, and have uploaded an Acrobate PDF version for you to download here:

Download file

Please note that this topic will be the subject of my Cover Story in December/January edition of Solid Waste & Recycling magazine, where I will again summarize some of Valiante's ideas, in addition to quoting other experts.

And here's the news item:

Ontario shifts toward Zero Waste approach

The Ontario Ministry of Environment has released Toward a Zero Waste Future -- a discussion paper that moves Extended producer Responsibility (EPR)from being a conceptual idea to possibly a practical reality in the province.

It has concurrently issued a letter to Waste Diversion Ontario (WDO) requesting a review of the existing Blue Box Program Plan (BBPP).

The WDA review discussion paper has been issued as the first step in a statutorily mandated review of the WDA.

The WDA discussion paper identifies several important concepts associated with Extended Producer Responsibility (EPR) as an approach to Zero Waste.

Specifically, the paper discusses producer versus shared responsibility, the economic implications of individual producer responsibility versus collective producer action on waste diversion, the issue of stewardship costs manifesting themselves as "visible fees" applied over and above the price of products and the impact of stewardship program design on competition in waste service markets.

In this context the discussion paper then proposes the following:

1. A clear framework built upon the foundation of EPR. The paper identifies key elements of this framework:

-- The concept that, "…waste diversion programs should shift more financial responsibility onto producers", while allowing, "…producers to discharge responsibility for their products and packaging in the way that best suits their needs, has the fairest impact on existing markets and meets the public's demand for successful diversion activities that strive for zero waste and foster a green economy."

-- The concept of differentiating between producers' products based on the environmental profile of those products (including waste and non-waste factors such as energy efficiency, toxics reduction, greenhouse gas emissions profile etc.);

-- A prohibition on "visible fees";

-- Application of stewardship fees to materials to materials that are not currently recyclable;

-- A more flexible approach to allowing producers to discharge their existing or future stewardship obligations through individually crafted approaches such as pre-existing schemes, or individual producer-run programs.

2. A greater focus on the first and second of the 3Rs – waste reduction, and reuse.

3. Increasing reduction and diversion of waste from the industrial, commercial & institutional sectors. Alternatives proposed include revising existing 3Rs regulations, extending responsibility for IC&I wastes to producers or
designating IC&I wastes on a material-by-material basis.

4. Governance and administration of EPR programs -- i.e., greater clarity around roles, responsibilities, and accountabilities, to ensure that all players are contributing to a common goal.

"This discussion paper moves from EPR as a conceptual model to discussing the policy and practical issues that have to be addressed to make EPR a functional and meaningful approach," says Usman Valiante, a waste reduction expert and contributing editor to Solid Waste & Recycling magazine, adding, "As proposed, a policy régime that has individual producers bearing the full and fully differentiated costs of their products is profoundly different than what is commonplace in Canadian waste diversion programs today. The discussions precipitating from this paper are going to have relevance in the broader Canadian context and not just Ontario."

Some of the concepts enunciated in the discussion paper are reflected in the BBPP review letter as issued to WDO by Minister Gerretsen. Most notably, the letter states that,

"The BBPP does not reflect full Extended Producer Responsibility (EPR) funding since the WDA requires Blue Box stewards to fund 50% of municipal program costs, with municipalities funding the rest."

The Minister then requests WDO to, "Recommend how to move the BBPP towards full EPR funding. Since different collection and processing systems for Blue Box wastes are the result of decisions made by local municipalities, in your review and recommendation, please consider the potential impact to the management of municipal recycling programs as industry moves to full EPR funding.

The Ministry has posted Toward a Zero Waste Future on the Environmental Bill of Rights registry at:

http://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTA0NjEy&statusId=MTU2Njg2&language=en

The comment period ends on January 15, 2009.

Waste Diversion Ontario has been tasked to report back to the minister regarding the BBPP review by March 20, 2009.

The next December/January edition of Solid Waste & Recycling magazine will contain an in-depth analysis of the new discussion paper and its implications.

October 21, 2008

Paper and paperboard defends itself

I thought readers might enjoy reading this letter that PPEC Executive Director John Mullinder sent to the Toronto Star about incorrect statements from Toronto Councillor Glenn De Baeremaeker.

October 14, 2008

Toronto Star VIA EMAIL

RE: Toronto’s loose cannon misfires again

Dear Editor:

Toronto Councillor Glenn De Baeremaeker would have more credibility if he got his facts right before opening his mouth (Rethinking the idea of packaging, Toronto Star October 11, 2008).
To claim that paper grocery bags and telephone books are the result of “ripping down thousand-year-old trees in British Columbia to use once …and then throwing (them) in the garbage” is just plain ignorant and irresponsible.

Most paper grocery bags used in Canada come from US plantation forests that have been third-party certified as being sustainably managed. The minority that come from Canadian managed forests (again certified) are made from wood chips, shavings and sawdust that are left over after harvesting trees for lumber (to make hospitals, universities and Councillor De Baeremaeker’s house).

As for telephone books, most are made from 100% recycled paper materials (old newspapers and egg cartons).

And while he’s checking his facts, maybe Councillor De Baeremaeker could find time to investigate the latest Blue Box recovery rates for Ontario: 72% for paper overall and 88% for telephone books.

Yours sincerely,

PAPER & PAPERBOARD PACKAGING
ENVIRONMENTAL COUNCIL (PPEC)

John Mullinder
Executive Director

October 04, 2008

Gilbert and Winfield debate incineration

I thought readers would enjoy this exchange from Alternatives Journal, an excellent Canadian publication to which I encourage readers subscribe. In the article, Richard Gilbert and Mark Winfield offer arguments for and against waste incineration. I have heard these arguments before, but I found it useful to have all the pros and cons presented this way. It's kind of a nice summary to have on file as a reference, and to send to folks who are just getting up to speed on these matters. With incineration proposals and projects at various stages in Durham, Vancouver, Ottawa and eslewhere, this is worth reading.

"Reprinted from Alternatives Journal, 33:2/3 (2007). Annual subscriptions $35.00 (plus GST) Visit http://www.alternativesjournal.ca

The article is also on their website at:

http://www.alternativesjournal.ca/index.php?

Alternatives Journal 33:2/3 (2007)

Point-Counterpoint: To Incinerate or Not to Incinerate

Richard Gilbert and Mark Winfield debate the burning issue.

There are more than two sides to the story. Read this article and then add your thoughts to our blog.

Richard Gilbert opens: WASTE IS WHAT we have used and have no further use for. Incinerating waste, I believe, is a better environmental solution than landfilling.

Only a limited amount of waste occurs in nature. Animals produce waste in the form of faeces, which, in turn, provide nutrients for other parts of the ecosystem. In contrast, we humans appropriate and discard major material flows beyond what is required for our metabolism and beyond what our local ecosystems can handle. The first objective of a waste management system should be to reduce material flows and thus potential waste. This reduction, in turn, can lower the likelihood of risks to human health and environmental problems.When the cost of managing waste is high, which is often the case with incineration, it encourages a reduction in the flow of material.

The second objective should be material reuse, which includes recycling. Because it is more costly, incineration can facilitate recycling. It also results in reuse when ferrous materials are readily extracted from ash.

Data back up the compatibility of incineration and recycling. If you look at the wealth of information in “The State of Garbage in America,” an article published in the January 2004 issue of Biocycle, you can readily figure out that the median recycling rate in US states where there was some incineration was much higher than in states with no incineration (29 versus 10 per cent).

In many places, combustion of materials with energy recovery is regarded as reuse, leaving what is sent to landfill as the only true waste. European Union directives require the avoidance of landfill for all but non-combustible waste. Denmark is closest to this ideal. In 2003, according to the European Environment Agency, Danes incinerated 60 per cent of their household waste, reused or recycled 31 per cent and landfilled six per cent.

Reasons to avoid landfilling include its high environmental cost and impact on human health. A 1999 Ontario government study suggested that the cancer risk from living near a landfill was about 100 times that of living near an incinerator. Differences for other health risks were less dramatic, but were still higher for landfill than for incineration. A 2005 study in New York City had similar findings, noting that the longer trucking distances associated with landfill present additional health
risks.

Landfills also produce methane, a potent greenhouse gas. As a result, a landfill’s contribution to global warming is between 45 and 115 times greater than incineration on a per-tonne-of-waste basis, depending on the extent of methane collection in the landfill.

But the strongest criticisms levelled against incineration arise from its history of releasing dioxins and furans. In 1987, incinerators produced 63 per cent of dioxin/furan releases in the US, according to the US Environmental Protection Agency. In 2002, they produced one per cent, a decline from 8877 grams to 12 grams. Technological improvements to waste incineration with regard to the release of dioxins, furans and a number of other pollutants are so advanced that concentrations of these compounds sometimes fall below levels found in ambient air. In this case, incinerators actually clean air rather than pollute it.

Flaring or other combustion of landfill gases can also result in dioxin emissions. However, trucking is the main source of dioxins.My calculations suggest that dioxin emissions from the trucks carrying Toronto’s waste to a Michigan landfill site are several times that of incinerating the same waste.

The politics of incineration are unusual. Opinion polls in Toronto consistently show that support for incineration exceeds 75 per cent. A 2006 survey suggested that “nine in 10 residents believe burning waste to produce electricity could be a viable solution [to the garbage crisis].” Of these, 60 per cent said they would support having an incinerator in their own neighbourhood. Nevertheless, Toronto City Council has consistently opposed incineration.

Toronto Mayor David Miller characterizes incineration as “expensive, polluting and damaging to recycling efforts” in comparison with landfill. That incineration pollutes and damages recycling efforts is not consistent with available data. Furthermore, there is even doubt about its expense.We know that in 2004, the tipping fee at the 850-tonne-per-day incinerator in Syracuse, NY, was $62.50 per tonne, when Toronto was paying $55 per tonne to landfill its waste in Michigan ($35 for trucking and $20 for landfilling). The Syracuse fee would likely have been lower if the plant were larger and its bottom ash could be sold as aggregate, as permitted in Europe and some US states, perhaps even lower than what Toronto was paying.

I would argue, however, that high costs for incineration and landfill can be a good thing if they reduce material flows, and encourage or even subsidize recycling.

Mark Winfield replies: Richard, your argument for incineration over landfill as a waste disposal option seems premised on two propositions: that incineration has less environmental impact than landfilling and that the high cost of incineration will drive waste reduction.

At the same time, you assume that the primary argument against incineration is its air pollution impacts. Most opponents of incineration as a waste disposal option, including me, concede that the hazardous and criteria air pollutant emission performance of newer incinerator designs may be better than those of the past. Nonetheless, these emissions continue to be a serious concern, as do greenhouse gas emissions.

Rather, the core critique of incineration as a waste disposal practice is that it competes directly with diversion options for high embedded-energy components of the waste stream such as paper and paperboard, wood, organics and certain plastics. Incinerators need the energy contained in these materials to be economically viable. The lower the portion of these materials in their feedstock, the more incinerators require expensive and high-value supplemental fuels such as natural gas.

This situation has resulted in incinerator operators requiring municipalities to enter into “put-or-pay” contracts. These provide for financial penalties when minimum waste levels (often with specified energy content) are not provided. Such arrangements effectively cap the expansion of diversion programs as they would undermine the ability of municipalities to meet their waste-flow obligations.

Even more serious from a sustainability perspective, the waste supply arrangements necessary to make incineration viable encourage continued waste generation and the underlying patterns of materials-use and consumption. In a global context, developed societies such as Canada need to reduce the intensity of their use of primary materials by a factor that ranges between four and ten to bring them in line with what the global biosphere can sustain.

The critical impacts from a global perspective are not those of waste disposal, be it landfill or incineration. Rather, it is the upstream impacts of mining, intensive forestry and petrochemical production that feed the current material throughput of our economy. Incineration perpetuates the resource-input and waste-output flow.

Furthermore, presenting the debate as one of incineration versus landfill is misleading. Widespread incineration would not eliminate the need for landfill.At best, incineration reduces the volume of material requiring disposal, but the resulting ash may well contain combustion products that are far more toxic than anything in the original waste.What really counts in environmental terms is what you are landfilling, not how much.

Your argument on the relative environmental merits of incineration and landfill is premised on the assumption of continued reliance on conventional mixed-waste landfills. Research completed for Friends of the Earth in the UK indicates that the combination of stabilized landfill and intensive up-front sorting to remove recyclables, and hazardous and other problematic wastes, for example, could lower greenhouse gas emissions and reduce other impacts. Furthermore, this combination doesn’t compete with diversion.

Moreover, extended producer responsibility programs that require manufacturers and distributors to assume responsibility for diverting post-consumer products from disposal could drive changes in product design to reduce waste and facilitate the reuse and recycling of product components and materials.

Richard, you also assume that communities are more likely to accept incinerators in their midst than landfills. The public opinion poll that you cite shows potential acceptance of incineration – as long as the incinerator is to be in someone else’s (very distant) backyard. In the meantime, the public is voting with its green bins. As Torontonians and others prove, when given the opportunity, people will alter their behaviour in significant ways to reduce the flow of waste requiring disposal.

I agree with your view that increasing the cost of waste disposal will improve the economic viability of diversion. However, there are many ways of achieving this outcome without committing to incineration. Your proposal is a little like suggesting we build expensive nuclear power plants to promote energy efficiency. Many jurisdictions around the world apply curbside disposal charges or landfilling taxes to improve the economic viability of waste reduction, reuse and recycling. More broadly, disposal costs alone, applied at the back-end of the materials cycle, are unlikely to reduce material use and consumption. A sustainable economy requires that we stop subsidizing the extraction and production of primary materials.

Gilbert responds: Mark, You write as though I had not provided compelling evidence of the following:
• There is much more recycling in communities where residual waste is incinerated than where it is not;
• Incineration has lower net greenhouse gas emissions than landfill; and
• Communities appear to be accepting of incineration. You add a few canards:
• “Incinerators require expensive and high-value supplemental fuels,” when no incinerator used for municipal waste requires supplemental fuel except for a few minutes during start-up after annual maintenance; and
• “At best, incineration reduces the volume of material requiring disposal,” when most incinerator ash is suitable for reuse, usually as aggregate, and is reused where permitted. The small percentage of ash containing toxic compounds captured from incinerator gases can be readily made inert. In Denmark, useful materials are extracted from fly ash.Without incineration, toxic materials end up in landfills, where they remain hazardous.

The “put-and-pay” requirement is a red herring. Landfill operators seek put-and-pay provisions too, which is why Toronto will continue sending its waste to Michigan even though it has purchased a landfill that is closer.

We don’t disagree about the need to reduce material flows. Indeed, I’ve been critical of some recycling in the past because
it may sustain flows.Nor do we disagree about the need to recycle what cannot be reduced.

However, I find the idea of shipping waste a long distance and putting it into a hole in the ground – however carefully engineered the trucks and the hole may be – so abhorrent I’ll support incineration of residual waste, at possible political cost, if it is shown to be environmentally superior to trucking and landfilling. Either you don’t consider trucking and landfilling to be abhorrent, or you find incineration to be less environmentally sound.

Mark, I’m curious to know what it is you like about trucking and landfilling, and whether there are any circumstances under which you would support incineration over trucking and landfilling.

Winfield closes: Richard, The issue isn’t one of abhorring the transport and landfilling of waste. Rather, it is a question of what precisely would be left to burn after we have reduced, reused and recycled as much of the waste stream as possible, as you agree we should. If the paper and paperboard, wood, organics and recyclable plastics are removed, all that remain are materials such as construction and demolition wastes that make very poor fuel, and non-recyclable plastics that release unacceptable by-products when burned.

The choice is not between incineration and landfill, but between incineration and diversion. Incinerators need the best components of the waste stream for diversion as fuel. What counts is what happens at the individual municipal level. We know that municipalities that have committed to incineration view their diversion efforts as capped. The same certainly cannot be said of the City of Toronto, which, notwithstanding the landfill arrangements you reference, is well on its way to a 70 per cent residential diversion target. Landfills do not need a continuous flow of high-energy-content waste to operate. Incinerators do.

What I do find abhorrent is the notion of squandering the embedded energy and materials by reducing them to ash that, at best, can only be used in low-grade applications. Indeed, the normal destination of incinerator fly ash is a hazardous waste landfill. I note that you wisely don’t raise the idea of obtaining “energy from waste.” Even with energy recovery, recent lifecycle inventories completed for Environment Canada and Natural Resources Canada make it clear that incineration is an absolute loser relative to reuse and recycling in terms of energy retention and greenhouse gas emissions.

Your argument is premised on an assumption that incineration is the only alternative to long-distance transport to a conventional mixed-waste landfill when, in fact, we have more sustainable options for the management of used materials. The problem with incineration is that it can’t co-exist with those paths.

Mark Winfield is director of the Pembina Institute’s Environmental Governance Program and is associate faculty with the University of Toronto’s Centre for the Environment. He will join York University’s Faculty of Environmental Studies in July.

Richard Gilbert is a Toronto-based consultant.With Anthony Perl, he is the author of the forthcoming Transport Revolutions: Making the Movement of People and Freight work for the 21st Century (Earthscan/James & James, 2008).

"Reprinted from Alternatives Journal, 33:2/3 (2007). Annual subscriptions $35.00 (plus GST) Visit http://www.alternativesjournal.ca

The article is on our website at:

http://www.alternativesjournal.ca/index.php?option=com_content&task=view&id=298