I thought readers would appreciate reading a letter that Susan Antler, Executive Director of The Compost Council of Canada, sent recently to CCC members inviting them to advocate for proper standards and best-management practices in regard to a proposed new Ontario policy that would increase the amount of organic materials a farm can utilize in an anaerobic digestion (AD) process. Antler’s concerns echo those of the Ontario Waste Management Association (OWMA).
In a worst case scenario, the thinking goes, people might buy farms in order to use AD to process and “dispose” of collected compostable materials, and thereby skirt provincial guidelines and requirements for the composting of those materials.
I don’t know how likely the worst-scenario is, but I agree with Antler’s interest in ensuring that the on-farm AD program be done properly if it’s to be done at all.
Anyway, here is the letter (and note that there’s an informative appendix at the end):
To Ontario Members of The Compost Council of Canada,
Yesterday, we met with various MOE representatives to discuss the proposed Mixed Waste On Farm Anaerobic Digestion Program as proposed in EBR 011-8998
Our concern is that there is a significant oversight in the proposed EBR that will result in waste management programs flowing on to agricultural lands without the same regulations or guidelines required by the MOE for off-farm anaerobic digestion and compost facilities.
The focus of our discussion was concerning appropriate testing parameters and safety analysis of the digestate. This regulatory oversight has created an unequality between on farm and commercial AD facilities.
Many members of our industry in addition to the involvement of the OWMA (Ontario Waste Management Association) and ONEIA (Ontario Environment Industry Association) stepped up in statesman-like fashion to voice common concerns.
We specifically requested that any proposed regulations be updated after conducting the research study being proposed by the Ontario Ministry of Agricultural & Food on the specifics of the digestate testing regime. This reflects our concern for product integrity and overall industry product sustainability and advancement. We also asked that representatives from our industry participate in this study to ensure comprehensiveness and inclusion.
If you have not done so already, it is important that your operation introduces yourself to your M.P.P. (Member of Provincial Parliament), identifying your significant contribution to the economy of your region (# of jobs, investment, etc.) and the environmental sustainability of both your region and the Province of Ontario (tonnage, products created, infrastructure support) and your opinion/concern for the proposed EBR. Your organics facility may be at risk, and health risks may arise from untested land application of digestate.
Here is the link to accessing your M.P.P.
Appendix I provides you with some background information that could be included in your conversation.
Linked here is our July 2013 submission pertaining to the proposed EBR. We are also now including another European document entitled: Biogas Handbook.
BOTTOM LINE: We advocate all forms of organic recycling including on-farm anaerobic digestion. The key is to:
i. respect the science
ii. implement using best management practices and appropriate technology for the intended practice
iii. ensure one operating standard that applies equally to on farm and commercial operations
iv. create value-added products that meet environmental health & safety as well as agronomic performance standards
The Compost Council of Canada
Organics Recycling in Ontario
Background & Operating Structure
– Ontarians generate about 13.5 million tonnes annually of waste (1 tonne/person), of which approximately 4 – 5 million tonnes annually are organic residuals
– currently approximately 1.3 million tonnes annually are processed through compost as well as anaerobic digestion facilities (an approximate 25 – 30% capture of the annual potential); as an added reference, current municipal Blue Box recycling efforts yield 893,000 tonnes (2012 WDO data) versus 880,000 tonnes diverted through organics programs (2011 data; latest published by WDO)
– for every tonne of organic residuals diverted, at least one tonne of greenhouse gas emissions are reduced
– ours is more than a waste management action in that we are involved in added value product creation with an estimated annual compost production of 500,000 – 600,000 tonnes (with added annual environmental benefits of water savings of 0.5 billion litres and indirect preservation of 10,000 hectares of natural topsoil)
– the future opportunity for organics resides in increasing multi-family residential collection; expanding organics collection in current non-participating municipalities (230 municipal programs have a focus on organics compared to the 400 municipalities with Blue Box programs) as well as fully involving the IC&I sector in organics diversion
Actions by our Industry
1. At the request of the Ontario Ministry of the Environment, our industry presented a series of recommended actions to exponentially advance organics diversion and product manufacturing inOntario.
The details of the recommendations and industry analysis are found in the following documents:
i. Organics Position Paper for the Province of Ontario
ii. Household Organics Recovery in Ontario
2. Amongst the many specifics, our industry has initiated the following:
i. Compost Facility Operator Training (with a certified operator training program implemented in the Province of Alberta)
ii. Odour Management Training (BioCycle Guide to Odour Management at Composting Facilities,Odour Management 101, Odours Workshop)
iii. Operational Best Practices (in addition to ongoing presentations and documentation, most recently, the promotion of Environment Canada’s Technical Document on Municipal Solid Waste Organics Processing)
iv. Ongoing survey of organics recycling operations and dynamics in addition to starting fully focus on the Canadian section of www.findacomposter.com
Regulations and Industry-Initiated Programs
i. With the CFIA (Canadian Food Inspection Agency) and the CCME (Canadian Council of Ministers of the Environment), most recently updated the Guidelines for Compost Quality which have been reflected in Ontario’s recent updating of the Compost Quality Standards
ii. Introduced over-and-above product testing and marketing parameters through the Compost Quality Alliance (CQA)
Current Regulations for:
i. Compost Facilities
a. Ontario’s Compost Quality Standards
b. Guideline for the Production of Compost in Ontario
ii. On-Farm Anaerobic Digestion Facilities
i. Development of the CQA (Compost Quality Alliance)
ii. Market Development programs including:
– use specifications (eg. Erosion & Sediment Control Guidelines; Sustainable Sites Initiative)
– Greenbin Compost Field Trials in Agriculture
– SOILS 101 with the Landscape Industry
i. Our industry sadly receives no EPR funding, depending totally on tip fees and product sales (this “zero” compares to $184 Million received by Stewardship Ontario from Blue Box and MHSW Brand Stewards in 2012)
ii. To help advance infrastructure development, other provinces have implemented a $10/tonnelevy on waste-to-landfill.
iii. There has been some advocacy for landfill bans on organics. However this would preclude the opportunity to realize carbon credits (currently not in existence in Ontario).