Statistics Canada claims that Ontario’s IC&I waste diversion rate is 18 per cent. This statistic is somewhat underestimated in that it discounts on-site diversion by waste generators or wastes sent by major IC&I waste generators directly to materials processors. Despite these uncertainties, the rate is undeniably low and the province is seeking improvement. There are three primary reasons that provincial IC&I waste diversion rates are low. Firstly, price signals to IC&I generators are weak; the low cost of waste disposal and the relatively high costs of diversion provide generators with little incentive to divert waste. Additionally, the existing regulatory framework for IC&I waste diversion in Ontario is weakly enforced and not supported by a comprehensive promotion and education program targeted at IC&I generators. Finally, the waste service sector is not bound to meaningful environmental performance standards with regard to diversion services.
As part of two ongoing public policy processes — the review of the Blue Box Program Plan (BBPP) and the review of the Waste Diversion Act 2002 — the Ontario government has asked for comment and suggestions on how to increase IC&I diversion.
The BBPP has requested parties to consider, “…if, and how, the BBPP could be extended to include blue box wastes generated by the IC&I sector.” In response Waste Diversion Ontario (WDO) has suggested that that IC&I wastes might be brought into the Blue Box Program Plan using an, “…incentive model or a fee-for-service model [that] could be utilized by stewards to increase collection and recycling of blue box wastes generated by the IC&I sector.”
The implication of extending the blue box stewards’ mandate to include the IC&I sector is that Stewardship Ontario (SO) would responsible for providing blue box diversion services to all IC&I facilities across Ontario — a dramatic expansion of its monopoly power as IFO for residential blue box waste. Such an approach would eliminate the existing developed and competitive IC&I waste diversion service marketplace.
The Ontario Waste Management Association (OWMA) argues against such an approach. The OWMA notes that the rationale for creating “systems of scale” for household packaging waste is understandable: a multitude of points of generation each generate small quantities of recyclable materials. It counters that such is not the case with regard to IC&I generators who generate larger quantities of blue box waste per location and can therefore be served effectively (and at much lower cost) by competing service providers.
Additionally, the OWMA argues that the right price signals and information resources would cause many IC&I waste generators to demand products and packaging from suppliers that results in less waste in the first place (effectively “inducing” extended producer responsibility [EPR]).
As an alternative to expanding the blue box monopoly the OWMA has proposed policy initiatives that build upon a Zero Waste Levy of $10/tonne applied to IC&I and C&D waste destined for disposal. The proposed levy is similar to the one launched in New Zealand in 2008 under the Waste Minimization Act 2008. The levy is designed primarily to provide IC&I waste generators with an economic incentive for waste reduction (i. e., reduction through green procurement/induced EPR) and diversion (recycling) targeted at waste generators. Revenues from the levy would be accrued in a dedicated “Zero Waste Innovation Trust” with a mandate to increase IC&I waste diversion by:
• Undertaking studies and R&D to inform green procurement practices (i. e., green procurement guidelines and life-cycle costing tools);
• Providing technical and financial assistance to IC&I waste generators to adopt comprehensive waste prevention and green procurement practices;
• Providing technical and financial assistance to IC&I waste generators to undertake waste reduction audits and work plans;
• Undertaking compliance auditing of diversion service providers;
• Funding dedicated environment ministry enforcement of its waste reduction/diversion regulations;
• Funding scientific and economic policy research undertaken by the Ontario Ministry of Environment in support of its development of public policies regarding waste diversion;
• Establishing a Financial Assurance Trust for underwriting the environmental liability associated with waste diversion and waste disposal facilities;
• Generator grants to install source separation equipment, recycling chutes, etc.; and
• Engage in communication, promotion, education and a waste diversion certification process for IC&I generators. With dramatically increased resources provided to small-and medium-sized businesses, the government could reasonably lower the deminimus IC&I regulatory threshold to require smaller businesses to conduct waste audits, prepare waste reduction work plans and implement diversion programs.
Finally, the OWMA proposes a waste diversion service provider certification program which would involve meeting a performance standard or accreditation necessary to obtain a ministry-issued waste diversion System Certificate of Approval. Only approved and accredited waste diversion companies would be eligible to provide waste diversion services to IC&I waste generators in Ontario.
Standards contained in the System C ofA could include specific definitions of “recycling” for each waste category included in the certification, the ability to track material collection and diversion to final disposition, and adherence to Occupational Health and Safety standards and other approvals. The accreditation system would be under oversight of the Zero Waste Innovation Trust.