The Ontario government recently issued a draft regulation for hazardous and special products that would require producers of hazardous and special products, such as paints, pesticides, solvents, oil filters, antifreeze and pressurized containers, to collect, manage or promote the recycling or proper disposal of these products at end-of-life.
Description of proposed regulation
The proposed regulations puts more responsibility of producers for the waste generated from their products and packaging. It also envisions waste as a resource that can be recovered, reused and reintegrated back into the economy.
The proposed regulation for hazardous and special products (HSP) would require producers to:
establish free collection networks for consumers
manage all collected hazardous and special products HSP properly, including meeting procedures for recycling, where possible, or disposal
provide promotion and education (P&E) materials to increase awareness
register, report, provide audited/verified sales data, keep records and meet other requirements
require producers to transparently reflect any related charges that are intended to be passed on to consumers.
Key principles of the proposed regulation
Under a producer responsibility model for waste diversion, costs would be shifted from municipalities and taxpayers to producers that can better control costs through influence over:
the types of products and packaging put into the marketplace
the materials used to make products and packaging
how the products and packaging are collected and managed at end-of-life
This model would encourage producers to find new and innovative ways to reduce costs and improve the environmentally responsible management of materials.
The proposed regulation is based on the following principles:
1. Improving Environmental Outcomes:
ensuring HSP is collected and managed at end-of-life in a safe and environmentally sound manner to keep harmful substances out of the environment and protect human health
providing a robust, convenient collection network across Ontario so that consumers can easily drop off their HSP for recycling or proper disposal
increasing waste diversion, recovering resources from products that are currently being lost to landfills, and reducing the use of virgin raw materials
2. Reducing costs and burden for businesses:
providing producers of HSP with increased flexibility for how they collect and manage their products at end of life or meet regulatory obligations
allowing producers of HSP to contract with other organizations in order to meet their regulatory obligations
encouraging a sustainable system for industry and consumers by lowering costs, promoting consistency and ensuring ease of access
enabling producers to develop and implement innovative and cost-effective approaches while still ensuring HSP are collected and managed properly
3. Supporting economic growth and innovation:
reducing taxpayer burden by shifting responsibilities and costs related to the collection and management of HSP to producers and using non-government oversight and compliance
encouraging a sustainable system for industry and consumers by lowering costs, promoting consistency and ensuring ease of access
providing producers of HSP with the flexibility to develop HSP collection and management systems in a cost-effective manner
supporting competition, innovation and better product design
Implementation and governance
The current Municipal Hazardous or Special Waste (MHSW) Program is scheduled to end on June 30, 2021. Ideally for the Ontario Government, that regulation will be replaced by the proposed Hazardous and Special Products producer responsibility regulation under the Resource Recovery and Circular Economy Act, 2016 (RRCEA). The new regulation is expected to be fully in effect on July 1, 2021, subject to all necessary approvals being obtained.
overseeing the proposed scheme, including the compliance and enforcement activities related to the proposed regulation
collecting data through its online Registry to oversee and assess performance
posting Registry procedures on its website to further clarify producer obligations
Proposed regulation details
The Ontario government is seeking input on the draft proposed Hazardous and Special Products regulation. The sections below summarize key elements of the draft proposed Hazardous and Special Products regulation. For full details, please review the draft proposed regulation which is attached under “Supporting materials”:
Defining responsible persons
Promotion and education
Collection and consumer accessibility
Registration, reporting and auditing
Defining responsible persons
The proposed regulation sets out a methodology for identifying producers who would be subject to the requirements under the regulation. This ensures that the person with the closest connection to the designated products is made the responsible producer.
The draft regulation proposes the following hierarchy to determine producer responsibility:
the first person responsible would be the brand holder who is resident in Canada and whose HSP are supplied to Ontario consumers
where no brand holder is resident in Canada, then the first importer of HSP into Ontario and who is resident in Ontario
where no importer is resident in Ontario, then the person who is resident in Ontario who first marketed the HSP
where no marketer is resident in Ontario, then the person who is not a resident in Ontario who first marketed the HSP; this would include retailers who are out-of-province and who supply HSP to Ontario consumers through the internet
This producer hierarchy would not apply to either fertilizers or mercury-containing devices, such as thermostats, thermometers and barometers, where the Ontario government is proposing to only obligate brand owners – and not importers or marketers – as brand owners would be in the best position to oversee the implementation of a P&E program for fertilizers or the management of mercury-containing devices.
To reduce burden, the Ontario government is proposing to exempt producers that supply a relatively small quantity (weight) of HSP into the Ontario market from all requirements under the regulation , except for recordkeeping requirements, if their supply of HSP is less than or equal to the product-specific minimum thresholds, as defined in the proposed regulation.
The proposed regulation would transition the products managed by the current Municipal Hazardous or Special Waste (MHSW) program, with the addition of mercury-containing devices (i.e. thermometers, barometers and thermostats). The proposed regulation sets out four (4) defined categories of HSP, where each category includes different HSP as well as different responsibilities that the producers of the HSP must undertake:
Category A Products include oil filters and non-refillable pressurized containers. Producers of these products would have consumer accessibility requirements, P&E requirements, management targets, and would have to properly recycle or dispose of any Category A products that are collected.
Category B Products include antifreeze (including factory-fill antifreeze), empty oil containers, paints, pesticides, solvents and refillable pressurized containers. Producers of these products would have consumer accessibility requirements, P&E requirements, and would have to properly recycle or dispose of any Category B products that are collected. The ministry is proposing to exempt propane that is marketed in refillable pressurized propane containers from collection, management or P&E requirements in recognition of their long lifespan (refilled and reused for many years) and existing closed-loop collection system for these products. The government continues to seek input and feedback to better understand the current management and recovery of these products and implications if these products were to be exempt from regulatory requirements.
Category C Products include mercury-containing devices, including thermostats, thermometers and barometers. Obligated producers of these materials would have P&E requirements and would be required to properly recycle or dispose of Category C products, if collected by municipalities or other permanent depots or at HSP collection events.
Category D Products include fertilizers. Producers of these materials would have P&E requirements aimed at encouraging consumers to use up or share fertilizers.
The Ontario government is proposing that producers of Category A Products and Category B Products would be subject to registration, reporting and auditing/data verification requirements. Producers of Category C Products (i.e. mercury-containing devices) and Category D Products (i.e. fertilizers) would be required to register and report annually.
At a future date, the ministry intends to consult on what additional products could be added in subsequent phases of the regulation.
The proposed regulation requires producers of Category A Products, including oil filters and non-refillable pressurized containers, to meet management targets. These targets set out a minimum amount of HSP that producers need to collect and recycle, calculated based on the weight of these HSP sold into the marketplace, multiplied by the management percentage stated in the proposed regulation.
Only HSP processed by registered processors that meet defined standards and is sent to an end market within the performance period would count towards meeting a producer of Category A Product’s management target.
The proposed regulation would prohibit a producer from satisfying the management target by adding the weight of HSP that is land disposed.
Producers of the other categories of HSP would not be subject to management targets. However, producers of Category B Products and Category C Products would still be required to properly manage (i.e., recycle or dispose) any HSP that they collect or receive.
Promotion and education
The proposed regulation requires producers of Category A and Category B Products to implement promotion and education programs to:
raise consumer awareness about the producer’s efforts to collect, recycle or properly dispose of HSP
encourage public participation in those efforts
Producers of Category C Products would be required to implement promotion and education programs to inform the public that mercury-containing devices can be returned to municipal depots, select non-retail collection sites and collection events.
The government is also proposing that producers of Category D Products (i.e. fertilizers) be required to implement promotion and education programs to:
educate consumers that unused fertilizers without pesticides are typically not hazardous waste and should not be brought to municipal HSP depots or events
encourage consumers to alternatively use up or share any leftover fertilizer so that there is no leftover residual product to be managed
To support transparency and protect consumers from potentially misleading or inaccurate information, the Ontario government is proposing that sellers who impose a separate charge in connection to the sale of HSP be required to communicate:
who imposed the charge
how this separate charge would be used by the seller to collect, recycle or properly dispose of HSP
The proposed regulation would require producers of Category A Products and Category B Products to establish and operate a robust, convenient collection network, including both collection sites and events, for consumers to return their HSP at end of life, free of charge. The regulation would set consumer accessibility requirements based on municipal population size and/or number of retail locations to ensure there are collection locations throughout the province, including northern and rural areas as well as Indigenous communities, while also providing producers with flexibility on how they may establish their system.
The proposed regulation would allow for a variety of options that producers can use to satisfy their consumer accessibility requirements. The Ontario Ministry of Environment, Conservation and Parks (MECP) continues to consider how to design an approach that would support an equitable number and distribution of permanent collection locations (for example, return-to-retail and municipal depots) and collection events. Producers can reduce their required number of permanent sites by implementing alternative collection options, such as call-in “toxic taxi”, mail-in, curbside collection services, or additional collection events. In addition, the MECP is considering an option which would allow producers to offset their required number of collection sites or events in certain municipalities with collection sites or events implemented in other municipalities where collection sites exceed the minimum regulated requirements. This could allow for greater flexibility for producers to use existing sites to offset requirements for establishing new sites and reduce burden. The MECP is considering appropriate conditions to limit the application of offsets to ensure that Ontarians will still have convenient access to collection options. This proposed option is not reflected in the draft regulation which accompanies this posting.
The proposed regulation would include service standards for the various collection options (e.g. hours of operation, types and amounts of materials to be collected) to ensure a level playing field in the service provided.
Producers would have 18 months to establish their collection network and obtain MECP approvals where necessary, while they would be required to maintain the current number of collection sites and events in each municipality, and current service levels.
The MECP recognizes that environmental compliance approvals (ECAs) are required for collection sites in order to receive certain types of HSP (e.g. oil filters, antifreeze, oil containers, solvents and pesticides). Through a separate process, the ministry intends to consider ways to streamline approval requirements by proposing and consulting on amendments to Ontario Regulation 347 (General – Waste Management), made under the Environmental Protection Act, that would make it easier to implement collection sites for HSP that is destined to be sent to a recycling or proper disposal facility.
Registration, reporting and auditing
The proposed regulation would require producers of all categories of HSP, voluntary organizations, producer responsibility organizations and certain service providers (i.e. haulers, processors and waste disposal companies) to:
Register with the Authority. The proposed regulation sets out the information to be registered and the timelines for submitting information.
Keep records that relate to the accepting, storing, handling, transferring, processing and disposing of HSP in Ontario.
Submit reports through the Authority’s Registry. The draft proposed regulation sets out each party’s reporting obligations, including contents of the reports and reporting frequency. Producers would have the option of having another organization submit these reports on their behalf.
In order to reduce burden, the Ontario government is proposing that collection site operators (e.g. municipalities and retailers) do not need to register and report to the Authority, although they would still be required to keep records related to HSP at their site.
The proposed regulation would require producers to have an independent audit conducted annually by a certified accountant or verification via internal attestation to verify sales data.
Public consultation opportunities
The proposed regulation is posted on the Environmental Bill of Rights Electronic Registry for comment until March 28th, 2021. The MECP will also hold consultation sessions in the coming weeks to seek stakeholder feedback and input on the proposed regulation.
https://advancedwastesolutions.ca/wp-content/uploads/2021/02/barrelslessbright.jpg5251600John Nicholsonhttps://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.pngJohn Nicholson2021-02-25 03:12:492021-02-25 03:12:49Ontario proposes new hazardous and special products waste regulation
The Government of Canada recently announced it was providing $95,000 in financial support to the Aurora Research Institute, in association with Delta Enterprises, a Gwitch’in owned company, to study the potential of converting waste cardboard into pellets as biomass feedstock for heating homes and businesses throughout Inuvik.
Northern communities are looking at ways to reduce their reliance on diesel for heating and electricity by increasing the use of local renewable energy sources and improving energy efficiency. The goal of the project is to eventually build a facility that will take up to 60 per cent of the community’s cardboard bound for the landfill and instead, recycle it into heating pellets, thereby supplementing Inuvik’s biomass pellet supply and reducing reliance on fossil fuels used for heating.
Converting the cardboard to pellets and then burning the pellets to generate heat and electricity results in lower greenhouse gas emissions than disposing of the cardboard in landfill.
By supporting an emerging northern biomass industry, the Government wants to create local jobs, transition to clean energy and keep investments in the North by using local resources and building a regional economy. This will support healthier, more sustainable communities, across the North.
The funding for the study is through the Northern Responsible Energy Approach for Community Heat and Electricity program (Northern REACHE). This investment is part of Canada’s nearly $700 million commitment to help rural and remote communities get off diesel, through programs delivered by Natural Resources Canada and Infrastructure Canada.
https://advancedwastesolutions.ca/wp-content/uploads/2021/02/cardboard-to-fuel-pellets-e1614114944866.png291900John Nicholsonhttps://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.pngJohn Nicholson2021-02-24 05:16:252021-02-24 05:35:00Canada invests in waste-to-fuel study for Indigenous and Northern Communities
The Government of Saskatchewan recently launched a new recycling program for consumer batteries that will provide an option for people in various parts of the province to dispose of their household batteries in an environmentally responsible manner.
Launching January 1, 2021, the program is operated by Call2Recycle Canada Inc., a non-profit environmental stewardship organization that has been voluntarily collecting batteries in Saskatchewan for recycling since 1997. Call2Recycle met all the regulatory requirements of a government-approved program under The Household Hazardous Waste Products Stewardship Regulations, 2019.
“This recycling program is a positive step for the environment and for the people of Saskatchewan,” Environment Minister Warren Kaeding said. “Having a convenient and important program in place to keep batteries and other hazardous materials out of our landfills helps support provincial goals laid out in our Solid Waste Management Strategy.”
“I would like to extend my thanks to the Government of Saskatchewan for its commitment to battery recycling in the province,” Call2Recycle Canada, Inc. President Joe Zenobio said. “Under the new regulation, Call2Recycle’s program will connect residents with many easily accessible and convenient battery drop-off locations across the province. We encourage all residents to safely drop off their batteries at their nearest collection location to help create a more sustainable environment for generations to come.”
The program accepts used single-use and rechargeable consumer batteries (weighing less than five kilograms each), excluding lead acid batteries. In partnership with municipalities and retailers, Call2Recycle has established convenient drop-off locations across the province for Saskatchewan residents, including in all SARCAN depots.
“We are excited for SARCAN’s 73 collection depots to be a part of Call2Recycle’s national network of battery collection sites,” SARC and SARCAN Recycling Executive Director Amy McNeil, said. “Our team of SARCAN recyclers is ready to help the people of Saskatchewan divert even more hazardous materials from our land and waterways, which means protecting our environment for generations to come.”
As part of the new program, an environmental handling fee will be paid at the point of purchase effective January 1, 2021. The fee rates range, depending on the size of battery and the chemistry type. For example, fees for AAA and AA batteries are $0.02 and $0.04, respectively.
The fees will be paid to Call2Recycle for the collection, transportation and recycling of the batteries at their end-of-life. For the full fee structure and a map of drop-off locations, please visit https://www.call2recycle.ca/saskatchewan/.
https://advancedwastesolutions.ca/wp-content/uploads/2021/01/saskatchewan.jpg79373John Nicholsonhttps://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.pngJohn Nicholson2021-01-08 23:35:292021-01-08 23:35:29Battery Recycling Program to Launch in Saskatchewan
Written by Calvin Lakhan, Ph.D, Co-Investigator: “The Waste Wiki” – Faculty of Environmental Studies at York University
Over the past 8 months, the university has been conducting a series of studies examining household waste management behavior in Ontario. This includes:
An examination of household attitudes and self-reported behaviors regarding illegal dumping
An examination of whether household waste management behaviors have changed over the past decade
Identifying the primary antecedents and obstacles to desired household waste management behavior, including measures of attitudes, awareness, normative/social influences and perceived behavioral control.
Evaluating the efficacy of promotion and education initiatives on diversion behavior across multiple mediums
Examining how, (if at all) COVID has affected waste disposal/diversion habits among households
In many ways, this can be seen as the conceptual follow up to the series of studies I conducted in between 2014 and 2018, with the goal of better understanding how household attitudes and behaviors towards waste have changed over time. The emergence of the COVID pandemic last year has added an additional dimension to this research, as the way we work, interact, consume and behave has changed radically – including for waste.
While each of these studies will be released as formal papers over the next 6 months, I thought I would provide a “sneak peek” into some of the results. This includes both a high level summary of the impacts of COVID on waste behavior, as well as more general results that provide insights into the aforementioned study topics.
Has COVID affected our attitudes towards waste?
COVID has resulted in several undesirable outcomes with respect to household waste behavior, largely as a result of the considerable increase in the consumption and disposal of packaging. This stems from the significant rise in e-commerce purchases, prepackaged foodstuff and food takeout as a result of pandemic restrictions.
Attitudes towards plastic packaging and plastic products have also improved considerably when compared to even as little as two years ago. Households recognize the role that plastics play with respect to PPE, and food safety. Survey results showed that support for a single use plastics ban among households was less than 35% – a precipitous drop when compared to prior year results. Attitudes towards plastics in general have also become more favorable among households, but to a lesser degree relative to single use plastics. While it is unclear as to whether this change in attitudes will persist as the pandemic abates over time, it does demonstrate that the narrative surrounding plastics is no longer binary (good vs. bad).
What is perhaps of greater interest is that COVID has not only affected consumption habits, but a household’s desire to better understand what is happening to their waste, and the resulting impacts.
More than 66% of survey respondents disagreed, or strongly disagreed with the statement “I know what happens to my waste once I dispose of it” (Note: this question was asked for both waste in general, as well as specific waste streams, i.e. packaging, organics, MSHW, textiles etc. – for brevity, only general waste results are discussed.
This finding in and of itself is not surprising, historically, households have reported poor levels of awareness regarding what happens to waste after disposal. What has changed significantly is that more than 61% of respondents agreed, or strongly agreed with the statement “I care about what happens to my waste once I dispose of it”. By comparison, only 21% of respondents from our 2016 study reported caring about what happens to their waste.
The Social Impacts of Waste – Diverting with a purpose
Historically, waste management has been seen through the lens of environmental impacts, i.e. reduced landfill utilization, increased recycling, less litter etc. However, households are increasingly wanting to know about the social impacts of waste disposal/diversion. What’s particularly interesting is that the economic uncertainty resulting from the pandemic has placed greater emphasis on households wanting to divert with a socially beneficial purpose. Using textile waste as an example, Figures 1 and 2 summarize results from one of the studies:
The results above show that not only has COVID encouraged households to divert more textile materials, but that households specifically wanted their donations to make a difference. During the open ended component of the survey, respondents indicated that they wanted their donation to help other families and/or charities during a time of economic uncertainty. While these results echo the findings from previous studies that have examined household textile diversion behavior, COVID has considerably increased altruistic intentions and the desire to “make a difference” among households.
While textiles (and furniture) more readily lend themselves to an examination of the social impacts of waste, households in general are wanting to ensure that waste is being managed in an environmentally and socially responsible way. During the open ended section of the surveys, more than 30% of respondents indicated that they were concerned about Canada “exporting waste to other countries” (i.e. Canada Philippines waste disputes), and that Canada is “dumping waste in poor countries”.
Lack of trust between households, municipalities and producers
A particularly interesting result from the surveys is that more than 41% percent of respondents expressed doubt that waste was actually being diverted (recycled/composted/reused etc.). There was a distinct lack of trust on the part of respondents, who did not believe that the municipality (or service provider) was telling the truth with respect to what they say is happening to their waste. While the survey examined specific waste streams, commonly occurring concerns that were coded during the open ended questions include: “We aren’t really recycling” “It all goes to the landfill” “It is getting shipped off to the 3rd world”.
While it is difficult to specifically isolate what is driving these concerns and the general lack of trust, it appears that incidents that are highly visible and garner a lot of media attention, i.e. “60 shipping containers of household waste rejected and sent back to Canada”, “National news story on exporting textile waste to developing economies” generate considerable uncertainty and skepticism among the public. These incidents often become the focal point for public ire and undermine trust between waste service providers and the public. Further compounding the problem is that how waste is managed and by whom varies radically across jurisdictions, making it difficult to address/dispute by any one waste service provider (municipal or private).
A lack of trust was also exhibited with respect to recycling/diversion claims made by companies. 54% of respondents disagreed, or strongly disagreed with the statement “I believe the manufacturer when a product is listed as recyclable” (note: the wording of this question originally included divertable in lieu of recyclable. However, a significant percentage of respondents were unclear as to what was meant by divertable. For our purposes, we use the term recyclable as a proxy for diversion).
Once again, news/reports that question or find fraudulent environmental claims made by manufacturers resulted in increased doubt/skepticism among households – in many ways, we have a situation of “One bad apple spoils the bunch”. When one manufacturer is caught making dubious claims, other manufacturers are punished for it in the court of public opinion. Households seemingly have difficulty differentiating between different types of products in a certain category, i.e. plastic vs. aluminum and compostable coffee pods. As an example, when Keurig was sued for making false recyclability claims, all coffee pods (regardless of type) were stigmatized and assumed to end up in the trash.
Issues in Terminology and how we communicate success
As alluded to in the previous section, respondents have difficulty understanding sector specific terminology, i.e. “divertable” etc. Less than one quarter of respondents agreed (or strongly agreed) with the statement “I know what a circular economy is”. Similar results were also observed when respondents were asked about the terms “Zero Waste – 32%” “Carbon Neutral – 11%” “Life cycle impacts – 15%”, “Green House Gases – 31%”, “Carbon Footprint – 24%” “Producer Responsibility – 17%”and “Diversion – 38%”. This finding highlights that the way we communicate with the public regarding waste, including how we choose to define and communicate success, needs to be re-evaluated. A theme that emerged during the open ended component of the surveys was that people lack context with respect to what certain metrics mean, i.e. “Is recycling 40% of waste good or bad?”, “Is a carbon reduction of 1000 T/CO2e good or bad?” “Does zero waste really mean that we won’t throw anything away?” etc.
Of note, these studies echoed the findings from our earlier work, which found that the public doesn’t fully understand or appreciate the environmental impacts of waste management outcomes that are not recycling. Reuse/refurbish, waste reduction, waste minimization, composting and incineration were waste management strategies that were not associated with desirable environmental outcomes. In short, households understand and appreciate the role that recycling can play in promoting sustainability, but the same cannot be said of other strategies on the waste management hierarchy. Respondents did recognize that certain materials/products must be safely managed and kept out of the environment as a harm reduction strategy (health and contamination hazards from household hazardous waste). However, respondents did not consider harm reduction as a component of promoting environmental sustainability.
Convenience and accessibility is what matters most
While the obstacles to desired waste management behavior (recycling, composting etc.) include a range of factors such as a lack of knowledge and awareness, negative attitudes, inconsistent service and enforcement etc., the primary obstacle remains a lack of convenience and accessibility.
Generally speaking, respondents expressed very positive attitudes towards the environment and a strong desire to “do the right thing” with respect to waste. However, respondents, particularly those living in multi-residential homes and in rural communities, indicated that they often faced barriers to access, which ultimately impeded their ability to participate.
This finding has been observed in numerous other studies, but the most important learning from our recent work is that a lack of perceived behavioral control (the ability to actually carry out a desired behavior) will largely negate any efforts to increase awareness, cultivate favorable attitudes, or normative pressures from the community/municipality. In fact, when measures of attitudes and awareness are high, but perceived behavioral control is low, it results in something called cognitive dissonance. In the simplest terms, cognitive dissonance (as it pertains to waste) refers to negative attitudes that arise from wanting to do the right thing, understanding the importance of performing the action, but being unable to do so because of an infrastructural or accessibility barrier. If cognitive dissonance persists over time, there is a risk of people becoming resentful of the desired behavior, as formerly positive attitudes now become negative.
Lack of convenience and accessibility are also seen as a manifestation of socio-economic inequality – in the broader literature, there is an extremely strong correlation between income levels and access to environmental amenities and infrastructure. While examining this topic is beyond the scope of this post, we need to ask ourselves the question “Is access to adequate waste management infrastructure and municipal diversion programs a right, or a privilege?”
Who should be responsible for educating households about what to do with waste?
Our most recent research confirmed an earlier observation from work we had done in 2018, in that households have very different expectations about who should be responsible for education and awareness with respect to waste. Intuitively, I would have guessed that households look to the municipality to provide guidance regarding what to do with waste at its end of life (as is the case in most cities across Ontario). However, when respondents were asked to identify who should be responsible for educating consumers about waste management outcomes, more than 42% said retail outlets, or at the point of purchase. This compares to 29% for municipalities, 21% for producer/manufacturers and 8% for the consumer themselves.
During the open ended section of the survey, respondents indicated that it would be easier to make an environmentally informed purchase if that information was provided at the retail level. Respondents also said that it would allow for comparison shopping among similar products, allowing them to choose items that they know can be recycled or safely managed at end of life. It is important to note that while consumers often list “recyclability” as influencing purchasing decisions, this historically has not been the case during actual observational research. Price, quality, brand loyalty etc. all play a greater role in influencing purchasing decisions when compared to the recyclability/divertability of a product (a phenomenon that is explained by the value action gap).
However, this finding about the role of the retailer in communicating what happens to a product at its end of life opens up a potentially new medium for engaging with consumers and increasing awareness, directly at the point of purchase. In fact, based on comments that were made during the open ended component of the survey, respondents would like to see additional environmental metrics communicated at the retail level. This finding is actually not as surprising as one would initially think, as there has been a marked increase in environmentally conscionable consumers who want their purchasing decisions to reflect their personal values.
Promotion and Education does not work….sort of
While I am being a tad disingenuous with the header, our most recent research reinforces our earlier findings that conventional methods and mediums of promotion and education are no longer effective. There are a number of caveats to that statement, the most important of which is that the efficacy of P&E is very much contingent on the maturity of the recycling system. All of our research was conducted in Ontario, which is seen as having a mature waste management system (characterized by high levels of accessibility and infrastructure, diversion programs for multiple waste streams, and high rates of household participation).
To make a very long story short, appeals to environmental altruism (i.e. recycling is good for the environment, helps conserve resources, helps combat climate change etc.) have already been received by the vast majority of households. Participation rates in recycling and other diversion programs among single family households is in excess of 90% – in short, the target audience for conventional P&E campaigns rooted in environmental altruism and conscionability are already doing what we want them to do, and they have been doing it for years.
Where things become more complicated is that the demography of Ontario is rapidly changing – Ethnic first generation Ontarians born outside of the country make up an increasingly larger share of overall households, particularly in the multi-residential sector. The issue with respect to increasing diversion is that many of these households do not speak English as their primary language and come from countries which lack mature waste management infrastructure and formal recycling/diversion programs. Many of these households also do not readily associate recycling/diversion with positive environmental outcomes, and do not understand or respond to promotion and education initiatives asking them to recycle. Further complicating matters is that these households are not behaviorally homogeneous, as the drivers of desired waste management behavior varies significantly across ethnic groups (South Asian households will recycle for very different reasons than African households etc.). There simply is no one size fits all approach to P&E that will be effective.
While our study will discuss this topic in greater length, habituation will be difficult to achieve unless there are significant changes made to ensure equitable access to waste management services and programs. As noted above, there is a strong correlation between community income levels and access to waste management infrastructure. On average, new Ontarians who immigrate to the province make up a significant share of these communities (in multi-res). Not only do these households have lower levels of access and face greater barriers to participation, but habituation is reinforced by performing a behavior consistently, and observing those in your community also participate consistently. Multi-residential buildings in particular lack the normative influences of being seen (and observing others) participating in a desired behavior. Residents can go to the waste room (or use a waste chute) at their convenience, and there is no way of knowing whether people are actually recycling/composting or not.
Our study also found that levels of skepticism and distrust surrounding what happens to waste was more than double among first generation ethnic minorities when compared to respondents who were born in Canada. Almost 65% of respondents who were classified as a first generation ethnic minority expressed doubt regarding whether waste is actually being recycled/diverted. Additional work needs to be done in this area to better understand whether this result was an anomaly, or part of a larger pattern of distrust among immigrants living in Ontario.
The above are very high level summaries of some of the salient findings from our most recent survey work that I thought would be interesting to share. The university was uniquely positioned to include a temporal dimension to our analysis, as many of these studies were conducted in prior years and within the same communities.
While the intent of this survey work is to ultimately produce published academic articles, I will make a concerted effort to share the overall results with the LinkedIn community. My goal is to write one post per week that goes into greater detail surrounding a study’s methodology and findings and I welcome feedback/questions/critiques etc.
PS: I’m also attaching the raw data from our illegal dumping survey results, to give you a better sense of how we organized questions and results.
Calvin LAKHAN, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior.
https://advancedwastesolutions.ca/wp-content/uploads/2021/01/household-waste.jpg6871107John Nicholsonhttps://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.pngJohn Nicholson2021-01-08 22:50:542021-01-08 22:53:29An examination of household waste behavior: What drives us to do what we do, and has COVID affected our attitudes towards waste?
Markets have been plagued by uncertainty this year, but cleantech investors can nevertheless rely on the proven practice of recycling materials into sustainable products, so says GreenMantra CEO Jodie Morgan. How fortunate, then, that Morgan and her Brantford company are one of Canada’s top post-consumer, post-industrial plastics recycling firms — morphing one of the most problematic innovations in history into things like asphalt shingles, wax and ink. As a member of MaRS Momentum, GreenMantra is also one of the country’s fastest-growing firms, with sales increasing so rapidly in 2020 that the startup expanded its manufacturing facility and doubled capacity.
What’s next: If “plastic is the new crude oil,” then Morgan and her employees are going to be busy well past next year. GreenMantra is working with petrochemical companies NOVA Chemicals and Inter Pipeline to develop new ways of enhancing asphalt. The positive environmental impact could be huge, particularly when you consider that 1,000 kilometres of paved road, for example, represents up to 2.7 billion plastic bags removed from a landfill.
Ajay Kochhar, CEO and co-founder of Li-Cycle
As climate-focused initiatives become a bigger priority, homegrown companies are looking to contribute in their own unique way. “Canada aims to achieve net-zero carbon emissions by 2050, and clean technology will play a massive role in this transition away from emissions,” says Ajay Kochhar, CEO and co-founder of Li-Cycle. Based in Mississauga, Li-Cycle recovers more than 80 percent of all materials found in lithium-ion batteries through their environmentally sound recycling plants.
https://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.png00John Nicholsonhttps://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.pngJohn Nicholson2021-01-08 22:03:102021-01-08 23:47:24Two Recycling Company CEOs make the Canadian Tech Entrepreneurs Watch List for 2021
After what seemed like a distant obligation in May of 2019, and overshadowed by an increase in plastic usage while managing the virus in 2020, the plastics amendments decision to the Basel Convention will take effect in January 2021 (the Plastic Amendments).
Unfortunately, it seems that the Plastic Amendments provide more questions than answers in how global markets will adjust to these profound changes surrounding end-of-life plastics and products containing plastic – including electronics and other consumer goods.
What do the plastics amendments do?
Under the Plastics Amendments, end-of-life plastic waste, both homogenous and mixed streams, will now be regulated under the Basel Convention (subject to some exemptions) and their transboundary transfer will either be:
Prohibited as “hazardous”; or
Controlled by domestic regulators through disclosure/Prior Informed Consent (PIC) requirements as “other wastes”.
Gone are the days of unregulated transfers of mixed (often municipal) plastic wastes which became the subject of minor international incidents in the months leading up to the Plastics Amendments. But how do exporters of end-of-life plastics know whether their material is banned, controlled, potentially exempt under the convention, or otherwise not considered a waste at all?
Convention “wastes” include resource recovery materials
As a transboundary waste transfer agreement recognizing “the need as far as possible to reduce such movement to a minimum”, material is deemed a “waste” under the convention when subject to a broad spectrum of treatments – including both various disposal-related activities, as well “operations, which may lead to resource recovery, recycling, reclamation, direct re-use or alternative uses”.
Unlike some domestic enabling legislation, the Basel Convention does not have a companion agreement on recyclables so all end-of-life processes are grouped together. Further, the Plastics Amendments have meant that there are now multiple avenues for many post-consumer products containing plastic to fall under the convention.
Reverse onus to prove not hazardous
Where the material is a waste, the Basel Convention may deem it “hazardous” under broad, inclusive categories by:
Direct listing of many conventional waste streams; or
Combination of waste:
from defined activity or containing (any level) of listed substances; and
capture within certain United Nations Dangerous Goods Classes.
There is an ability to rebut the effective presumption that a waste is hazardous but it may be more trouble than it’s worth for exporters managing waste streams of varying composition, including mixed plastics now subject to PIC requirements. Until recently, a hazardous designation was not fatal to the possible export of such materials to developing world markets for circular economy activities, but this has since changed.
Basel Ban Amendment on hazardous waste recycling in developing world
In September of 2019, Croatia became the 97th signatory to the “Basel Ban Amendment”, thereby entrenching a prohibition against the transfer of hazardous wastes, for whatever purpose, from the Organisation for Economic Co-operation and Development (OECD)/ European Union (EU) Parties to developing world nations.
In respect of products containing plastic (such as electronics), this may mean very few Basel Convention non-OECD countries will be willing to receive such wastes in potential violation of the convention and transits to such countries through a non-convention country such as the United States are also prohibited.
Other wastes and the exemption test
The majority of post-consumer plastic wastes will likely either fall into the convention’s “other wastes” category – which are subject to controlled mechanisms such as shipment-specific PIC requirements or be exempt from these mechanisms. The exemption test is whether the plastic waste is:
Destined for recycling in an environmentally sound manner and almost free from contamination and other types of wastes
As to the meaning of “almost free of contamination and other types of wastes”, the Plastics Amendments only note cryptically “international and national specifications may offer a point of reference. Unfortunately, the Secretariat has yet to issue relevant guidance, but it would seem that plastics mixed with paper, metals or glass, as well as products containing both plastics and other “waste” materials such as some electronics, would likely be “other wastes” where they are not otherwise hazardous.
Further, only certain specified plastics streams which meet the exemption test will be free from the Basel Convention control mechanisms.
Due diligence required on the importer
Convention compliance is not assured even when an exporter has managed to meet the requirements to establish that the transferring materials are merely “other wastes” and has obtained PIC. Specifically, the Basel Convention further prohibits the transfer of non-hazardous wastes where the exporter has reason to believe that the wastes will not give “environmentally sound management” (ESM), which is generally:
Taking all practicable steps to ensure that hazardous wastes or other wastes are managed in a manner, which will protect human health and the environment against the adverse effects, which may result from such wastes;
But how is an exporter to recognize ESM or its absence from distant shores? For example, the Agbogbloshie e-waste recycling site in Accra, Ghana is praised by some as model of local opportunity in resource recovery, but has also been plagued by soil contamination issues.
A rise in illegal traffic of international waste
The result of any attempts to skirt the full requirements of the convention as it relates to plastics may draw a determination of “illegal traffic”, which will have both domestic and international implications for the exporter.
Of particular concern are shipped wastes deemed to have been:
don’t “conform in a material way” with the manifest documents; or
result in deliberate disposal (i.e. dumping) in contravention of:
the Basel Convention; or
“general principles of international law”.
In other words, the contents of the shipments must get a fully description and all material must fully conform to such description. The host country regulator, now a direct participant in waste transfers, will ensure this takes place.
With the Plastics Amendments, exporters of end-of-life plastics should be aware that the Basel Convention includes a “Protocol on Liability and Compensation“, which exposes export nations (and indirectly domestic recycling industries) to potentially significant damage claims for improper exports under the Basel Convention. The stakes in the trade of global plastics and e-waste have risen considerably.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
About the Author
Jonathan Cocker, Partner at BLG LLP, provides advice and representation to multinational companies on a variety of environmental and product compliance matters, including extended producer responsibilities, dangerous goods transportation, GHS, regulated wastes, consumer product and food safety, and contaminated lands matters. He assisted in the founding of one of North America’s first Circular Economy Producer Responsibility Organizations and provides advice and representation to a number of domestic and international industry groups in respect of resource recovery obligations.
https://advancedwastesolutions.ca/wp-content/uploads/2021/01/Basel-Convention.png263700John Nicholsonhttps://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.pngJohn Nicholson2021-01-08 00:00:182021-01-08 00:06:34Basel Amendments Create Uncertainty In Global Plastics And E-Waste Markets
Written by Calvin Lakhan, Ph.D, Co-Investigator: “The Waste Wiki” – Faculty of Environmental Studies at York University
Can recycling be bad for the environment? This is a question that I have posed to students in the past – almost universally, the answer has been a resounding no. For decades, Ontarians have been inundated with the message that “recycling is good” and that it is our collective responsibility to recycle in order to preserve resources for future generation. In fact, Ontario’s Blue Box program is expected to play a critical role in helping the province achieve its carbon reduction and zero waste goals, and remains as the centerpiece of the Waste Free Ontario Act. With all of this in mind, recycling must surely be a good idea, right?
I would be disingenuous if I told that recycling was bad for the environment. However, I do feel that not all recycling is created equal. What we recycle, when we recycle and why we should recycle is very much contingent on a number of site and situation specific circumstances. When evaluated in isolation and all things being equal (cetterus paribus), recycling will yield a positive environmental outcome. However, the situation becomes much less clear once we begin to include other factors (economics, social equity etc,) and the “opportunity cost” of recycling activity (where opportunity cost is the forgone benefit that would have been derived by an option not chosen.).
Looking at the performance of Ontario’s Blue Box program, we observe a troubling trend – the environmental performance of the Blue Box (measured in terms of GHGs abated) has decreased every year since 2015. In that same period, the net cost per tonne to recycle all Blue Box materials has increased by 21%, while overall tonnes diverted has fallen by more than 80,000 tonnes. In short, the province is doing “less with more”, as the cost of the Blue Box program continues to increase by double digits year over year, while recycling less material and abating fewer tonnes of carbon.
It is important to note that this “decrease” in performance cannot be attributed to any particular cause – the rapidly changing nature of what packaging is made up of, uncertainty regarding the scope and timeframe of proposed legislation, volatility in end markets and realized revenues etc. are all exogenous factors that affect what is being recycled and the costs of doing so. The Blue Box of today is fundamentally different than it was even as little as a decade ago. Over the past 5 years, the program has seen overall paper recycling drop by more than 159,000 tonnes annually (an approximately 38% reduction). Steel packaging and glass cullet have also seen their overall recovered tonnages decrease, while aluminum, PET and HDPE have remained flat. Of particular interest, is that the share of plastics #3-7 (LDPE Film, Polystyrene, Plastic Laminates and Other Plastics) of all tonnes generated and recycled has increased significantly during this same period. This change in the mix of materials generated into the market and recovered tells a story of a system that is increasingly being made up of expensive, difficult to recycle materials.
In light of these challenges, the province now finds itself at a crossroads of sorts, and faces questions that are fundamental to the very nature of the program. 1) Does Ontario continue to promote recycling policy in the hope that a producer operated system will realize operational and economic efficiencies that overcome these problems? 2) Does the province explore alternative modes and methods of waste diversion that are no longer rooted in recycling, and 3) What is the goal of the program, and what are we willing to spend to achieve it?
For me, this last question is probably the most important one. In many ways, we have a decoupling of environmental and diversion goals. For decades, we have been taught that ‘more’ recycling is better for the environment – but conspicuously absent from this feel good message is what should be recycled. Is the decision to recycling everything (everywhere), economically feasible or environmentally desirable?
As noted earlier, a message that cannot be stressed enough is that not all recycling is made equal – while counterintuitive, a higher recycling rate does not necessarily result in a superior environmental outcome – a system which prioritizes recovery of materials such as aluminum, newsprint etc. (low cost, high impact) can achieve greater carbon reduction, even in a scenario where overall recycled tonnes decreases. In 2016, the university published a study titled “Optimizing emissions targets for residential recycling programs: Why more is not necessarily better with respect to diversion” (Lakhan, 2016 doi: 10.1177/0734242X16659923). The following is an excerpt taken from the paper abstract:
This study demonstrated targeting specific materials for recovery could result in a scenario where the province could improve both overall diversion and emissions offsets while reducing material management costs. Under the modelled scenario, as the tonnes of greenhouse gases (GHGs) avoided increases, the system cost per tonne of GHG avoided initially declines. However, after avoiding 2.05 million tonnes of GHGs, the system cost/tonne GHG avoided increases. To achieve an emissions target in excess of 2.05 million tonnes, the province will have to start recycling higher cost non-core materials (composite materials, other plastics, etc.).
While the paper itself goes into much greater detail surrounding the methodology and findings, the key take away was that what is being recycled, is often more important than how much is being recycled. Much of the current dialogue surrounding waste management revolves around increasing recycling rates and waste minimization, but we must take a step back and ask whether a higher recycling rate should be the focal point of policy objectives. Are there metrics beyond recycling rates and emission impacts that need to be considered when evaluating the long-term sustainability of waste management systems?
While movements towards more sustainable waste management options should certainly be promoted, we must recognize that the most sustainable system is not necessarily the one that recycles the most material. Although recycling is a central component of developing sustainable waste management systems, its adoption must be weighed against budgetary, social and environmental considerations. For every one dollar we spend on one activity, is one dollar less to spend on another – in a resource constrained world, how we chose to prioritize our goals and allocate these resources is of paramount importance. The careful balancing act between continuous improvement in diversion, GHG abatement and cost containment is a topic that requires more attention now more than ever.
Note: For the purposes of this editorial, I have defined carbon abatement/reduction as being a barometer for environmental performance. I recognize that carbon/GHG reduction is only one component of a much larger environmental footprint, and a true life cycle analysis should consider things like water consumption/acidification/eutrophication/toxicity etc.
About the Author
Calvin Lakhan, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior.
https://advancedwastesolutions.ca/wp-content/uploads/2020/12/pw-waste_bluebox.jpg19412243John Nicholsonhttps://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.pngJohn Nicholson2020-12-10 02:54:142020-12-10 02:54:14Doing less, with more – Why the environmental performance of the Blue Box is decreasing over time
Written by John Nicholson, Navdeep Randev, and Anastasia Jagdeo
There has been much discussion on the term “circular economy” and the need for individuals, organizations, and governments to think in terms of circular economy. In essence, a circular economy is one in which waste is essentially eliminated. Prior to the modern age, humans were part of the circular economy that exists in nature.
As we may have learned in high school science class, there are cycles in nature including those for carbon, water, and nitrogen. The industrial revolution broke away from natural cycles and created a linear approach to materials and energy management – products were manufactured, served their useful purpose, and then disposed of in a landfill. The circular economy approach attempts to create a circle again through the 3Rs and the 4th R.
In Europe and in other forward-thinking jurisdictions around the world, energy-from-waste is considered the Fourth “R” after the 3Rs (reduce, reuse, recycle). The fourth “R” represents the recovery of energy from waste.
Circular Economics applied in Waste Management
Since 1992, the Emerald Energy-from-Waste (EFW) facility has quietly and unassumingly been part of the 4th R – recovering the energy from municipal solid waste. The facility, originally knowns as Peel Resource Recovery Inc. is situated in an industrial area in north Mississauga, Ontario. In all of its years of operation, there has been nary an odour, noise, or other nuisance complaint formerly brought against the facility. Visitors tend to be amazed when they tour the facility which ends at the emissions stack. Their preconceived notion is that they would see smoke from the stack. In fact, the emissions are invisible on a warm day. On cold days, the visible emissions are water vapour.
For the first twenty years of its operation, the facility’s main source of waste was from the Region of Peel. More recently, it has received waste from several municipalities as well as U-Pak Disposal Ltd., a related company. The facility also specializes in disposing of special waste including contraband seized by various police departments and Canadian Border Services at nearby Pearson Airport.
The facility runs 24-hours a day, 7 day per week. It has a total of five two-unit gasifiers/combustion modules that work in parallel to process 500 tonnes per day of solid waste.
The heat generated from the combustion of waste at the facility is used to turn water into steam. Some the steam is piped to a neighbouring cardboard recycling facility to meet their process needs. The remaining steam is used to generate about 10 MW of electricity. The facility itself consumes about 2 MW and its sells the remainder to the local power utility.
Unfortunately, the electricity generated from the Emerald EFW is not considered renewable under Ontario rules and hence does not receive the premium pricing other forms of the renewable energy receive. There are jurisdictions around the world where EFW is considered a renewable energy source and is priced at a premium.
The volume of waste coming into the facility is reduced by 90 percent through the EFW process and is in the form of either bottom ash or fly ash. The bottom ash is disposed of in a landfill, although the facility has been and continues to look for other uses for it such as an additive to asphalt or in building materials. The facility is working with McMaster University researchers on developing a high-value use for the bottom ash.
The fly ash, by regulation, is considered hazardous and is managed at a hazardous waste landfill.
The facility is currently in the planning stages of an expansion which would involve the addition of more combustion units and an upgrade of its air pollution control system. The plans also include an alternative use of the energy recovered from the waste – the production of hydrogen fuel for the trucks that bring waste to the facility.
The facility is working with researchers at the University of Waterloo and a partner in the automotive industry to work out the details of hydrogen generation and use as a fuel for the trucks the off-load waste at the facility on a daily basis. Preliminary economics and environmental analysis indicate that this is a much more effective use of the heat obtained from the EFW facility.
The Emerald EFW is a shining example of EFW done right in Canada. It has been an underappreciated harbinger what can be accomplished at municipalities throughout the country.
https://advancedwastesolutions.ca/wp-content/uploads/2020/12/emerald-efw.png279596John Nicholsonhttps://advancedwastesolutions.ca/wp-content/uploads/2018/09/coollogo_com-184851434-300x23.pngJohn Nicholson2020-12-02 04:22:082020-12-02 04:23:34Circular economy approach at Emerald Energy from Waste
Conservationist group #SeaTheBiggerPicture Ocean Initiative (#STBP) and engineers from Matriarch Generic Engineering have developed a giant vacuum cleaner that picks up trash and sieves out microplastics from the beaches of Cape Town in South Africa.
Called the Enviro Buggy, it sieve out microplastics, pieces of plastic that have broken down and now are smaller than 5mm, from ordinary beach sand. It would take humans days to do the same using manual methods.
“The Enviro Buggy was born out of a necessity. We were fed up with trying to pick up so many tiny degraded particles of plastic. It was near impossible by hand, even with a large-scale crew,” said Tash Krauss, a conservationist at STBP.
Waste Management Canada is planning on seeking the approval of the Ontario Ministry of Environment, Conservation and Parks (MECP) to expand its landfill operation in southwestern Ontario. The existing landfill, which opened in 1972 is expected to reach capacity in 2032. If the MECP grants the company the right to expand, it will be possible to keep the landfill in operation until 2044.
As reported in the Sarnia Observer, the Mayor Jackie Rombouts of Watford Township (the municipality in which the landfill is located) stated the announcement of the expansion plans by Waste Management Canada was not welcome news. “Obviously, it’s not something that our community wants,” she said in an interview with the Sarnia Observer. “We were looking forward to the end of this.”
The township receives landfill royalties, based on the amount of waste entering the site, that totalled about $4.4 million in 2019. The initial concerns expressed by the municipality was the potential of 12 more years of truck traffic in the area and nuisance issues (i.e., odour and noise).
The company has started the long process of getting approval for the expansion by initiating an environmental assessment (EA). An EA sets out a planning and decision-making process so that potential environmental effects are considered before a project begins. It requires that the company seek input in the planning process from a variety of stakeholders including the local government, neighbours, indigenous groups, and others.
As reported in the the Sarnia Observer, Wayne Jenken, area landfill manager for Waste Management, said the environment assessment process is expected to take about five years and cost more than $35 million. The typical timeline for an EA landfill expansion, from start to finish, is typically between three to five years.
The proposed expansion will not involve an expansion in the existing landfill’s footprint. Instead, the proposal calls for modifying the side slopes of the landfill as well as increasing its existing height. Currently, the landfill site takes up approximately 300 hectares. Of that, about 100 hectares are currently approved for landfilling. If the expansion is granted, the maximum increase in the final height of the landfill could be 40 metres.
The remaining capacity of the existing landfill is Approximately 15 Million cubic metres. The proposed expansion would provide additional airspace of up to approximately 14M m³.
One of the factors working in favour of the proposal getting approved is that fact that it is very difficult to get EA approval for a new landfill in the province, especially with new requirements that allows municipalities more say in the approval of a new landfill in their boundaries. Also, study after study has shown that there is a dearth of landfill capacity in the province.