Can more recycling be a bad thing? Why including more materials in the recycling bin will do more harm economically, environmentally and socially

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Written by Calvin Lakhan, Ph.D., Faculty of Environmental Studies at York University

In a recent review of New York State’s proposed Extended Producer Responsibility (EPR) legislation, I was taken aback by the sheer number of materials that were included (more than 30 individual materials in all) – it included everything from the conventional (newsprint, magazines, corrugated cardboard, aluminum cans) to the obscure (Multi-layered and flexible packaging made out multi resin products like LLDPE, PCV and PS), and even things we know not to be recyclable (BPA, Compostable Plastics, Polycarbonate and Lexan).

While surprising, I can’t say that it was entirely unexpected. New York State is merely following the lead of jurisdictions such as Ontario, which have decided to adopt the “Kitchen Sink” model towards printed paper and packaging recycling, and attempt to recycle everything, everywhere, in order to make recycling simpler for households.

It’s an extremely easy story to sell to the public, more recycling is obviously good, and the companies who produce the packaging will need to figure out a way to recycle it effectively. While the latter comment touches on the topic of extended producer responsibility, which is not what this article is about. Rather, I want to remind readers that not all recycling is created equal, and the “Kitchen Sink” approach being proposed by New York State (and other jurisdictions), is not sustainable, and unequivocally does more harm than good – economically, environmentally and even socially.

The endogeneity hypothesis  

Whenever I refer to the “endogeneity hypothesis”, I am often met with blank stares. In its simplest terms, endogeneity (in this specific context) refers to when variables within a system are interrelated – the existence of variable A, impacts variable B, which in turn, affects variable C. This is a gross oversimplification of a rather complex issue, but I do so to illustrate a broader point: What we decide to accept in our recycling bin will not only influence our ability to recovery these materials economically, but also affect the recycling performance of individual materials that make up the recycling program.

What policy makers and advocates of the “Kitchen Sink” approach fail to recognize is that waste management infrastructure (including the development of downstream processing and end use applications) was largely designed around “core materials” – These materials, which are characterized by high levels of recyclability, stable revenue, strong end market demand and are accepted in most municipal recycling programs: Newsprint, Other Paper (Magazines, Office Paper etc.), Corrugated Cardboard, Boxboard, Gable Top Cartons, PET bottles, HDPE bottles, Aluminum Cans, Steel Cans, and Glass* (glass cullet is generally not considered a core material due to poor end market demand). While the proliferation of light weight and composite packaging has spurred innovation in the waste management sector, it would be a gross overstatement to say that these materials are readily recyclable. Recycling of flexible plastic and composite plastic packaging in particular are still in its most nascent form – research for this article could only find a handful of pilot projects (across North America) where recyclers are accepting composite and flexible packaging to be tested for chemical recycling and waste to fuel.

But what does any of that have to do with the “endogeneity hypothesis”? For every additional “non-core” material added to the recycling program, not only do the costs of the entire program go up, the costs of managing individual materials within the program go up. Materials that are difficult to sort and/or recycle have an adverse impact on all other materials being managed within the same system – this is particularly true of single stream recycling systems. The more materials accepted by a program, the greater the number of types of materials inbound into a material recycling facility. If a MRF is not configured or cannot be readily retrofitted to efficiently sort materials that fall outside of the “core material” categories, it increases both the sort time and cost of managing *all* materials, irrespective of whether it is newsprint or a multi-laminate plastic.

In essence, the decision to attempt to recycle everything not only radically increases the costs of a recycling system that was never intended to capture these materials, but it poses an externality on the materials that were already being recycled. It makes the cost for all participants within the system more expensive, a somewhat perverse outcome given that we are trying to encourage producers who use readily recyclable packaging.

What are we trying to achieve again?

When writing these articles, this is a question that I often return to – largely because I don’t think a clear answer has emerged. Based on what I am seeing in the latest legislative developments in both Canada and the United States, it appears as though increasing recycling rates may be the end goal. It’s a “Do good, feel good” activity that people can readily get behind – I agree with half of that statement.

It certainly is a feel good activity, but whether it “does good” is highly questionable. I have repeated time and time again that not all recycling is created equal – decision makers are not oblivious to this, as there was a time when certain municipalities were considering *contracting*the list of accepted materials due to the issues that it posed within the recycling system.

So why the sudden 180 degree turn – in fairness, one part of that is consumer driven. Telling households not to recycle is walking back on years of environmental messaging, and can serve as a significant source of confusion/contradiction. The second part has to do with “who pays for the system”. Municipalities were very interested in booting materials out of the Blue Box when they paid for half of the cost. However, under a 100% EPR system, the same people who wanted me to find out how to get LDPE film and Polystyrene out of the program, are now calling for producers to pay their fair share for keeping materials out of landfill.

Not all recycling is created equal

While I obviously have very strong feelings about the appropriateness of EPR for PP&P, and the efficacy of recycling in general, I want to leave you with the following. One is a tool that I had developed several years ago that allowed users to enter in either a goal recycling rate, or a goal carbon abatement target, and the model would automatically find the lowest cost way to achieve it by prioritizing the recovery of specific materials. The data is a bit outdated (2018), but the overall finding remains unchanged – it isn’t how much we recycle that matters, it’s what we recycle. The “optimized” scenario actually found that maximum carbon abatement was achieved by recycling *less* (in absolute tonnes) than what we do today, and at a lower cost. There is a decoupling of recycling rate performance and environmental impacts – no longer is recycling directly correlated with carbon abatement.

Beyond this tool, I also want to provide a material evaluation matrix that looks at the characteristics of each material being considered in the New York State EPR program. Please note that I have grouped all the sub-categories (i.e. flexible PET, flexible PP, Flexible PS) into one container category (flexible packaging). As best I could, I tried to mirror the proposed list to the ones we use in Ontario – the reason for that is that I wanted to give actual data for what the quantities and costs of recycling are in a program that has already implemented EPR.

The criteria I used to evaluate materials are based on:

·        recovery rate,

·        revenue received (using Ontario price sheet)

·        cost of recycling, (using the SO Pay in Model)

·        Is the material accepted in most programs?

·        Is there available recycling infrastructure?

·        Is there end market demand?

·        Carbon abated per tonne recycled (by material) (EcoInvent)

·        Carbon impacts per tonne landfilled (by material) and  (EcoInvent)

·        Money spent on recycling to abate one tonne of carbon (by material).

I have always felt that the last metric is the most important – how much would you have to spend recycling something in order to abate one tonne of carbon? If you refer to the second worksheet (“Cost of Carbon”) it quickly becomes apparent that some materials make virtually no sense to recover given how much you have to spend to achieve a given environmental goal, i.e. $1856.14/TCO2e for plastic laminates.

It is critical that decision makers use data and evidence to guide their decisions, and not rely on emotionally or politically driven narratives. Jurisdictions are tripping over each other trying to push forward with EPR legislation for packaging waste, but it is of paramount importance that we proceed with caution and question the approach we are taking and explore potential alternatives. Producers also need to understand that EPR systems prioritizing recycling based outcomes is likely to have many adverse impacts that need to be better understood. Now more than ever, producers cannot resign themselves to playing a passive role in legislative discussions.

Recycling is a wonderful thing, but it is not the only tool in our tool box. In fact, it should be one of our last resorts when we cannot find ways to achieve waste reduction (i.e. package light weighting) or adopting systems that make reuse easier.

There will be many people that disagree, but I encourage you all to look at the data, and see what conclusions you reach.







Why expanding the list of acceptable Blue Box materials hurts more than it helps


Written by Calvin Lakhan, Ph.D, Co-Investigator: “The Waste Wiki” – Faculty of Environmental Studies at York University

Preface: For readers outside of Ontario, the Blue Box refers to the province’s residential recycling program for printed paper and packaging.

What is being proposed?

On October 19, 2020, Ontario’s Ministry of the Environment, Conservation and Parks released a proposed regulation to govern the Ontario Blue Box program under the Resource Recovery and Circular Economy Act, 2016 (the RRCEA). The regulation will transition Ontario’s blue box recycling program for printed paper and packaging to full extended producer responsibility (EPR).

The proposed regulation expands the list of acceptable Blue Box materials to include “packaging-like products” and certain single-use items. Examples of packaging like products include: aluminum pie plates, tin foil, plastic wraps and food trays, plastic cutlery/plates and single use drink containers.

The intent of this change is three fold: 1) By including packaging-like products, the regulation targets items that so far have been free riders in Ontario’s Blue Box system. 2) Reduce public confusion regarding what is considered an acceptable Blue Box material in their jurisdiction. The proposed change will standardize accepted Blue Box materials, with the same set of materials being collected throughout the province 3) Move towards harmonizing approaches to managing packaging waste at a national level – British Columbia has announced plans to include single-use and packaging-like products in its list of obligated materials by 2023

What is the issue?

The MOECP’s decision to expand the list of acceptable Blue Box materials to include “packaging like products” is inconsistent with previous direction from the province and contradicts the messaging surrounding the federal single use plastics ban.

Prior to the transition plan, municipalities actively discouraged accepting packaging like products in the Blue Box. The primary concern expressed by municipalities was that it was extremely difficult, if not impossible, to recycle many of these materials. The costs associated with attempting to collect and recover packaging like products was prohibitive, and could not be rationalized given that these materials were often treated as contamination (both at the material recycling facility, and downstream re-processors), and subsequently disposed of.

Under a full EPR system, wherein packaging producers assume 100% of the physical and financial responsibility for managing packaging waste at end of life, the messaging surrounding packaging like products has now changed. While the infrastructural and technical barriers to recycling these materials remains unchanged, who pays for it has. The potential costs to producers is significant, as none of the pre-requistes for effectively recycling packaging like products are in place – there is limited infrastructure, no viable end markets and no end use applications for these materials.

With respect to the federal directive to ban single use plastics, Ontario’s decision to try and include these items as part of the Blue Bin program is perplexing. Allowing households to place single use packaging in the Blue Bin erroneously suggests that these materials are going to be recycled. As a result, the public receives two conflicting messages – the federal government is saying that single plastics should be banned due to their lack of recyclability and impact on the environment, while the provincial government is saying to include these materials as part of the residential recycling program.

Consumers already struggle with differentiating between what products can be recycled, and what cannot. Consumers have also expressed skepticism as to whether the materials that are collected are actually recycled at all. With this in mind, the decision to include packaging like materials as part of the Blue Box program is likely to exacerbate uncertainty, and serve to undermine the efficacy and credibility of the federal single use plastics ban.

It is the university’s assertion that expanding the list of acceptable materials will result in adverse economic, environmental and social outcomes for Ontarians and lead to consumer confusion regarding what materials are actually recyclable.

What will this cost?

Quantifying the economic impact of expanding the list of acceptable Blue Box materials is enormously challenging, largely because the vast majority of packaging like products cannot be recycled in our existing system. Further complicating matters is that we don’t have a clear understanding of the quantities of packaging like products that are being generated in the province – in short, there is not enough data at this time to make informed policy decisions.

With that in mind, this section attempts to model a scenario using best available data that is intended to provide directional guidance as to what this change will cost. Additional research needs to be done in this area as better data becomes available.

Note: The data used in this section is based on the Stewardship Ontario Pay in Model (used as an analog to estimate net costs per tonne for packaging like products) and 55 waste audits conducted throughout Ontario, between the periods of 2015 and 2020. Audit data is used to estimate the quantities of packaging like products that are being generated by households each year.

Based on the waste audit data, Ontarians, on average, generate approximately 567kg of waste per household every year (Note: Estimates range from as little as 411kg/hh to more than 740kg/hh depending on where the audit was conducted). Overall residential waste generation in Ontario, based on a population of 5,169,175 households, is 2,933,196.66 Tonnes.

Of this, packaging like products makes up approximately 4.01% of all waste generated. Table 1 below provides a detailed breakdown of waste composition, as well as net cost per tonne to manage these materials as part of the Blue Box.

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Weighted Average Net Cost Per Tonne: $2002.52/T

% of Packaging like products of overall waste: 4.01%

Based on our aggregated audit data, 39% of packaging like products are found in the recycling stream (Blue Box), 8% in the Organics Stream (Green Bin) and 53% in the garbage stream (Trash)

Using the above data, we can now estimate what the potential cost would be if Ontario were to move forward with the decision to include packaging like products as part of the Blue Bin. To reiterate, these numbers should be interpreted with caution due to the paucity of available data. This modeling assumes that the material analogs we have taken from the PIM model, accurately reflect packaging like products. We also assume that packaging like products are being recycled, as opposed to being screened as contamination and subsequently discarded. The results of this analysis are shown in Table 2 below:

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Are there environmental benefits?

In light of the enormous costs attributable to expanding the list of acceptable Blue Box materials, it seems prudent that we evaluate the environmental benefits of this decision. The increase in costs could potentially be rationalized if it yields a more sustainable outcome (in this context, we refer to environmental sustainability)

Unfortunately, the inclusion of packaging like products in the Blue Bin does not mean that these materials will be recycled. Based on available infrastructure, processing technology and end markets, there is a very strong likelihood that these materials will be treated as contamination (either at the MRF, or at the processor) and subsequently discarded.

If the landfill is the likely outcome for these materials, it begs the question, “What are we trying to achieve?” At this juncture, it’s not entirely clear what expanding the list of Blue Box materials achieves other than a higher cost for producers (and subsequently, a higher cost for households).

While proponents of this legislative change will cite that packaging producers will have the ability to innovate and develop new end markets and end use applications for these materials, there is very little evidence (if any) of that occurring. Policy makers often erroneously assume that packaging producers have a significant degree of autonomy and control regarding what happens with their products at end of life. The reality is that the vast majority of CPG companies are “market takers”, subject to macro-economic conditions that ultimately determine the value and recyclability of a particular material. In short, if a material had inherent value at its end of life when recycled, then markets would already exist for these materials. Forcing packaging producers who operate in Ontario to invest and develop the infrastructure to recycle packaging like products places them at a distinct disadvantage, as they are incurring an additional cost to manage and recycle materials that would not be recovered if left to a free market.

An argument could even be made that the decision to include packaging like products as part of the Blue Box yields an inferior environmental outcome relative to landfilling. Based on the modeling shown in Table 2, we estimate that the decision to include packaging like products would result in an additional 45,872.26 tonnes being managed as part of the Blue Box system. These are materials that would ultimately have to be collected, transported and sorted – all of which have a carbon impact associated with each activity. For context, GHG impacts of recyclable collection and sorting (at the MRF) makes up approximately 19% of the total carbon footprint of recycling activity. If packaging like materials are ultimately sent to disposal due to a lack of adequate infrastructure or end market demand, then the province’s decision would have actually added GHGs to the environment, not prevented it.

Whatever environmental benefit that may result from including packaging like materials in the Blue Bin is predicated on these materials actually being recycled. Both the public and policy makers need to understand that diversion/recycling is not based on the quantities of collected material inbound to a MRF – at present, recycling is defined as baled and marketed material. In the absence of end markets for packaging like materials, what does the province think is going to happen to the material that is collected?

Caveats to this analysis and key considerations

To reiterate, the estimates used in this analysis use the costs associated with attempting to actually recycle packaging like products. Given that these materials are not actually recyclable in the given system, we have used cost analogs taken from the Stewardship Ontario Pay in Model. Numerous parties (including the university) have expressed concern regarding the accuracy and validity of the data found within the PIM model, but at this juncture, there is no alternative source that can be publicly referenced.

If packaging like products were to be included as part of the Blue Bin, the most likely scenario is that the vast majority of the material is going to be screened and end up in landfill. Even in this scenario, producers would be obligated to pay for the costs of collecting, sorting and disposal – while significant, the only credible way to estimate what this would cost would be to conduct an activity based costing study.

In a review of the proposed changes being put forward by the MECP, there are two key takeaways are: 1) What are we trying to do? If these materials can’t be recycled and ultimately be discarded, why bother including them to begin with? The decision to do so would result in industry spending millions of dollars to achieve an outcome that is no different than what is happening today.

2) At this juncture, there is insufficient data regarding how much of these materials are being generated, where it ends up, and what it costs to manage them. Given the degree of uncertainty surrounding the credibility of the data, it would be in the best interest of all stakeholders for the government to defer the decision to include packaging like materials in the Blue Box (until the potential impacts are better understood).


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.

Ontario looking to revamp recycling and plastic waste programs


The Ontario government recently appointed a special advisor to assist in revamping the Province’s recycling programs.

The Ontario government has engaged David Lindsay, currently the President and CEO of the Council of Ontario Universities, as a Special Advisor on Recycling and Plastic Waste prepare a report by the end of the summer on how to tackle plastic waste and litter, improve recycling, increase products that can go into the blue box, and ensure producers are responsible for managing plastic and other packaging at end-of-life.

Ontario Environment Ministry, Rod Phillips, stated in the news release that he was engaging Mr. Lindsay in an effort to find solutions to the Province’s languid recycling rates. The current Blue Box Program has been in place since the 1980s and had world-renowned success in recovering residential printed paper and packaging for recycling. However, Ontario’s waste diversion rates have stalled at just over 60 per cent for the past 15 years.

“Ontario families take pride in doing their part for the environment. In fact, our own city of Kitchener was the birthplace of the world’s first Blue Box program,” said Minister Phillips. “Knowing this, I was disappointed to learn that, while Ontario families work to sort and recycle properly, government and industry are failing them. Ontario’s recycling rates have been stalled for 15 years and up to 30 per cent of what is put into blue boxes is sent to landfill. Not to mention, recent stories highlight how some of Ontario’s plastic waste is being unsustainably shipped across the ocean to the Philippines and Malaysia.”

In the open-facing letter to the Special Advisor, the Environment Minister has requested that work be guided by the following public policy objectives:

  • Standardization across the province of what can be recycled in offices, parks, public spaces and homes;
  • Improve diversion rates and increase what materials can be recycled;
  • Reduce litter and waste in communities and parks;
  • Improve Ontario’s Blue Box Program by requiring producers to pay for the recycling of the products they produce, through achieving producer responsibility;
  • Maintain or improve frequency of Blue Box collection; and
  • When increasing diversion in the residential sector, consider how these policies can also enable diversion in the institutional, commercial and industrial sector.

As Special Advisor, Mr. Lindsay has limited direct experience with waste issues. Prior to his current role as the President and CEO of the Council of Ontario Universities, he was President and CEO of the Forest Products Association of Canada and of Colleges Ontario, an advocacy organization for the province’s 24 colleges of applied arts and technology. Mr. Lindsay has experience in the Ontario Public Service previously holding the position of Deputy Minister for the Energy and Infrastructure, Northern Development, Mines and Forestry, Natural Resources, and Tourism and Culture portfolios.

David Lindsay

“I’m looking forward to helping Ontario’s municipalities and producers work together to address plastic litter and improve recycling in our province,” said David Lindsay. “Having stakeholders come together to identify concerns and find solutions will be integral to reinvigorating the province’s Blue Box Program and solving the problem of plastic litter and waste.”

In the Made-in-Ontario Environment Plan, Ontario committed to transitioning the costs of the Blue Box Program away from municipal taxpayers to make the producers of products and packaging fully responsible. Shifting to producer responsibility will obligate producers across the province to pay for and manage their materials. Based on 2017 costs, municipalities would save about $125 – $175 million annually once full producer responsibility for the Blue Box Program is put in place.

Reducing plastic waste and litter and making producers responsible for the end-of-life management of their products is a key part of Ontario’s Made-in-Ontario Environment Plan.

Survey suggests some Ontario Municipalities are open to hosting a landfill

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A recent survey of municipal politicians and Chief Administration Officers commissioned by a coalition of over 70 Ontario municipalities has found that four in ten municipalities are open to the idea of acting as a host to a new landfill.

The coalition was formed to lobby the Ontario government into allowing more municipal control on the approval process for landfills in the Province. The coalition calls itself the Demand the Right Coalition of Ontario Municipalities. It commissioned Public Square Research to conduct the survey.

The survey involved a random selection process, with 325 participants. Invitations to participate in the survey were sent to a list of over 1,700 Mayors, Reeves, Councillors and chief administrators in Ontario.

Currently in Ontario, a private sector company is required to go through an environmental assessment process and then a technical environmental approval process before being permitted to develop a landfill site. Both of the processes are managed by the Ontario Ministry of Environment, Conservation, and Parks (MOECP). No municipal approval is required.

The current timeline for approval for a new landfill in Ontario is anywhere from five to ten years. Extensive public consultation is required as part of the process as is discussions with municipal government officials. Many private sector proponents would likely see another level of government approval for landfill development as an added time and cost burden with very limited environmental benefit.

In November 2018, the Ministry of the Environment, Conservation, and Parks published its Made-in-Ontario Environmental Plan. The plan included a proposal to provide municipalities with the right to approve new landfills. Further details of the proposed change were released for public comment in the follow-up Discussion Paper on Reducing Litter and Waste in Our Communities, published in March 2019.

The results of the survey found that the chief concerns of municipal leaders for new landfill approvals are environmental (27%), site location (19%), and financial considerations (15%). Other issues of importance included resident opinion (9%), odour controls (9%), and public safety (8%).

“We can now confirm that municipal approval will improve landfill operations, not eliminate them,” said Ted Comiskey, Mayor of Ingersoll and Chair of the Demand the Right Coalition. “By placing municipal governments on a level playing field with private waste management companies, councils and staff can negotiate for enhanced environmental protections, better site selections, and improved financial considerations on costs such as tipping fees and municipal services.”

Comiskey said, “Municipalities want the right to say yes or no, as we do with casinos, cannabis stores, and nuclear waste sites. This will be good for all concerned, as it means that communities will be given real choices. There will also be a cost impact on waste management. If the cost of landfill goes up, there will be a financial incentive for everyone to reduce their waste. Currently, there is none.”

70 Ontario municipalities are members of the Demand the Right Coalition


Ontario Government issues Waste Reduction Discussion Paper

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The Ontario government recently released a discussion document entitled
Reducing Litter and Waste in Our Communities: Discussion Paper
, which reaffirms the Province’s commitment to the 3Rs and diversion from landfill including Ontario’s curbside Blue Box Program, municipal green bin programs for organics, and other waste recovery options.

The 29-page discussion document expands upon the commitments made by the Ontario government in December 2018 when it released Preserving and Protecting our Environment for Future Generations: A Made-in-Ontario Environment Plan. The paper poses questions that will help guide future decision-making to divert more waste from landfill.

The Discussion Paper acknowledges that existing and emerging technologies are increasingly allowing society to recover and recycle materials back into the economy rather than sending them to landfill. This is helping society to better protect communities and keep the air, land and water clean and healthy.

The discussion paper outlines eight key areas for action:

  1. prevent and reduce litter in our neighbourhoods and parks
  2. increase opportunities for Ontarians to reduce and divert waste at home, at work and on the go
  3. make producers responsible for the waste generated from their products and packaging
  4. reduce and divert food and organic waste from households and businesses
  5. reduce plastic waste going into landfills and waterways
  6. provide clear rules for compostable products and packaging
  7. recover the value of resources in waste
  8. support competitive and sustainable end-markets for Ontario’s waste

These eight areas of action are the steps the the government will take to make waste reduction, reuse, and recycling easier.

One key aspect of the discussion paper is the commitment by the government to making producers responsible for the waste generated by their products and packaging, encouraging them to find new and innovative cost-effective ways to recycle their products and lower costs for consumers. If the proposals in the discussion document are implemented, the transition to extended producer responsibility will increase the amount of household material recycled, while shifting the cost of recycling from municipalities – and taxpayers – to producers.

The discussion paper sets out goals, actions and performance measures and outlines how the government will decrease the amount of waste going to landfill and increase the province’s overall diversion rate.

The discussion paper is posted on the Ontario Environmental Registry for public comment. The deadline for public comment is April 20th 2019. The government states that the feedback on the discussion paper will help the province to move forward with a clear, comprehensive and outcome-based approach to reducing litter and waste.

Nova Scotia amends rules to allow waste-to-energy projects

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The Government of Nova Scotia recently gave the green light to waste-to-energy projects in the province. Nova Scotia’s solid waste regulations have been amended to allow thermal treatment facilities to turn plastic, cardboard and newsprint into energy. The changes clarify that the province considers energy recovery as waste diversion.

All waste-to-energy facilities will require an environmental assessment and industrial approvals before going ahead.

A potential benefactor of the amended regulation is Sustane Technologies based in Chester, Nova Scotia. The company is in the process of constructing a waste-to-pellets facility. Sustainable Development Technology Canada (SDTC) provided $2.6 million in funding assistance in 2017 for the development of the facility.

At the media event in 2017 announcing the SDTC funding award, Leah Lawrence, President and CEO of SDTC, stated: “Sustane’s first-of-its-kind technology converts waste into useful products like synthetic diesel and recycled metal and plastic, potentially eliminating the need for landfills. This Nova Scotia–based company’s technology has applications around the world, and SDTC is proud to be its partner.” 

When fully constructed and operational, the plant will transform up to 70,000 tonnes per year of MSW into 35,000 tonnes per year of biomass pellets, 3.5 million litres per year of diesel fuel, plus recyclable metals.  The project will increase landfill diversion rates for Chester, Valley Waste Authority (Annapolis Valley) and Municipal Joint Services Board from approximately 50% to over 90%.

The project broke ground in March 2017 and is currently undergoing testing with full operation expected in Q1 of 2019.

A waste audit in 2017 by Divert Nova Scotia found 43 per cent of the garbage being sent to landfills is banned material that could have been composted or recycled. 

According to the province’s news release, recyclable materials will still be banned from landfills.

“Nova Scotians are national leaders in waste diversion, but there is still more we can do to keep waste out of our landfills,” Environment Minister Margaret Miller said in a news release. “We want Nova Scotians to continue to recycle and compost, but we also need to ensure we’re doing all we can to reduce our footprint. This will give new businesses the chance to create something useful from waste destined for landfills.”

Gordon Helm, Chief Technical Officer at Fourth State Energy & Nova Waste Solutions Inc., said “This is very exciting news for Nova Scotia, and the government’s stated intention to modernize our solid waste resource management regime. It’s a major step in reducing the harmful environmental impacts of active landfilling and the generations of emissions of methane GHG and the production of millions of litres of toxic leachate.”

Mr. Helm added, “Advanced thermal conversion technologies are a proven, cost effective, and energy efficient alternative to landfills and incineration. We can and need to continue to do more in terms of reducing waste resources, but waiting for the all or nothing solution is not the answer … In the end, any solution that moves us towards ending active landfilling is a worthy effort.”

Nova Scotians, on a per capita basis, send the least amount of waste to landfill – 404 kilograms of waste per person per year. The national average is 688 kilograms of waste landfilled per person per year.

Cutting the Waste: How to save money while improving our solid waste systems

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by David McRobert, Environmental Lawyer and Advisor

Canada’s Ecofiscal Commission (EFC) recently released a report on cutting municipal solid waste (MSW) by promoting incentives and market-based policies. Accordingly, municipalities should implement “pay-as-you-throw” (PAYT) programs for residents and higher “tipping fees” for business. As well, provinces should implement “extended producer responsibility” (EPR) programs.

Are user pay instruments such as PAYT programs and related policy tools the magic bullet that can solve our municipal solid waste problems and reduce the MSW quantities flowing to landfills and energy from waste (EFW) sites? Regrettably, if we have learned anything in the past twenty-five years with respect to MSW in Canada there probably are no easy answers on reduction, reuse and recycling (3Rs) of solid waste.  To my mind, there are just difficult choices that will require combinations of government, municipal, community and corporate mechanisms and policies such as improved enforcement by regulators, user pay, increased producer responsibility, greater corporate social responsibility, improved public education, technological changes and packaging material and equipment innovations.

For example, increased tipping fees seem like a logical policy tool to target and reduce wastes produced by industrial, commercial and institutional (IC&I) generators. However, in the post-US-Canada Free Trade Agreement era (FTA, 1988) and then under the North America Free Trade Agreement (NAFTA, 1993) municipal solid wastes, recyclables and some hazardous wastes have flowed much more freely between national, provincial, state and municipal boundaries on the North American continent.

In 1988, I was part of an advisory group that strongly recommended the City Toronto implement significant increases in tipping fees, from $17/tonne to $150/tonne in 1990 – to support 3Rs. At the time, the US border was closed to Canadian municipal solid waste (MSW) unless it was incinerated in the USA. At the time, Halton Region had run out of landfill space (and would struggle for more than 16 years to site a new landfill as OMOE regulators kept changing the goalposts).  Consequently Halton Region was shipping its MSW waste to Hooker Chemical in Niagara Falls, New York where it was incinerated for – surprise, surprise — $150 a tonne. So this seemed like the right number.

No doubt $150 a tonne seemed like a bonanza to some haulers in Canada and the US and landfill operators in nearby states. The multinational garbage companies lobbied to get the US border restrictions lifted and in 1991 Ontario’s MSW, especially its IC&I wastes, began to flow to the US for as low as $30/tonne. To facilitate the new collection-transfer-shipping system, makeshift transfer stations also were established in empty industrial buildings and on farmer’s fields in the Greater Toronto Area (GTA).  In short, we created an enforcement mess for Ontario Ministry of Environment (OMOE).

Between 1991 and the late 2000s, hundreds of thousands of tonnes of Ontario’s MSW flowed into landfills in Michigan, mainly ones that were scheduled to be closed because of strict rules implemented after 1991 (and phased) in by US EPA on landfill standards under Title D. By the mid 2000s the US and Ontario media began to track this ongoing and intriguing export issue. Historically Canada mainly had shipped raw materials such as wood, paper products, minerals, aggregates and other resources to the USA. This was something different. Inevitably, there were a couple of incidents graphically reported in the media when giant transport trucks from the GTA were involved in serious accidents, dumping their smelly and messy loads on highways and roads in Michigan. As expected, a strong No Ontario Garbage in My Backyard (NOGIMBY) emerged out of dust and the fumes. This made for great TV and was early fodder for social media banter and colourful photo exchanges.

Governor Jennifer Granholme and other state legislators, then campaigning for re-election in the State of Michigan in the 2006 US midterms, fought back claiming that the GTA’s MSW was full of soft drink containers and used smoke and CO2 alarms (with small amounts of radioactive wastes) and that its import should be banned because these materials supposedly were banned from Michigan’s landfills. Upon taking office in early 2007, the Michigan Legislature managed to stop the flow of Ontario’s MSW into the state’s landfills. This forced Toronto to purchase the Greenlane landfill near London, Ontario in the late 2000s for its MSW. However, Industrial, Commercial, and Institutional (IC&I) waste is still trucked from Ontario to Michigan landfills. In sum, tipping fees proved a challenging tool to use. Cooperation between provincial, state and federal regulators in the US and Canada undoubtedly will be required to make this instrument work well.

In 1993 I drafted a discussion paper on PAYT programs for the OMOE. Our research at the OMOE showed that PAYT programs can encourage scofflaws to “throw without paying” (TWP) in farmer’s fields and forests requiring municipal staff to become garbage detectives.

In 1994, I prepared a summary of my OMOE discussion paper and related research for a seminar on user pay I conducted for several environmental non-government organizations (ENGOs). I also used the 1994 paper for teaching Environmental and Administrative Law (as well as Waste Management Law and Policy) at Osgoode Hall Law School, the University of Toronto and York University between 1990 and 2009. My 1994 brief can be found below.  Although the discussion paper is over 20 decades old, it is uncanny how most of the issues raised back then are still current today.

Discussion Paper: User Fees for Waste Management – Issues and Options (1994)


A. Introduction

In the United States and Canada, most industrial, commercial and institutional (IC&I) waste generators are charged for waste services on the basis of the quantities of waste that they produce. In contrast, the vast majority of householders are not charged user fees. Instead, residential waste management services are financed through property taxes, provincial grants and subsidies, and revenues generated from the sale of secondary materials. Therefore the user of the service often does not directly pay for the service.

B. The Trend Towards User Fees

In the past five years, many Ontario municipalities have considered charging users for waste management services. Between late 1988 and early 1993 approximately 10 different municipalities asked the provincial government for clarification of these powers in the Ontario Municipal Act.(see Note 1) Most municipalities that have examined or implemented user fees are small and ethnically uniform; larger municipalities that have considered user fees include Peterborough and Ottawa.

In 1993 the Ontario government passed Bill 7 amending several parts of the Municipal Act to give municipalities the authority to implement user pay systems for financing waste management if they choose to do so. It is likely that in the coming years Ontarians will see introduced an increasing number of municipal user pay systems.

  1. The Supposed Benefits of User Fees

According to proponents, the main advantage of user fees is that generators are provided with a direct financial incentive to reduce their waste. In other words, the less garbage a household or IC&I user generates, the less it would pay for disposal.  Another advantage is that householders become keenly aware of the major sources of residential waste, and adjust their purchasing habits accordingly.

There also can be significant cost savings to municipalities. In many communities with a generator pay system in place, it has been found that residents pay less for the collection and disposal of solid waste after the systems are implemented.

  1. Experience in Ontario and U.S.

In the United States, a variety of user fee systems for household waste disposal services have been established in many jurisdictions. In most systems, the charges are administered on a per can or a per bag basis. However, in some cases, the generator can prearrange a certain specified level of service on a weekly or monthly basis.

In June 1990, Carlisle Borough, Pennsylvania (estimated 1990 population of 20,000) simultaneously implemented a per-bag waste collection fee and a borough-wide recycling program. Householders purchase 30-gallon garbage bags costing $2.10 each. Borough officials estimated that they recovered more than 30% of previously disposed recyclables during the first 40 weeks of the user-fee program’s operation, saving the Borough $83,504 in avoided disposal costs.(see note 2)

The Borough of Perkasie in Pennsylvania implemented a volume-based bag program in January 1988 for its 6,000 residents. Residents buy bags capable of holding 40 pounds for $1.75 and smaller, 20 pound capacity bags for $1.00. The program has assisted the Borough in achieving a significant diversion rate; between 1988 and 1992, the quantity of waste being recycled increased by 49% (by weight). Similarly, the quantity of waste being disposed at landfill declined by 51% (by weight).

In 1991, Gananoque, Ontario faced an increase in disposal costs of approximately $160,000 per year. In response, the Town started a mandatory tag system in July 1991 for an estimated 2,200 households. Tags cost $1.00, and only tagged bags are collected.

The Town had established a backyard composting program in 1990 and a recycling depot in March 1991. The depot takes in steel, glass, paper, aluminum, PET (polyethylene terephthalate), and old newsprint (ONP). A free tag is given out for every two bushels of recyclables delivered to the recycling depot.

Householder participation in recycling and source-reduction activities increased after implementation of the user fee system in July 1991. By March 1992, the Town had distributed 15,000 free bag tags through the recycling depot and recycling tonnages increased 175% compared with July 1991 (i.e., from 8 to 22 tonnes of recyclables/month). By April 1992, approximately 900 composting units had been distributed to 40% of the Town’s households. The user-fee program also resulted in a decrease of 45% in the amount of solid waste requiring disposal, and an estimated cost savings to the municipality of $216,000 in 1992.(see note 3)

Experience in Canada and the United States suggests that the more 3Rs options householders have to reduce their disposal costs, the more effective user fee systems will be in reducing waste.

C. Discussion

From an administrative viewpoint, funds raised by generator pay charges could be retained by municipalities or regions and then could be used to support development of local infrastructure.

The charge can be administered on a per can or a per bag basis, or the generator can pre-arrange/pre-select a certain specified level of service on a weekly or monthly basis. Obviously, the more options householders have to reduce their costs, the more effective the system will be in reducing waste. Householders will need access to composting and recycling, and they should also have the opportunity to choose a reduced level of service.

Some supporters of user pay for garbage argue that eventually it would be logical to require generators to pay nominal charges for recycling and centralized composting services to ensure that source reduction is maximized.

User fees for garbage usually are supported for the following reasons:

1) user pay seems to be consistent with the argument that polluters (including companies and consumers) should be made responsible for externalities when possible;

2) user pay does not seem to conflict with any of the policies and major programs of the Ontario Environment Ministry such as support for the Blue Box program. Moreover, it was seen as supportive of the home composting program;

3) in theory, user pay would encourage shifts towards the 3Rs by individuals and corporate entities;

4) user pay systems would be simple and cost-effective to administrate, and ideally could be integrated with existing federal, provincial and municipal financial, regulatory and institutional structures;

5) revenues generated could be retained by municipal governments to support the overall waste management system;

6) user pay does not raise all of the messy inter-jurisdictional, trade, political power, etc. issues related to most other (and in my opinion) better economic instruments (such as removal of subsidies to virgin material extraction); and

7) user pay seems to be consistent with the goal of disentanglement of municipal/provincial financing and responsibilities and off-loading of provincial programs onto municipalities.

Here are some of the other major policy issues that should be considered in discussing user pay options.

  1. Equity Issues

The most frequently raised issue with respect to generator pay or Pay as You Throw (PAYT) charges is equity. For example, it is argued that large families may be less able to cope with the additional cost of a generator pay system. Undoubtedly there is some truth to this argument; however, the proponents argue that inequities that would arise could be addressed through appropriate rebates to large or low-income families.

The permissive powers in the amendments to Ontario’s Municipal Act contained in Bill 7 [as it then was] will allow municipalities to exempt or reduce the fees charged to these types of households. In other words, at the Ontario Environment Ministry knew this was going to be a big political issues and designed the law to accommodate municipalities.

  1. Potential for Littering and Illegal Dumping

Municipalities often raise the concern that user pay schemes will result in illegal dumping. There is considerable evidence that PAYT programs can encourage scofflaws to “throw without paying” (TWP) in farmer’s fields and forests requiring municipal staff to become garbage detectives.

Proponents argue the issue that arises is a traditional deterrence argument: should the fact that a few individuals will break the law stop us from putting good laws into place?

In some municipalities, user fees and PAYT charges have increased illegal dumping of waste in commercial dumpsters and littering, particularly in the first year after introduction of user fees. Usually, these problems are addressed through public education, by imposing stiff fines against those caught dumping and by the locking of unattended dumpsters. However enforcement is difficult.

Successful public education campaigns against illegal dumping and littering have been launched in many jurisdictions in both the U.S. and Canada. To discourage illegal dumping in Perkasie, Pennsylvania, officials there publish the names of illegal dumpers in the local newspaper.

Advocates of user pay systems argue that public education could help control illegal dumping. However, in some jurisdictions with pay-by-the-bag systems, illegally dumping problems have not been entirely resolved. For example, in Nanaimo, BC user pay has increased the incidence of illegal dumping in the ocean and in wooded areas near the town.

  1. Dealing with Apartment Buildings

Another problem with implementing user pay is dealing with residents in apartment buildings. At present, garbage collection services for most apartment buildings are part of the cost of doing business for landlords and the cost is passed on to tenants. Thus, most apartment dwellers are, in effect, serviced by private hauling companies and these companies would be very happy to charge a user fee.

Conceivably, apartment dwellers could be required to participate. However, there is the technical problem of how and when a fee would collected (ie. each time they put waste down the garbage chute in their building?).

In large cities where single family dwellings and apartment buildings are scattered in residential districts one could imagine that administering user pay might create a nightmare for officials. There might be an enormous temptation for landlords to try to arrange user pay to gouge tenants and off-load the cost of garbage disposal onto tenants. In addition, there would be an equally great temptation for apartment dwellers to try to avoid the charges altogether. And this might lead to illegal dumping.

  1. Occupational Health and Safety Issues

Pay-by-the-bag user charges are opposed by the Canadian Union of Public Employees (CUPE), which represents between 1,500-2,000 municipal waste management workers in Ontario, because the charges tend to encourage people to increase the density of their garbage by compacting it (ie. to fit more into a bag or can). This could lead to an increase in occupational injuries (i.e. back problems) for CUPE workers. It is unclear if CUPE would support user charges if they are based on weight.

  1. User Pay Focuses on Consumers Instead of Producers of Packaging

Another argument that is made against user pay systems is that there is no direct pressure on the manufacturers of certain products to change their packaging. Many individuals feel trapped by a lack of choice with respect to packaging; they want to purchase a certain good or service but they cannot buy the product inn a reusable container at supermarkets.

In theory, user pay could result in the indirect pressure of consumers on manufacturers and distributors, which can be a powerful force. Market adjustments would certainly occur because supermarkets would begin to provide more bulk foods and reusable packages (smaller health food stores would pick up the slack if they did not) as cost conscious consumers began to demand them to reduce their generator pay charges. User pay also could encourage greater use of some difficult-and-expensive-to-recycle materials like plastics. This trend should be monitored to ensure that taxpayers don’t get saddled with the burden.

Moreover, the main benefactors of this shift will be better educated middle class consumers with time on their hands.

Based on current evidence, I would argue that user pay systems will have, at best, a marginal impact on encouraging product stewardship by manufacturers.

D. Conclusion

In sum, I think user pay systems have good potential to: 1) improve material recovery rates of recycling programs; and 2) increase diversion of waste from disposal in landfills or incinerators.

If user pay is adopted, then I agree with those who say that it should be extended so that charges are imposed for every pick up of blue boxes and and containers brought to centralized composting facilities.

My concern is that, in the absence of other policies to encourage product stewardship, user pay will not necessarily encourage a shift in waste management from recycling to waste reduction.

My guess is that large municipalities in Ontario will continue to avoid implementing user pay because of the difficulties associated with educating an ethnically diverse population and the great potential for increased littering and illegal disposal.

If user pay is worth supporting, I would suggest that the following configuration of measures would be optimal:

  • user pay fees for residential MSW disposal by weight. An appropriate fee should be between $1-2 per bag (about $1 for every 10-15 kilograms?).
  • user pay fees for Blue Box pick up by weight in the range of $0.50-75 for every 15-20 kilograms.
  • user pay fees for pick up of wet waste (food and leaf and yard wastes) for composting at residential dwellings to encourage home composting. However, in the short term it may not make sense to charge for use of centralized composting in the next few years to encourage development of this service in Ontario.


The following list of documents is incomplete but lists some of the key sources on user pay that could be consulted.

Association of Municipalities of Ontario (AMO)

AMO’s Response to RCO’s “Who Should Pay for Recycling?”. Toronto: AMO, January 1991.

AMO’s Policy Position on Reduction and Re-use. Toronto: AMO, June 1991.

AMO’s Response to Municipal Waste Management Powers in Ontario. Toronto: AMO, July 1992.

British Columbia Ministry of the Environment Guide to Establishing User Fee Systems for Solid Waste Management. October 1992. Victoria: BC MOE.

Canadian Institute for Environmental Law and Policy (CIELAP)

A Regulatory Agenda for Solid Waste Reduction, Report prepared for SWEAP by S. Shrybman. Toronto: Solid Waste Environmental Assessment Plan, Metropolitan Toronto Works Department, July 1989.

Looking Back and Looking Ahead: Municipal Solid Waste Management in Ontario From the 1983 Blueprint to 50% Diversion in 2000 — Conference Background Paper and Conference Report. Edited by M. Winfield. Toronto: CIELAP, March 1993.

Environmentally Sound Packaging Coalition

The Consumer Interest in Economic Instruments, July 1993. Vancouver: ESP Coalition.

Honourable Ruth Grier, Former Ontario Minister of the Environment

“Ontario’s Waste Reduction Action Plan”, Speech to a conference of Eastern Ontario Mayors, Wardens and Reeves, 21 February 1991, Toronto: MOE.

The Road to a Conserver Society, Speech to the Ontario Waste Management Conference, 17 June 1991. Toronto: MOE.

Grocery Products Manufacturers of Canada (GPMC)

GPMC Packaging Stewardship Model: A Discussion Document. Toronto: GPMC, December 1992.

Ontario Ministry of the Environment (MOE)

Blueprint for Waste Management. Toronto: Queen’s Printer, 1983.

The Physical and Economic Dimensions of Municipal Solid Waste Management in Ontario. Report prepared by CH2M Hill Consultants for the Fiscal Planning and Economic Analysis Branch, MOE, November 1991. Toronto: MOE, 1992.

Ontario Ministry of the Environment and the Office of the Greater Toronto Area (OGTA) The Waste Crisis in the Greater Toronto Area: A Provincial Strategy for Action, released by the Minister of the Environment, 27 June 1991. Toronto: MOE and OGTA.

Ontario Ministry of Municipal Affairs
Municipal Waste Management Powers in Ontario. Toronto: Queen’s Printer, March 1992.

Ontario Waste Management Association (OWMA)

Position Papers on the 3Rs, Flow Control, Incineration of Municipal Solid Waste and the Regulation of Rates Charged. Submitted to the Ministry of the Environment Toronto: OWMA, January 1993.

Recycling Council of Ontario (RCO)

Who Should Pay for Recycling? Toronto: RCO, August 1990.

Achieving a Balance: Public and Private Sector Roles in the Development of a 3Rs Infrastructure. Toronto: RCO, January 1992.

Waste Reduction Advisory Committee (WRAC), Ontario Government

The Shared Model: A Stewardship Approach to Waste Management in Ontario (For Dry Recyclables and the IC&I Stream). Toronto: WRAC, February 1992.

Resource Stewardship in Ontario: A Shared Responsibility. Toronto: WRAC, November 1992.

Generator Pay Charges: A Discussion Paper. Toronto: RAC, December 1989.


1. Most municipalities that expressed interest in implementing user charges for residents in their jurisdiction did not do so because they wish to avoid controversy and possible legal challenges.

2. See Biocycle, April 1992.

3. RCO, Presentation on User Pay Systems to CIELAP Conference, January 23, 1993 in Winfield et al. (1993)


About the Author

Mr. McRobert is a team leader, lawyer, and Policy Advisor with extensive government regulatory sector and Non-Government Organization (NGO) experience.  He has in-depth knowledge of environmental law and policy in Ontario along with experience in the administrative, aboriginal and municipal law fields, providing leading edge advice and analysis on compliance and policy options that empower organizations and clients to make better decisions.  David provides practical ways to solve complex policy and operational problems and implement change.  He works well with diverse management styles to achieve organizational goals; enjoys multi-faceted projects working with multidisciplinary teams where employing well developed analytical skills is essential.