Please be advised that I object to the application by the City of Guelph to amend condition 45(4)(d) of CofA-A170128 that would permit the site to compost organic waste collected in readily biodegradable organic bags. I have provided below, some concerns and responses from the City through correspondence and discussions at Public Liaison Committee meetings. I have also sent this list to the City of Guelph to get answers to the follow-up questions and will forward them to you when received.
Question:
Does the city of Guelph still plan on applying for an amendment of their C of A regarding the collection of organic waste in plastic and compostable bags even though the PLC did not support it?
City Response:
The City will be seeking an amendment to their current Environmental Compliance Approval that will seek Ministry approval to collect source separated organics (SSO) in a collection program that allows for the use of a compostable/biodegradable plastic bag.
It is important to note that the City has been receiving SSO in non compostable plastic bags since the facility began operations last September and there have been no odour issues related to the processing of these plastic bags. In September of this year, the City will be converting one third of the City to a cart based collection system which will automatically eliminate one third of the plastic bags being received at this facility.
Further, the City of Guelph organics facility was designed to process all SSO received in plastic bags. There is absolutely no evidence to even suggest that this facility creates odours due to the use of plastic bags in the collection process.
Follow up Comment and Question:
A December 5th, 2011, committee report to “reaffirm the planned conversion to fully-automated cart collection program commencing in 2012” was approved by Council. The report signed by Dean Wyman and Janet Laird stated: “Certified compostable products may not completely decompose in the composting process. Furthermore, as compostable plastics are not always distinguishable from non-compostable plastics, contamination of the waste stream with non-compostable plastic would be anticipated. Although the private sector facility operator (Aim Environmental Group) is responsible for marketing the final compost product and assumes the risk of marketing a lower grade product, intentionally allowing contaminants in the feedstock is not an environmentally sustainable practice. Based on all factors, staff recommends proceeding with the fully-automated system previously approved by Council.”
Is it acceptable practice for staff to go against their own recommendations to Council and furthermore ignore Council’s direction for staff to proceed with a fully-automated cart collection program as approved in the May 25, 2010 Council Meeting? I request that staffs decision to seek an amendment to their current Environmental Compliance Approval that will seek Ministry approval to collect source separated organics (SSO) in a collection program that allows for the use of a compostable/biodegradable plastic bag, despite Council’s direction and despite non-support from the PLC be questioned on the basses of acceptable procedure by staff through Council.
Since you say that there is absolutely no evidence to even suggest that this facility creates odours due to the use of plastic bags in the collection process, can you provide the details that did contribute to the odours to date and explain how the bags could not have played a part?.
Question:
If the City of Guelph is going to apply for this amendment to accept waste in bags will it be modified to meet the recommendation by the PLC to only include paper bags?
City Response:
As stated above, the City will be requesting an amendment that will permit the use of compostable/biodegradable plastic bags by users in the collection process.
Question:
It is our understanding that the City of Guelph initiated the ‘no bag collection’ condition in the current C of A. Can you explain your rationale for this initial request and explain why the sudden change to this decision?
City Response:
This is incorrect. The City did not initiate the exclusion of plastic bags in the collection process. This condition was a Ministry demand that the City objected to. The City would have appealed this condition at that time however Orgaworld in Ottawa already had an appeal on the exact same issue before the Environmental Review Tribunal. The City had been provided with assurances from senior Ministry approvals staff that if the Tribunal adjudicator ruled in favour of the decision to allow the use of plastic bags in the collection process, that the City would simply be required to submit an amendment application to have the condition changed.
Follow up Comment and Question:
I understand that the City of Ottawa does not allow compostable/biodegradable plastic bags in their waste stream. I called Dr. Greg Mariotti who is the operations manager at Orgaworld on September 28th and he informs me that their facility is currently not accepting SSO in any type of bags as they are supporting Ottawa’s decision not to allow bags in their collection of organics. The City of Ottawa objected to the Orgaworld appeal and in their submissions on pages 21-23 of the Environmental Review Tribunal indicates that they support a no bag system for a cleaner waste stream that is more suitable to composting and that it will have a significant beneficial effect on the facility’s operations and environment controls as well as reduce the amount of residual waste production.
Now that you aware of Ottawa and Orgawold’s support for a no bag system, will Guelph support their decision?
Question:Being that Guelph initiated the ‘no bag’ condition, why on page 6/7 of the Golder and Associates draft report does it state that “Guelph did not consider the collection or SSO waste in a cart based system?” Is this so called business case prepared by the City of Guelph available to PLC members?
City Response:
As previously stated, the City of Guelph did not initiate the no bag condition.
Follow up Comment and Question:
You did not answer the second part of the question: Is this so called business case prepared by the City of Guelph available to PLC members?
Is the statement in the Golder Associates draft, page 6/7 “Notwithstanding the points already discussed herein, it is critically important to emphasize that the initial business case prepared by Guelph for the OWPF did not consider the collection of SSO waste in a cart-based system.” a true or not true statement?
Will the City loose the 1.3 million CIF Funding Agreement if this amendment is approved?
Question:
Has Orgaworld started to accept SSO waste in plastic or compostable bags? If not, why?
City Response:
The City is not aware whether or not Orgaworld is now accepting SSO in plastic bags.
Follow up Comment and Question:
As previously stated, Orgaworld is not accepting SSO in any type of bags as they are supporting Ottawa’s decision not to allow bags in their collection of organics. The City of Ottawa’s objection indicates that they support a no bag system for a cleaner waste stream that is more suitable to composting and that it will have a significant beneficial effect on the facility’s operations and environment controls as well as reduce the amount of residual waste production.
Guelph’s direction to accept bags is in direct conflict with Ottawa’s decision not to. Is council aware of staff’s direction and do they support it?
Question:
How will an automated cart system which allows bags to be collected with SSO waste be able to monitor compliance? I understand there are cameras but even so this will be very difficult to detect non compliance
waste.City Response:
Program and compliance staff will be conducting spot audits of the carts on collection routes to ensure compliance. Further, site staff will be continuing to monitor the receipt of the SSO after it has been tipped on the tip floor and prior to the SSO being shredded. Once the SSO is shredded, further observations will be made by site staff which will determine if further actions will be required to prevent non compliance.
Follow up Comment and Question:
As quoted by staff in their December 5th, 2011, committee report “Certified compostable products may not completely decompose in the composting process. Furthermore, as compostable plastics are not always distinguishable from non-compostable plastics, contamination of the waste stream with non-compostable plastic would be anticipated. Although the private sector facility operator (Aim Environmental Group) is responsible for marketing the final compost product and assumes the risk of marketing a lower grade product, intentionally allowing contaminants in the feedstock is not an environmentally sustainable practice. Based on all factors, staff recommends proceeding with the fully-automated system previously approved by Council.”
Can you tell me why staff is now going against their own recommendations to Council and furthermore if it is acceptable to Council that despite non-support from the PLC and previous decisions by Council to support the no bag system, for staff to be seeking this amendment?
Question:
Please explain in detail Guelph’s understanding of the MOE’s concern relating to composting waste collected in bags.
City Response:
The City was made aware of the draft guideline for composting facilities and compost use in Ontario that specified that the use of plastic bags in the collection of feedstock materials can significantly contribute to odour issues and this is due to the fact that anaerobic decomposition of organic waste starts even before the material arrives at the facility. In response to these Ministry concerns the City made submission on this issue that demonstrated the advanced odour control system that was designed and implemented at the facility would alleviate any odour issues.
Follow up Comment and Question:
Orgaworld provided three biofilters an air lock and are 1.5- 2km’s away from 79 sensitive receptors. The Guelph facility is less that .5 of a km, had two biofilters, however one was deleted as a cost saving measure, a booster that was roughed in and not installed and an air lock was not installed despite being recommended by consultants. Orgaworld does not allow bio-degradable bags in its waste stream and have had no complaints about odours. Guelph however has had complaints with an unknown number of them being verified due to the confusion of what it takes to have an odour complaint verified.
Given that this facility has been operating less than a year and only recently at capacity, how can we be assured that the Guelph facility has a superior odour control system than the one that Orgaworl has and that it compensates for the residential area that is over one kilometer closer that the nearest residence in Ottawa? Most importantly is how can the Guelph facility determine the added odours that it must process if the bags are accepted from outside the city? How do you determine or control how long the SSO has been sitting at another facilities transfer station or in an enclosed truck?
Orgaworld conducted a model calculation with the stack emission rate of 4,148 Odour Units and the model predicted that the odour concentration level at the location of the prescribed sensitive receptor was .84 Odour Units which is below the odour performance limit of 1.0 Odour Unit. The Guelph Facility model calculation was done at 1,500 Odour Units and the model predicted that the odour concentration level at the location of the prescribed sensitive receptor was .67 Odour Units. Since the Orgaworld facility in Ottawa is twice as far away from the nearest sensitive receptor compared to Guelph, can the model calculation with the stack emission rate of 4,148 Odour Units predict the odour concentration level at the location of the prescribed sensitive receptor and the results provided?Question:
Provide a summary on how in particular this amendment would alleviate those concerns.
City Response:
The City felt it had addressed the Ministry odour concern by demonstrating the effectiveness of the design of the advanced odour control systems and that these controls would effectively control these potential odour sources. The City has proven over the past year that these designed systems are effective.
Follow up Comment and Question:
Orgaworld in Ottawa appears to have a more advanced odour control system, with an air lock, they do not allow bags, are over a kilometer farther from a residential area and did their model calculation with almost three times the stack emission rate than Guelph . London, however has the same odour control system as Ottawa, accept bags, are within .5km as is Guelph to the closest receptor and do have many odour complaints.
Even if the City of Guelph added to their odour control system to equal that of the Ottawa facility it would be more like London that is .5km away from residents instead of Ottawa that is 1.5 – 2kms. London accepts bags and has plenty of odour complaints compared to Ottawa that does not accept bags, how can we be assured that the so called advanced odour control system in Guelph will not end up more like London than Ottawa?
Question:
What are the factors in particular that support the requested change?
City Response:
There is a distinct correlation between an increased participation rate by users of a cart based SSO collection system and the elimination of the “yuck” factor when plastic bags are permitted to be used as liners. The City has received numerous comments from Guelph residents regarding their concerns of not being able to use plastic bags with their carts for the purpose of eliminating the “yuck factor”. Further, the Ministry fully supports waste diversion through composting in this Province and as this facility has the capacity to process more SSO than what the facility is currently processing, the City is unable to source additional SSO due to the fact that there are no other municipalities in the Province of Ontario that are able to send their SSO for processing because of the current plastic bag restriction in the ECA. Finally, the organics facility has been designed with an array of odour best management practices that have been designed to minimize the potential for odour emissions from the facility, and include physical measures of containment, capture, control and administrative controls.
Follow up Comment and Question:
Can you provide the survey or source of where you obtained the information that confirms that there is a distinct correlation in participation with and without plastic bags as liners?
The city of Guelph has a unique opportunity to get hands on data on the conversion to a no bag system that would be invaluable information that can be used by other municipalities and the MOE. Would it not make sense to go with the complete cart conversion program and then see if the participation drops off to the present bag system?
The MOE’s major concern with the Ottawa Facility was that if they accepted bags, those from out of town would be very odorous when received as they could sit too long before being processed. Ottawa received approval, however it was conditional on receiving from a 200km radius.
You state that the City is unable to source additional SSO due to the fact that there are no other municipalities in the Province of Ontario that are able to send their SSO for processing because of the current plastic bag restriction in the ECA. Besides the Mayors comment that municipalities should look after their own waste, In the draft amendment, there are eight municipalities that do not accept SSO in compostable bags and these eight municipalities would be open to accept waste from if you consider changing the amendment to Kraft Paper Bags as supported by the PLC. Although I do not agree with importing waste into our City, would opening up the Guelph facility to over 38% of the Ontario market not satisfy the requirement to bring other peoples waste into our facility?
Question:
Has the Orgaworld facility had a history of odour complaints and can you provide a summary of the number of complaints over the last two years?
City Response:
The City of Guelph is not privileged to that information.
Follow up Comment and Question:
Orgaworld does not allow bio-degradable bags in its waste stream and have had no complaints about odours that I am aware of. Guelph however has had complaints with an unknown number of them being verified due to the confusion of what it takes to have an odour complaint verified.
London is the same design as the Ottawa facility, however they have plenty of odour complaints as they are .5km from residence and accept bags. This may be why Ottawa has decided to not accept bags.
Question:
Has anyone done a study to determine how much waste by volume would be added to our waste processing facility to deal with the packaging materials associated with the proposed bags? This would have to include from the retailers as well as the homeowner.
City Response:
Compostable bags decompose in the composting process so therefore little or no residue waste is anticipated.
Follow up Comment and Question:The question was about the packaging material that the bags arrive in. This includes the large packing that the store receives the packages of bags in as well as the packaging that is left over after the bags are removed at the home.
Page 23 of the ERT states that Waste not collected in bags will reduce the amount of residual waste production.
Question:
Is there any documentation that provides the details as to why the ETR thought that allowing bags at Orgaworld would not result in increased odours or that the increased odours would still be within the 1 odour unit because of their location?
City Response:
Please find the web link for the Orgaworld ERT appeal decision for your review.
http://www.ert.gov.on.ca/files/201111/00000300-BQW7PWKETN0026-BK753D11EIO026.pdf
Follow up Comment and Question:
See page 84, 85 & 86 of the ERT. The odour units used in the stack emission rate for the Guelph modelling was 1,500 and Orgaworld used 4,148. Can the model be used with the 4,148 that Ottawa used and the results provided?
Question:
Can you provide the evidence and circumstances specific to the Orgaworld facility that were presented to the ERT?
City Response:
I have attached the web link above of the ERT decision for your review.
Follow up Comment and Question:
The Ottawa Facility was being compared to London that was built with the same odour management system.
Page 23 of the ERT states that Waste not collected in bags will reduce the amount of residual waste production. Does the City of Guelph agree or disagree with this statement?
Question:
How in particular does the Guelph facility meet the odour minimization and control design features found at the Organworld facility when the Guelph facility has not yet been commissioned at capacity?
City Response:
The City of Guelph OWPF has been commissioned at capacity and source testing has been completed. Results of the source testing which has been released, confirms that the plant is meeting all designed specifications related to odour minimization and control design features.
Follow up Comment and Question:
The facility may have been tested to verify that it has complied with the design features; however the odour units used in the stack emission rate for the Guelph modelling was 1,500 and Orgaworld used 4,148 when they were looking to add bags to their SSO. Can the model be used with the 4,148 that Ottawa used and the results provided?
Question:
Will the acceptance of bags decrease the amount of residual waste requiring final disposal from the residents of Guelph?
City Response:
Yes, the acceptance of compostable/biodegradable bags will decrease the amount of residual waste currently generated at the facility as the bags will be composted in the process rather than being removed and disposed of.
Follow up Comment and Question:
It looks like you are comparing the compostable/biodegradable bags to plastic bags. The plastic bags are to be phased out as per the C of A. The question is will the compostable/biodegradable bags decrease the amount of residual waste compared to the cart system with no bags as recommended by staff to Council? Page 23 of the ERT states that Waste not collected in bags will reduce the amount of residual waste production as does staff’s recommendation to council. Will the acceptance of bags decrease the amount of residual waste compared to a cart system without the use of any bags?
Question:
I do not believe that organics is part of the Solid Waste master Plan. Please provide a copy with the details that specifically relate to SSO.
City Response:
A copy of the Waste Management Master plan can be found on the City’s website at:
http://guelph.ca/uploads/ET_Group/wetdry/WMMP/Open%20House%20material/SWMMP_FINAL.pdf
There are many references in plan regarding organics specifically pages 4, 12, 13, 22, 23, 24, 25 and 26.
Follow up Comment and Question:
Page4 of the Master Plan says: “Modifications to infrastructure to support organic waste processing is being considered by the City under a separate process and separate steering Committee.” As well as page 8 that adopts a Zero-Waste Philosophy. I do not believe that this amendment adopts that philosophy.
Question:
Is there a reason why Guelph cannot meet our diversion rates without the use of bags? By adding bags to our system, is it not just adding more material in our waste stream that we have to divert? If so why would we want to do this if not to increase the numbers for political reasons?City Response:
With the use of compostable/biodegradable bags, the City will be actually reducing the amount of residual waste that is currently being sent to landfill as these types of bags become part of the final compost and not the waste stream. With the amount of public feedback the City has received requesting the use of bags in the bins, the City believes by eliminating the “yuck” factor with the permitted use of compostable/biodegradable bags, SSO waste diversion would actually increase.
Follow up Question:
It looks like you are comparing the compostable/biodegradable bags to plastic bags. The plastic bags are to be phased out as per the C of A. The question is will the compostable/biodegradable bags decrease the amount of residual waste compared to the cart system with no bags as recommended by staff to Council? Page 23 of the ERT states that Waste not collected in bags will reduce the amount of residual waste production as does staff’s recommendation to council.
The following information was copied from the City of Toronto website. Does the City of Guelph disagree with Toronto?
Biodegradable plastic products and bags cause problems for municipal recycling systems
Currently, the City of Toronto and the majority of other municipalities across Ontario do not want biodegradable plastic packaging, including biodegradable plastic bags, in their recycling or organics programs for the following key reasons:1. Biodegradable plastics can ruin recycling markets. The plastics we recycle are used to manufacture new products such as landscape edging, decking and automotive parts. These products are manufactured to be durable and to not break down over time. The presence of biodegradable plastics puts the durability of these products with recycled plastic content in peril. The markets which buy waste plastic from municipal Blue Bin programs refuse to buy any material which may contain any bio-plastics.
2. It is crucial that the integrity of our plastic recycling contracts remain intact. The City generates over $20 Million per year from the sale of recyclables to help offset the cost of collecting recyclables. Bio plastics put a portion of this revenue at risk.
3. There is a risk of biodegradable plastic packaging or products contaminating the Green Bin organics collection program where one brand in a class of products (e.g. snack food bags) introduces a biodegradable bag, regardless of the processing system in place.
4. The current funding system for municipal ‘Blue Box’ recycling programs requires the producers of recyclable products to pay 50% of cost to recycle their material in our municipal system. However, packaging material accepted in Green Bin organic program is not eligible for this funding. The City bears 100% of the cost of this program.
Biodegradable plastics do not compost well in Toronto’s or other municipalities’ systems, regardless of whether the processing uses an anaerobic (without air) or aerobic (with air) system. Again, there is the risk of degrading the expected quality of the fine finished compost produced as a beneficial end-use product.Follow up Question:
The following is the Position paper from the Regional Public Works Commissioners of Ontario (RPWCO) regarding Biodegradable Plastic Products and Packaging. Does the City of Guelph disagree with this paper?
RPWCO Position Paper
Biodegradable Plastic Products and Packaging
June 19, 2009
Residents, businesses and brand owners should be discouraged from using or introducing not be encouraged to use ‘biodegradable’, ‘compostable’ or ‘OXO degradable’ plastic packaging and productsQuestion:
The MOE suggests that the bags be considered carefully in concert with consideration of facility design. Can we be provided with more details on how the Guelph facility has considered the direct impact in the facility design.
City Response:
To mitigate odour generation, the facility has been designed and constructed using the best available pollution control technology including:
I. Enclosure of all processing activities including the maturation hall
II. The processing areas are maintained under negative pressure
III. Separation of processing areas, air handling systems to prevent cross-contamination facilitating better air flow control in all areas of the facility and computerized control of air handling systems to better manage air flow based on production activities
IV. Rapid roll up and air curtains on the bay doors
V. Computerised control of air handling systems to better manage air flow based on production activities
VI. The design also includes a built in 20% redundancy in the design of the biofilter that is enclosed with a 47.5m stack
VII. Engineered biofilter with inorganic media
VIII. Closed top design of biofilter
IX. An acidification system that eliminates practically all ammonia post scrubbers
X. Development and compliance with an Odour Management and Monitoring Plan and a Fugitive Odour Management Plan
XI. Administrative controls (including procedures for reporting of rejected loads, tunnel cleaning) and staff training.The design and capabilities of production equipment initially procured has also enabled the operator to remove most unwanted plastic from compost produced. On the back-end of the screening plant, high velocity air separates and suspends plastics via Wind Sifter this essentially is pulling plastics away from the compost stream to a separate collection system
Should Guelph move forward with compostable liners, the City feels our positive processing experience to date at the OWPF provides confidence in that the process operations will remain relatively unaffected.
See comments about Orgaworld and ETRFollow up Comment and Question:
-What were the odour units used in the stack emission rate for the Guelph modeling? Orgaworld used 4,148.
-The MOE warned Orgaworld that there would be higher concentrated odours if importing waste in bags so Ottawa used 4,148 odour units. Can Guelph use these odour units and still meet the 1 odour unit at the property line?
-Can the overhead doors and exhaust fans be interlocked to prevent a door from opening if the exhaust fans are off and to prevent more than one door to be opened at the same time?Question:
There have been and continue to be a great number of odour complaints and the facility has not proven that it can operate odour free as promised. There are a number of odour control systems that were roughed in or recommended by consultants that did not get installed to minimize the chance of odours. Would these additional control systems such as a booster in the stack and air locks at the doors be added into the facility if bags were considered?
City Response:
Detailed and comprehensive odour investigations by City and Ministry staff are conducted for each and every odour complaint received. If there is one consistent result that is derived from these investigations, it is that the odour is definitely not originating from the composting facility. Further, there is little to no odours coming from the sniff ports which are strong indicators of any potential odours being discharged from the stack. The source testing has now been completed and the results clearly demonstrate that the facility is meeting the odour unit limit as set out in the Air ECA. There is absolutely no reason to investigate further odour control measures at this facility.
Follow up Comment and Question:
If odours are coming from elsewhere on the site, can you provide the details as well as an action plan to provide odour control measures to eliminate them?
Question:
I was under the understanding that there was no initial business case for this facility, was there?
City Response:
No business case was developed. The attached web link outlines some of the reasons why the City constructed the OWPF.
Error! Hyperlink reference not valid.
Follow up Comment and Question:
I was unable to access the information:
Your search – http://www.guelph.ca/living.cfm?itemid=78687&smocid=2410 – did not match any documents.The statement in the Golder Associates draft, page 6/7 “Notwithstanding the points already discussed herein, it is critically important to emphasize that the initial business case prepared by Guelph for the OWPF did not consider the collection of SSO waste in a cart-based system.”
Since there was no business case developed and staff recommended the cart system with no bags as the best financial solution in their presentation to Guelph City Council on December 5, 2011 can you explain why this false statement is included in the Golder Associates Draft?
Question:
Why was the cart collection system not part of the business case when it was required from the beginning?
Response:
The City did not anticipate the Ministry mandating the no plastic bag use and did not envision having to utilize carts.
Follow up Comment and Question:
What is the date that the City first found out that there would be no plastic bags use allowed?
Question:
Please provide details on how the importation of SSO from other municipalities will be a financial benefit to the taxpayers of Guelph based on the true operating costs per tonne, including the loss of interest on the bond that was cashed in to fund the facility as well as all operating costs of the facility compared to the income to the city on a per tonne basis.
City Response:
The actual per tonne processing cost to the City of Guelph versus the per tonne cost charged to other users are substantial and the City utilizes this cost benefit to offset operational costs.
This does not answer the question, I was looking for the true operating costs per tonne, including the loss of interest on the bond that was cashed in to fund the facility as well as all operating costs of the facility compared to the income to the city on a per tonne basis from other users.
Follow up Comments and Questions:
This amendment does not comply with the Guelph Innovation District Secondary Plan-preferred design. Guelph City Council supported the use of the preferred vision principals, objectives, design and implementation approach set out in planning & building, engineering and environment report No. 11-104 as amended by council report No. 12-18, as the basis for the completion of the secondary plan. This amendment would not promote best practices for sustainable infrastructure and community design targeting a zero carbon horizon or enforce being a leader in conservation and resource protection/enhancement. Has Council reviewed this application and do they confirm that it conforms with the preferred vision principals?
The general public was not informed of this amendment and a change of this magnitude should have been presented to the entire population for comment. The City of Guelph has not followed their corporate policy and procedure for accountability and transparency as it did not encourage public access and participation to ensure that decision making is responsive to the needs of its constituents and respective to their opinions; Accountability, transparency and openness are standards of good government and the City did not utilize a process that was open and accessible to its community stakeholders or engage its stakeholders throughout its decision making process in an open, visible or transparent manor. This application does not reflect a commitment of senior management to ensure that administrative practices and procedures recognize Council’s commitment to accountability and transparency. Can and will the City put the application on hold until they follow the policy and procedure for accountability and transparency?
This amendment does not comply with the intent of the waste diversion principals that are intended by the MOE as it will not reduce the amount of waste WE create, Reuse the waste WE create or recycle the waste WE do not use. Can you confirm that it is acceptable to Guelph City Council not to follow the waste diversion principals and that this application meets the guiding principals of the Guelph Waste Master Plan?
A December 5th, 2011, committee report to “reaffirm the planned conversion to fully-automated cart collection program commencing in 2012” was presented by Guelph City staff and approved by Council. The report signed by Dean Wyman and Janet Laird stated: ……………”Based on all factors, staff recommends proceeding with the fully-automated system previously approved by Council.”Is it acceptable practice for staff to go against their own recommendations to Council and furthermore ignore Council’s direction for staff to proceed with a fully-automated cart collection program as approved in the May 25, 2010 Council Meeting? Staffs decision to seek an amendment to their current Environmental Compliance Approval despite Council’s direction and despite non-support from the PLC should be questioned on the basses of acceptable procedure. Can you confirm that Council supports staffs direction with this application?
I understand that the City of Ottawa does not allow compostable/biodegradable plastic bags in their waste stream. I called Dr. Greg Mariotti who is the operations manager at Orgaworld on September 28th and he informs me that their facility is currently not accepting SSO in any type of bags as they are supporting Ottawa’s decision not to allow bags in their collection of organics. The City of Ottawa objected to the Orgaworld appeal and their submissions on pages 21-23 of the Environmental Review Tribunal indicates that they support a no bag system for a cleaner waste stream that is more suitable to composting and that it will have a significant beneficial effect on the facility’s operations and environment controls as well as reduce the amount of residual waste production. Does the City of Guelph support the City of Ottawa’s decision?
The organics facility was built in the city, adjacent to a long established residential area. It was due to the lack of foresight about odour problems for the neighbours that resulted in the first facility closing down. The reconstruction of a new facility in the same location is why the Ministry made the new C of A requirements so stringent that bags were not allowed. We were assured that by not allowing bags, it would help control the odours at the facility. To apply to the Ministry of the Environment less than a year after starting up the facility blatantly breaks the promise that was made to the residents in the area of the facility. Is Guelph City Council aware that staff has not followed through on the promise made?
The City was made aware of the draft guideline for composting facilities and compost use in Ontario that specified that the use of plastic bags in the collection of feedstock materials can significantly contribute to odour issues and this is due to the fact that anaerobic decomposition of organic waste starts even before the material arrives at the facility. Orgaworld in Ottawa provided an air lock and are 1.5- 2km’s away from 79 sensitive receptors. The Guelph facility is less that .5 of a km and an air lock was not installed despite being recommended by consultants. Orgaworld does not allow bio-degradable bags in its waste stream and have had no complaints about odours. Is Guelph considering the addition of an air lock?
The City says that they are unable to source additional SSO due to the fact that there are no other municipalities in the Province of Ontario that are able to send their SSO for processing because of the current plastic bag restriction in the ECA. In the draft amendment, there are eight municipalities that do not accept SSO in compostable bags. The PLC had supported an amendment to accept Kraft Paper Bags opening up more of a market, however for the record, I do not support the importation of SSO from other municipalities. We should not be in the business of trucking other municipalities waste into our city as the Mayor had indicated on many occasions that each municipality should be responsible for dealing with their own waste. Any municipality that wants to use the Guelph facility should be able to conform to the collection system that was promised to be maintained by the city prior to construction.The facility is designed and approved to process 60,000 tonnes per year of organic feedstock which is comprised of 30,000 tonnes of SSO and 30,000 tonnes of amendment material. The City is also quoted to say “The City currently generates 10,000 tonnes of SSO per year and uses 10,000 tonnes of amendment material thus taking up 20,000 tonnes of the facility capacity. The Region of Waterloo has committed to sending 20,000 tonnes of SSO per year for processing through our facility and once the 20,000 tonnes of amendment material required for processing is added, the facility will be at full capacity.” With this being the case, there is no requirement to source SSO from other municipalities. Is the City in danger of losing the contractual commitment from Waterloo? What is the current percentage of Amendment material to SSO? KS