Submitted by

Bruce Webster, Rural Council of Ottawa-Carleton:

Comments Regarding the Waste Management Terms of Reference
for an Initial 200% Landfill Expansion at the Carp Road Landfill Site 

Ministry of Environment Policy and Landfill Waste Diversion Targets⁽¹⁾

At a time when the Ontario Ministry of Environment is striving for landfill waste diversion targets of 60%, it seems counter-constructive for Waste Management, Inc to be applying for a 200% increase in landfill capacity at its Carp Road Landfill site.

Realistic Waste Diversion Targets

The former assistant administrator for America’s Environmental Protection Agency, (EPA), J. Winston Porter, stated that diversion of 35% of waste into recycling is about as high as any city can justify. He believes that any higher than that can be wasteful, if not harmful. ⁽²⁾

If Ministry objectives of landfill waste diversion percentages of 60% or higher are to be achieved, it will not entirely be through recycling, i.e.: through the traditional blue, black, or green bin programs alone. It has to be achieved, and is being achieved with the help of new technologies that are emerging, today. Technologies that can keep 100% of the waste from ever going to a landfill.⁽³⁾

Waste Management’s Waste Diversion Targets:

While Waste Management’s Terms of Reference claim present-day diversion rates of 30%:

1.      There is no explanation as to where it will find markets for most of its collected plastics that are currently going into landfill.

2.      There is no explanation as to how an immediate 200% landfill expansion will contribute to accomplishing more waste diversion than its currently claimed 30%.

3.      There is no explanation as to why it is not attempting to achieve the target 60% landfill waste diversion now, rather than after a doubling of its landfill size. (Is this, in fact, an admission that 60% is unattainable?)

4.      While Waste Management’s Terms of Reference claim to have reviewed Alternative Options to landfill expansion, such as “Thermal Destruction (waste to energy)”, some of which are capable of 100% landfill waste diversion, the Rural Council believes that there is no rationale for WM discarding its “ALTERNATIVE 2 – Develop a thermal destruction (waste to energy) facility at the WCEC,” at this stage since the option has not been objectively or adequately explored.  

The Rural Council believes the following:

Both the public and the Ministry of the Environment must have an opportunity to review a qualitative and quantitative analysis of all of the alternative options, including perhaps some of those previously not evaluated, before realistically expecting a ruling from the MOE on any potential merits of their request for landfill expansion.

Environmental, Social and Economic Negatives of Landfills ⁽³⁾

 
“Landfill” is the euphemism for the primitive and ancient practice of merely throwing our waste into “garbage dumps”.

Landfills are hugely problematic, in that they pollute our air with methane, H2S, volatile organic compounds, and a host of other noxious and offensive substances, as well as pollute our ground water and soils with a plethora of disease-causing and environment-poisoning toxins, the migration of which ultimately becomes uncontrollable.

Environment Ministries rule that dumps are not permitted to pollute neighbouring properties. However, the abatement process can easily be circumvented and deferred for many years simply by dump owners acquiring the land in the path of the polluted groundwater migration. 

Landfills or dumps, by any name, are an abomination, and the intelligent goal should be to eventually divert all waste away from landfills, by recycling, reusing and converting the remainder into energy and inert reusable residues. The utopian goal would be to “mine” all landfills, (as we would do any mining of resources), for their energy and inert construction materials, eradicating garbage dumps from the face of the earth.

The Rural Council believes that the time when we can begin to do that is now here, in Ottawa.

Landfill expansion clearly lacks public/political confidence and support

Residents are voicing loathing, fear and grave health concerns over the performance history and continued presence of the Carp Road Landfill. Any thought of expansion, at a time when the public believed that the landfill would be closing, is intolerable to them. ^{(4), (5)}

The Province of Quebec has already started moving in an environmentally conscientious direction by banning, as of March 30^th, 2010, any new open pit landfills in the province and by closing existing ones. This is to avoid further groundwater pollution and air pollution from persistent dump fires.

Quebec’s solution is to avoid reliance upon landfill expansions and to assist municipalities in the construction of energy-from waste plants.

Rural Council’s Conclusions and Recommendations:

1. Waste Management Inc should immediately commence every effort to raise its waste diversion capability from its stated 30% toward 60%, as a good-faith gesture to the community and as a demonstration of its intent to achieve MOE objectives. This would also have the advantage of extending its existing landfill capacity by several more months.
2. Waste Management Inc should conduct a valid cost-benefit evaluation of all alternative methodologies that can achieve up to 100% waste diversion from existing landfills, thus making landfill expansion redundant. Such methodologies as the “thermal destruction (waste-to-energy)” system, mentioned in the Terms of Reference, should be thoroughly evaluated and publicly documented, along with other SOTA systems that are available.
3. MOE should immediately put into effect, a new Landfill Expansion Approvals Moratorium, for two years, (throughout Ontario). This would provide a reasonable review period for thorough technical evaluation of emerging thermal destruction/disintegration technologies claiming 100% waste diversion, to be proven for market, while providing an opportunity to monitor other ways to achieve the targeted 60%, (and beyond), landfill waste diversion alternative methodologies.

References:

1. http://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTA4MDIy&statusId=MTYyMjY5&language=en
2. http://www.nationalpost.com/news/story.html?id=2305057
3. http://www.ruralcouncil.ca/energyfromwaste.htm
4. http://www.ruralcouncil.ca/CarpRdLandfill--2010.htm
5. http://www.ruralcouncil.ca/CarpDump-100622.htm