[Sust-mar] -Urgent Call for Comments and Support- Going forward on Recycling, etc,
davidwimberly at eastlink.ca
Fri Aug 1 05:21:50 EDT 2014
Sure would help if all of you could send in comments, even if only brief
ones, and even if only a copy of what is here - because that is what it
And please share this widely. This really could help us all to have
this great step forward succeed!
*-Urgent Call for Comments and Support-*
*It is not often we get the chance to rally in support of a government
proposal on environmental and sustainability issues.*But we're reaching
out to you because what seemed like certain approval may be in jeopardy.
The Nova Scotia Department of Environment (NS DOE) has a consultation
process on waste resource issues that is about to conclude. Its aim is
to gauge public support for finally going further towards Zero Waste
-the direction citizens advocated for, and the government agreed with,
in the mid-1990's.They're proposing to add various materials to those
prohibited for disposal through landfill or incineration, to clarify the
definition of incineration to include new variations, as well as other
common-sense improvements.These changes would once again make Nova
Scotia an environmental leader in Canada and the world.
But industry lobbies and landfill operators worry that this will cost
them money, and they've organized to oppose these changes. Their voices
are being heard --but is yours?
*If we want to be good environmental stewards, we need to immediately
send in comments to the consultation process.*Even very short comments
can have a huge impact.
Remember, these proposals -- most of which are excellent -- came from
the NS DOE. They want them to be approved. But they need to show that
the public agrees that sustainability and environmental stewardship is a
*Below you'll find information to help you make a submission*, whatever
amount of time you have. Only have 1 minute to spare? We have a form
letter for you to use. Do you have 5 minutes or more to say something
more detailed? The It's Not Garbage Coalition's submission includes a
pithy reference guide to what changes support a zero waste future and
what changes do not. This, along with links to the detailed submission
from the Ecology Action Centre and the original NS DOE discussion paper,
should give you what you need to make a submission that explains more
personally why going to zero waste matters to you and our society.
However much time you have to help, the most important thing is to make
a submission now.It's also important that individuals and groups contact
reporters and write articles or letters to the editor to get positive
messages into the media to offset the damage done by those opposing zero
*The comment period officially ends at midnight, Friday August 1, but
comments shortly thereafter can still be included -so don't let that
deadline stop you!*
Thanks for reading, for actively caring about our future, and for making
Email Sophia Foley <Foleysj at gov.ns.ca> at the NS DOE, and be certain to
include Robert M Kenney <KENNEYBM at gov.ns.ca> on your email.Additionally,
we'd appreciate it if you also include the It's Not Garbage Coalition
<itsnotgarbagens at gmail.com>.
Here are all three emails together to be easily copy and pasted into
*To:*Foleysj at gov.ns.ca <mailto:Foleysj at gov.ns.ca>, KENNEYBM at gov.ns.ca
<mailto:KENNEYBM at gov.ns.ca>, itsnotgarbagens at gmail.com
<mailto:itsnotgarbagens at gmail.com>
Submission to the Solid Waste Unit, Nova Scotia Department of
Environment, regarding the discussion paper on solid waste regulation.
I'm writing to express my support for moving Nova Scotia in the
direction of sound environmental stewardship. In the past, Nova Scotia
has been a leader in waste resource management, and I believe we should
build on that proud tradition by strengthening environmental
protections. I support the submissions made by the Ecology Action Centre
and the It's Not Garbage Coalition and encourage you to accept the
changes to your proposals that they have put forward.
*Changes to the seven areas of discussion: Steps toward Zero Waste
1._Product stewardship_ -Support extensively!For every product proposed
and more! Extended Producer Responsibility is essential.Sharing
responsibility is essential to fiscal fairness and to changing products
to be designed and used in ways that are truly sustainable.Phasing in
rapidly is important, perhaps within two years, to not become mired in
delays and excuses as well as to reap the maximum economic and
2._Disposal bans and approval requirements_ -Support Disposal Bans for
every product proposed, and even more are possible.Ban from both
landfill and incineration (by any name or re-definition).Enforcement is
critical by independent agencies not subject to political interference
(like municipal employees).
3._Used tire management program_ -Yes. Expand the current definition in
the regulation to include off-the-road tires (OTRs) and all tires not
4._Removal of the requirement for regional solid waste management plans_
-- No.Do not support this.Instead, introduce enforcement that is truly
effective.Also require this to become a *ZERO WASTE STRATEGY by 2020*
plan with timelines, funding, and clear rewards for all sectors,
including private, ICI, and government.Require the same *ZERO WASTE
STRATEGY by 2020* of the provincial government.
5._Clarity on the rules for energy from waste_ -- Yes. Substitute the
term "thermal treatment technologies" for "incineration" for the
purposes of product disposal bans.Include all technologies that apply
heat to waste or produce "energy from waste" including pelletization,
plasma arc, pyrolysis, incineration, etc.These technologies simply
amount to a destruction of resources with lots of pollution at a great
expense.Incineration by any name, re-definition, or other disguise is
proven to be fundamentally incompatible with recycling, composting, and
other ways of conserving resources.Almost nothing combusts that can't be
better composted, recycled, or reused.The rest should be re-designed for
a sustainable world.
6._Improved enforceability of the solid Waste/Resource regulation _-Yes
to what is proposed.But we need to go far beyond that.50% of what is
disposed of now at landfill is already banned from disposal.Political
interference with enforcement is a critical issue.We call for bonded,
third party enforcement and inspection to ensure full compliance without
exception.This will need clear, legal definitions of standards of how
much deviation is allowable (which should be very little), and also
progressively more restrictive over time.This could be implemented
7._Beverage container deposit-refund program_ -If the benefits can be
specified to stay local then the NSDOE proposal seems plausible.The need
to focus benefits locally cannot be over emphasized.
We also agree with the two additional points made by the EAC:
1.Precise definitions are strongly needed for key terms.
2.We need a clear look at Green Economics, especially full cost
accounting, to demonstrate the full extent of financial benefits of
diversion to beneficial use.
*Response to the six specific questions in the NSDOE consultation document*
1.The list of products proposed for the initial stewardship framework is
fine.A two year time frame to implement is enough, and we can consider
what to do next.
2. In a product stewardship framework all sectors and participants
should fully assume responsibility.With each product there can be some
variability as to the best point for effective action.
3.The stewardship framework and material bans should be applied without
exception (residential, ICI, etc.).
4.We are long overdue for effective disposal bans on construction and
demolition materials.Two years is plenty of time to fully implement
bans.Using C&D materials as daily cover should be prohibited, as this is
not 'beneficial use' -anything going inside a landfill is being disposed
5.Citizen involvement in leadership roles is critical to success.
6.Citizen involvement in leadership roles is critical to success.
The complete submission from the It's Not Garbage Coalition can be found
The Ecology Action Centre's response and commentary on the discussion
paper can be found here: http://bit.ly/EAC-response
The NS DOE discussion paper can be found here:
*Thank you again for your concern and active engagement in working for a
better and more sustainable future for Nova Scotia.*
More information about the sust-mar