[Sust-mar] -Urgent Call for Comments and Support- Going forward on Recycling, etc,

David Wimberly 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 
is for.
And please share this widely.   This really could help us all to have 
this great step forward succeed!
David Wimberly

*-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 
a submission.


*Form Letter*

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 
your email:

*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 
environmental benefit.

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 
already covered.

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 
province wide.

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 
here: http://bit.ly/itsnotgarbagens-response

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 mailing list