Zero Waste: Comment on Waste Recycling in NS

1 08 2014

–Urgent Call for Comments and Support on NS Waste Policy–

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 priority.

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 waste.

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  at the NS DOE, and be certain to include Robert M Kenney  on your email.  Additionally, we’d appreciate it if you also include the It’s Not Garbage Coalition .

Here are all three emails together to be easily copy and pasted into your email:


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 Solutions

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 of.
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:

The Ecology Action Centre’s response and commentary on the discussion paper can be found here:

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.”




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