OFVGA Response: Waste-Free Ontario

Re: Proposed Strategy for a Waste-Free Ontario: Building the Circular Economy EBR Registry Number: 012-9356

Dear Mr. Peverini,

The Ontario Fruit and Vegetable Growers’ Association (OFVGA) is the umbrella organization for the province’s fruit and vegetable farmers representing 27 different grower groups. The sector supports 30,000 farm-based, non-family jobs in Ontario, as well as a further 8,700 jobs specific to horticulture and specialty crops. Over 125 different fruit and vegetable crops are grown in Ontario with an estimated annual farm gate value of $1.6 billion (2013).

OFVGA supports legislation towards a circular economy and the reduction of greenhouse gas emissions from the waste sector and emphasize the need for transparent legislation. Members of OFVGA are strongly committed to providing safe and sustainable food to consumers and strive to be stewards of the environment. We collectively must also recognize the costs associated with increasing recyclability and the goal of zero waste. With that in mind, food sovereignty is something that should also be considered. People have a right to healthy food produced through sustainable farming methods and part of that equation includes a sustainable income for those who produce food. OFVGA appreciates this opportunity to comment on the proposed Strategy for a Waste-Free Ontario and has the following comments to offer:

  • OFVGA supports efforts that will improve packaging containment in a comprehensive and consistent manner. OFVGA recommends that successful strategies currently used by farmers serve as the basis for expended and enhanced programming. An example would be the Clean Farm’s model, where used pesticide containers are being recycled into fence posts.
  • OFVGA recommends that the management of on-farm organic waste continue to be considered a formal farm practice, including the use of nutrient management applications and approved technologies (i.e. biodigesters, composting etc.) and that these practices be eligible for offsets under the new cap and trade program.
  • Define Best Management Practices also known as BMRs for on-farm land application and/or composting of horticultural organic material that is not within the Nutrient Management Act.  BRMs should seek to address the reduction of GHGs, while supporting healthy soils.
  • OFVGA recommends that complimentary organic waste reduction initiatives be applied throughout the supply chain and not downloaded at the farm-level. Putting a tool in place to ensure that these costs are distributed at the level of the value chain where the waste occurred and not be passed on to farmers, as they have little control over how produce is handled once it leaves the farm-gate. With this in mind, OFVGA requests the government recognize and quantify the cumulative impact (financial and environmental) this Act could have on purchasers of packaging.

OFVGA is supportive of policies that are comprehensive, science-based and economically sound. We thank you for the opportunity to comment on this proposed legislation and look forward to working with you and your government towards a zero waste Ontario.