5. Analysis of Exports/Imports of Non-Hazardous Wastes

• 5.1 Newfoundland
• 5.2 Prince Edward Island
• 5.3 Nova Scotia
• 5.4 New Brunswick
• 5.5 Quebec
• 5.6 Ontario
  • 5.6.1 Ontario Waste Exports
  • 5.6.2 Ontario Waste Imports
• 5.7 Manitoba
• 5.8 Saskatchewan
• 5.9 Alberta
• 5.10 British Columbia
• 5.11 Summary
• 5.12 Factors Influencing NHW Transboundary Flows
• 5.13 Trade in Recyclable Materials

One aspect of this project was a review of present and projected exports and imports of non-hazardous waste (NHW) destined for final disposal. The outcome of this work, which included a look at waste types, volumes and transportation destinations is presented in this section. While not a primary focus of this exercise, comments are also made herein with respect to the trade in recyclable materials.

Base data and background information used in this analysis were largely derived from the stakeholder contact survey (see Section 2.3). Reference is also made herein to previous reports prepared on the subject of transboundary movements (see Section 4). As discussed throughout Section 4, accurate data reflecting the transboundary movements of NHW destined for disposal is very difficult to obtain in the absence of reporting from private waste management firms. These difficulties were also encountered in this study as reflected in the poor quality of data derived.

As noted herein, six provinces reported no waste export or import activity, although confirmatory data was often scarce. These provinces were Newfoundland, Prince Edward Island, Nova Scotia, Quebec, Manitoba and, Alberta.

The Department of Environment & Labour report that municipal NHW is not exported from the province. IC&I establishments, however, may be exporting NHW (further details unknown). Recyclable material exports include tires, scrap metals, beverage containers, etc.

A standing order is in place that requires prior government approval before waste importation can occur (put in place in response to a proposal several years ago to import waste for disposal). As a result, no waste is imported into the province (minor quantities from aircraft and cruise ships, considered international wastes, are received).

In this province, solid waste is managed by the Island Waste Management Corporation (IWMC). Corporation representatives report that PEI does not import or export solid wastes for disposal, with the exception of exported hazardous wastes (PCBs, bio-medical waste, etc.) and the occasionally received waste from cruise ships (at the ships' request). Some materials are exported for recycling.

The Nova Scotia Department of Environment report that no municipalities are currently exporting waste for disposal. They are also not aware of any such movements concerning IC&I wastes. No landfills are further receiving waste imports with the Department noted to having a policy against such waste movements for landfilling or incineration (with or without energy recovery).

The only transboundary movements identified were related to fibre/corrugated cardboard, used clothing, and potentially, newsprint/magazines (imports received from the U.S.). Exports, primarily directed to the U.S., were noted to comprise paper fibre, waste tires and plastics.

The New Brunswick Department of Environment reports that solid waste from the state of Maine is imported to two areas for disposal. These areas are represented by the Solid Waste Commissions of South West (6000 to 7000 tonnes per year imported) and, Madawaska/Victoria (7800 tonnes/year imported). The Department further reports that Environmental Impact Assessments must be carried out for sites intending to dispose of imported waste. Material imports are considered beneficial in some cases as they help support local 3Rs programs.

One other jurisdiction, the Fundy Region Solid Waste Commission, reported receiving some minor offshore waste from international shipping activities. No waste export activity was identified in the province.

As noted in Section 3.6, Quebec's Regulation respecting Solid Wastes adopted pursuant to their Environment Quality Act prohibits any landfilling of waste generated outside the province. No waste imports, therefore, are presently occurring in Quebec. With respect to waste exports, no data was forthcoming at the time of this report.

As noted in Section 4.1, a 1993 report entitled "Export of Solid Non-Hazardous Waste From Ontario" estimated that 1.3 million tonnes of NHW were exported in 1992 to the United States. At the time that study was undertaken, the majority of this waste was from the IC&I sector and collected by private haulers serving Metro Toronto and the Regions of Peel, Halton and Hamilton-Wentworth. No waste was reported as being imported for disposal in Ontario. This situation remains largely unchanged.

Present waste disposal practices in Ontario were canvassed with the following results:

• City of Toronto: currently (1999) 325 000 tonnes of municipal NHW are hauled to Michigan. In 2000, this is expected to increase to 450 000 tonnes. Present disposal contracts may be extended for 2 more years. In 1998, municipal waste exports amounted to approximately 254 000 tonnes. Significant quantities of IC&I and C&D waste are also exported.

  A significant degree of uncertainty was noted with long-term waste disposal from Toronto and the Regions of York and Durham as the Keele Valley landfill is scheduled to close in 2002. Toronto is currently in the process of searching for long term waste management solutions. The Toronto Integrated Solid Waste Resource Management Process (TIRM) call for proposals (on behalf of Toronto and Peel, York and Durham Regions) resulted in several responses offering disposal in the U.S. York Region, in a parallel process, has also received proposals primarily from U.S. disposal facilities.

• Halton Region: it is estimated that at least 100 000 tonnes of NHW, mainly IC&I-based, are exported out of the region through two private operated transfer stations. Most of the waste handled by one of the facility operators (estimated at 57 000 tpy) is exported to an incinerator in the U.S.
  
• Region of Waterloo: 120 000 to 150 000 tonnes of NHW, mainly IC&I, are estimated as exported through three privately operated transfer stations. Two of the transfer facilities are suspected to be exporting to the U.S.
  
• Region of Peel: all municipal waste is currently directed to local landfills. As the primary site (Britannia) is expected to reach capacity by 2003, the Region is currently looking at future disposal options including export to the U.S. The Region doesn't track IC&I exports although data from a 1996 Benchmarking Report may be useful (pending).
  
• Region of Hamilton-Wentworth: no export of municipal waste is reported. Significant quantities of IC&I wastes are exported, however, with two privately operated transfer stations known to dispose of waste in the U.S.
  
• Region of Niagara: currently no exports of municipal waste are taking place. The Region has applied though, for amendments to Certificates of Approval for their municipal landfills in Niagara Falls and St. Catharines to receive waste from outside of the Region. Two major private sector waste management firms operate out of this Region, one with its parent company located in Niagara Falls, New York.
  
• Essex-Windsor: this area estimates that more than 100 000 tpy of NHW from the IC&I sector are exported to the U.S. through two privately operated transfer stations.
  
• Kingston: no waste exports reported.
  
• Simcoe County: some 25 000 tonnes of IC&I waste are presently estimated as exported (based on lost tipping fee revenues), a portion of which may be going to the U.S.
  
• Dufferin County: currently about 10 000 tonnes of municipal waste are exported, believed directed to the U.S.

Based on the preceding, a comparison of 1992 data (from the report entitled "Export of Solid Non-Hazardous Waste From Ontario") with currently derived data is as follows:

As evident from the above, based on information received from the Ministry of Environment and from municipal specific data, an estimated 770 000 tonnes of NHW waste was exported to the U.S. in 1998. The export figure for that year was comprised of an estimated 506 000 tonnes of IC&I waste and 264 000 tonnes of municipal waste, the latter from the Toronto/GTA area and Dufferin County. Areas reporting significant quantities of IC&I waste exports also included Toronto as well as the Regions of Halton, Waterloo and Hamilton-Wentworth, Essex-Windsor, and Simcoe County. In some cases, particularly with the larger Regions, annual waste exports from the IC&I sector were estimated at more than 100 000 tonnes.

The Recycling Council of Ontario also note a significant level of trade in recyclable goods with the United States. Aluminum, plastics, textiles, etc. are currently exported while, with respect to paper and OCC, Canada is a net importer.

U.S. Customs Data

As initially observed in the 1993 Ontario Export Study, two harmonized system U.S. Customs commodity codes are thought to account for most non-recycled waste shipments. These are: "other waste and scrap of paper or paperboard" - tariff #4707900000 (SIC9100 - thought to capture most residential and IC&I wastes); and, "sawdust and other wood waste and scrap" -tariff #4401304090 (SIC2499 - thought to capture most construction/demolition waste). While these codes potentially include some wastes destined for recycling and exclude other waste categories (sorted, uniform materials such as tires, glass, etc.), they continue to represent the best available information from this source.

For this study, the Buffalo Export Assistance Center of the U.S. Department of Commerce provided recent U.S. Customs data for the two commodity codes. The data supplied was for all border crossings between Canada and the U.S. No breakdown by state or port of entry was available but, as it was suspected that most of the waste movements were occurring from Ontario, this data is presented in this section. Reported flows exported to the U.S. were as follows (all figures in tonnes):

A trend of declining waste exports is evident from the data, following an increase in quantities from 1996 to 1997. The percentage decreases in waste exports from 1997 to 1999, calculated annually, are approximately 38% and 76%, respectively (using data from the first half of 1999).

It is noted that the combined figures presented above are significantly less than those estimated for 1992 as reported in the 1993 Waste Export Study. This is an interesting observation considering that the most recent data is for all ports of entry, and not just from Ontario.

U.S. State Data

As documented in the 1993 Waste Export Study, U.S. waste management officials from various jurisdictions estimated the following waste imports for various states: Indiana - 3 100 tonnes; Michigan/New York - 220 000 tonnes; Ohio - 540 500 tonnes; and, Pennsylvania - 267 868 tonnes. In all, a total of 1 031 000 tonnes of NHW was reported as entering American landfills from Ontario. For the current study, only data from the State of Michigan was available.

As discussed in Section 4.7, the Michigan Department of Environmental Quality published a report on solid waste landfilled over the period of October, 1997 to September, 1998. As noted therein, all state landfills are required to annually report the amount of solid waste received by point of origin. While it was recognized that the data may include some limitations, Canadian waste imports were estimated at 2 548 815 cu.yds. for this period. This annual volume translates to approximately 811 000 tonnes based on an average compacted waste density of 700 lbs/yd³.

It is interesting to note that the 1993 Ontario Waste Export Study estimated that 220 000 tonnes of NHW were exported to Michigan/New York (combined) in 1992. This estimate, however, was based on very limited data (with only 4 out of at least 12 facilities in these two states reporting data). Industry officials indicated during that time that the 1991 waste export figure from Ontario to Michigan was thought to be as much as 700 000 tonnes.

Ontario Export Summary

As discussed throughout Section 4, accurate data reflecting the transboundary movements of NHW is very difficult to obtain in the absence of reporting from private waste management firms involved in this practice. Notwithstanding, it is suggested that a significant level of waste export is still occurring. Estimated waste exports for 1998 amount to almost 800 000 tonnes based on data from provincial and municipal waste management officials.

As a comparative check to the preceding, U.S. Customs Data from the Buffalo Export Assistance Center was also examined but found to be of limited utility. Problems were encountered with commodity code definitions, for example, and no breakdown by state or port of entry was available. Further, with only 120 000 tonnes recorded for the first half of 1999, the Customs data is in direct conflict with known values from Michigan and Toronto. With regards to information from Michigan, that State's data was interpreted to conclude that approximately 811 000 tonnes of Ontario waste was received for disposal over the period of October, 1997 to September, 1998.

As to the future, there is considerable uncertainty associated with the long-term export of NHW from Ontario. In 2000, municipal NHW exports from Toronto are expected to grow to 450 000 tonnes and significant quantities of IC&I waste exports (including construction/demolition debris) are also anticipated. In the longer term, it is noted that the main landfill serving Toronto, York and Durham (Keele Valley) is scheduled to close in 2002. Peel is anticipating the closure of their primary municipal site by the start of 2003.

Toronto is currently in the process of searching for long term waste management solutions. The Toronto Integrated Solid Waste Resource Management Process call for proposals (on behalf of Toronto and Peel, York and Durham Regions) resulted in several responses offering disposal in the U.S. York Region, in a parallel process, has also received proposals primarily from U.S. disposal facilities.

As noted in Section 4, the 1993 waste export report did not reveal any data on waste imports into Ontario. Currently, the Ministry of Environment is only aware of one site receiving waste from the United States. An undisclosed amount of treated industrial waste is received at a private sector landfill in the Region of Hamilton-Wentworth.

As with waste exports, some data was available from the Buffalo Export Assistance Center, although only for one commodity code: tariff #4707900000 - "other waste and scrap of paper or paperboard". The data supplied (again no breakdown by state or port of entry available) showed imported quantities fluctuating between approximately 470 000 to 810 000 tonnes in the 1994 to 1999 period. While materials captured in this code are thought to include residential and IC&I wastes, waste import practices identified from other sources (see above) indicate that most of the noted material streams are not related to wastes directed for disposal.

Manitoba Environment Protection were unaware of any NHW exports from the province, only non-regulated bio-medical waste was identified as being shipped by BFI to North Dakota for disposal. No waste imports are also presently occurring. The preceding notwithstanding, the development of a provincial waste import/export policy has been recommended as part of a review of solid waste activities in Manitoba.

Saskatchewan Environment and Resource Management were unable to offer any specific transboundary movement data although they noted that there were a number of incidental imports/exports of NHW at border communities which share waste management facilities with U.S. municipalities. Imports and/or exports are not monitored or tracked by the department. The identified communities include the City of Lloydminster, the Town of Creighton and, the Village of North Portal.

The Saskatchewan Waste Reduction Council further identified one landfill, located in Estavan, as importing waste from the U.S. They also identified recyclable tires, plastics and aluminum cans as being shipped to the U.S. and scrap metal as being imported from Chicago.

Alberta Environmental Protection had no knowledge of any NHW export activity. The only activities in this regard identified in the province were related to recyclables (primarily waste paper to the U.S.). The Recycling Council of Alberta also indicated that some collected plastics travel to the U.S. and Pacific Rim countries. No waste import activities were identified.

The Ministry of Environment, Lands and Parks does not regulate the import and export of non-hazardous wastes (defined as "municipal solid waste" or MSW). The responsibility for MSW management rests with the 27 regional districts in BC and their MSW Management Plans approved by the Minister of Environment, Lands and Parks. Export and import of MSW requires authorization by the approved plan of the exporting or importing jurisdiction, and regional districts have authority under the Waste Management Act to ensure that MSW is disposed of only in authorized facilities by licensed haulers.

The Pollution Prevention and Remediation Branch of the Ministry identified the following waste export activities (all directed to landfills in Washington State): Fraser Valley - 8000 tonnes; and, Powell River - 6000 tonnes. The identified wastes included municipal, institutional and commercial refuse. No information was available for industrial wastes although substantial quantities of contaminated soil were reported as exported during the stakeholder consultation sessions. The Squamish - Lillooet area was further identified as potentially exporting waste to the U.S. in the future.

One landfill (Fort Nelson - Liard, recently renamed Northern Rockies) reportedly received a minor amount, in the range of 200 tonnes, of imported waste from the U.S.

As summarized in Section 4, there have been several other attempts to quantify Canada's transboundary waste movements. One example, described in Section 4.6, was a study prepared for Environment Canada entitled "Assessment of Canadian Trade in Wastes/Recyclables, 1988-1995". This study examined import and export statistics using Statistics Canada's Harmonized System (HS) codes - an internationally based system. The report identified significant limitations with the ability of the HS system to track waste types, whether destined for disposal or recycling. For example, some HS codes potentially contain both hazardous and non-hazardous wastes or encompass both wastes and non-waste materials. The Trade Information Enquiry and Retrieval System (TIERS) database, which records all imports and exports was also examined. While the TIERS database is, in theory, a comprehensive record of Canadian trade, its usefulness for waste analysis was again found to be limited as it is based on the HS code system.

Notwithstanding, most trade in wastes was noted to occur within the OECD, with our largest trading partner being the United States. The quantities of waste exported to non-OECD countries were noted to fluctuate significantly. Certain materials were further noted to be of potential concern as hazardous wastes to some receiving countries, even though they were not considered hazardous under Canadian (or international) regulations. Tires and waste plastics were two examples cited.

Accurate data reflecting the transboundary movements of NHW continues to be very difficult to obtain in the absence of reporting from private waste management firms. While actual quantities are unknown, however, a significant level of waste export still appears to be occurring, primarily from Ontario. Waste import levels are also unclear although they are assuredly taking place at a far lower level.

Where opinions were forthcoming from the stakeholder survey (Section 2.3), it was felt that economics played the most significant role in transboundary waste movements (primarily due to lower tipping/disposal fees in American landfills and (for imports) differences in currency values). Other factors noted were the proximity of neighbouring Canadian and American municipalities on either side of the border and the desire of multinational waste management firms to utilize their own waste disposal assets, wherever situated, for collected waste.

As recognized in Section 3.6, several provinces were identified as having policies or regulations in place to prevent or discourage waste imports.

While not a primary focus of this discussion paper (there is no authority in CEPA to regulate the export or import of non-hazardous recyclable materials), all provinces generally reported some degree of waste export and/or import activity related to recyclable materials. A report entitled

"Study of the Transboundary Movement of Waste Into/Out of Canada", May 1995, (see Section 4.3) examined the nature and impacts of the transboundary movement of wastes between Canada and other countries. The report focused on non-hazardous solid waste, but also looked at other waste and selected categories of recyclables. The estimated transboundary movements of selected recyclable material streams in 1992 were summarized as shown below:

The report identified several key related aspects to these material flows, including:

• with regards to secondary metals, the total value of imports into Canada and the estimated earnings by employees represented an economic impact of almost $577 million; and
• an estimated 4240 jobs were directly related to the availability of imported fibre. The total impact on the Canadian economy from waste paper imports was $336 million in 1993.

Given the scale of economic value and employment impacts involved, and the inter-relationships among the various waste streams, it was suggested that care should be exercised in examining significant changes to current practices/regulations.

In a related vein, a 1994 Policy Forum (Section 4.2) conducted by the Recycling Council of Ontario concluded, in part, that the export of solid waste to the U.S. was having a negative impact on the development of 3Rs industries. It was noted that waste diversion facilities which were established based on the expectation that sufficient quantities of materials would be available to sustain their operations were, in some cases, being impacted by waste export at lower prices.