What Are The Issues Preventing The Implementation Of A Leaf Landspreading Program In The Region Of Waterloo From A Multi Stakeholder Perspective?



Submitted by: Nicole Weaver, Ross Gardner, Melanie Nunez

Submitted to: Professor Susan Wismer on April 5th 2002 for ERS 250












a. Boundaries of the Research……………………11

b. Scope……………………………………………12

c. Limitations……………………………………..13

LITERATURE SEARCH……………………………….15


    1. Overview of Leaf Land spreading……………17
    2. Advantages/Disadvantages……………………18
    3. Stakeholder Perspectives……………………..19


a. Assumptions…………………………………….23

1. Iterative Process…………………………24 2. Sampling Rationale……………………………………25

b. Research Strategies……………………………26

1. Selections…………………………………27

c. Data Collection………………………………….28

1. Collection Tools and Rationale…………30

2. Data Management and Analysis Strategies……31


    1. Unfair Risk Management……………………………32
    2. Flexibility…………………………………………….33
    3. Familiarity……………………………………………34
    4. Time and Money……………………………………..35
    5. Simplicity and Clarity……………………………….36


MANAGEMENT PLAN………………………………..24

APPENDIX A — OCED CHART……………………………...45



















The leaf land-spreading group for the ERS 250 course of 2002 consists of Ross Gardner, Nicole Weaver and Melanie Nunez. These three individuals had a common interest in the process of leaf land-spreading and the groups and organizations that interact with each other within this system. On a more personal note, two of the group members, Melanie Nunez and Ross Gardner, hope that knowledge that they have acquired, can be shared with, and applied to soil-management practices in their own countries (Trinidad and St. Lucia respectively). The ultimate goal of this project is to propose ways to improve the administration and regulation of a sustainable leaf land-spreading program. As such, the thesis question of this project is: ‘Issues affecting social acceptance and sustainability of leaf land-spreading practices in the Region of Waterloo from a multi-stakeholder perspective’. The intended result of this project is to arrive at a set of recommendations which would complement each stakeholder group involved in this program, leading to further improvements in the overall utility of the system.

These recommendations will be fully inclusive of factors such as:

As mentioned above, this research was undertaken by a group of Environment and Resource Studies students as a graded component of the course called Greening the Campus/Community. The research team is comprised of second year students whose experience with conducting research projects is limited. Their qualifications for this project are inadequate in terms of experience with conducting researches and writing reports. In addition to this, the budget and resources for this project were limited, because of the fact that this is a second year course project. There was a lack of information on leaf land-spreading, and a troubling unavailability of interviewees had to be dealt with. With this in mind, the following information is what has been gathered, taking into consideration the scope of the project and its limitations.


The concept of leaf land spreading is that it is simply a tool for combating the un-sustainability in a waste disposal system, by reducing the amount of leaf waste that it sent to a landfill. . In an age where Ontario’s landfills are facing the major issue of lifespan, (the current operation in Waterloo is estimated to be in operation until 2020. It began operation in 1972, and there are a total of 175 acres licensed to be used for landfill purposes) and prospects for new sites are limited (in 1997 approx. 10% of Ontario’s 1,365 active landfill sites reached capacity), leaf land spreading presents an opportunity to divert waste otherwise destined for land filling.

Currently, Bill 81 enlists "provisions for the development of strong new standards for all land-applied materials containing nutrients". Legislated on June 13th, 2001, this law also addresses the weaknesses of the current regulatory systems and ways in which they can be strengthened. The Bill proposes to "build on the existing system by giving current best management practices the force of law, and creating comprehensive, enforceable, province-wide standards to regulate the management of all land- applied materials containing nutrients" . In other words, the overall goal of this Bill is to give legislation with regards to nutrient management practices more teeth.

Notable is the fact that leaf-waste presents a challenge to municipalities, which are more familiar with recyclable waste, in that it has the potential to be sold for profit, but requires multi-stakeholder support to be realized and become successful. Aside from this, leaf land-spreading activities would be beneficial in improving poor soil quality. A February 2002 article in the Biocycle Journal titled "Linking Organics and Zero Waste" reports that "30% of farm soils in the UK were deficient in organic material". Another report to the World Wildlife Fund stated that three quarters of southern European agricultural soils have a 2% or less organic carbon content. Canada is also the 25th out of 28 OECD (Organization for Economic Cooperation and Development) nations for the highest fertilizer rating (See Appendix A for chart). These reasons show us that there is a need for a program like leaf land spreading.

With regards to the group’s own interest in the project, as explained before, it is for a variety of reasons, such as information transfer, self-fulfillment, contributing to the University of Waterloo community, and the Kitchener-Waterloo community at large, that drove this group towards the choice of this particular project. The topic of leaf land spreading is an area of great interest to the group because it also has implications with concerns of bad management of Biosolid waste and the subsequent human health effects. The "Post-Walkerton Syndrome" has many citizens of Canada very leery of the government’s actions (or lack thereof) in this field.

For this project, there is no proposed study site because the thesis question lends to a more qualitative approach to research. The majority of interviews were conducted in the office of Mr. Mike Birett at the Waterloo Waste Management Facility, whilst the telephone questionnaires were conducted at the house of one of the group members. Hence, there was no major study site for this project and the individuals studied were subjects for the interviews such as key informants and farmers. Because there is no major proposed site and the information to be retrieved is of a qualitative nature, the baseline data for the project is either non-existent or varies due to the source from which it came. The available baseline data includes information on the current regulatory process for leaf land spreading (known as a Certificate of Approval), biosolids management and proposed government reforms with regards to soil management practices. In general, the majority of the data is descriptive whereas, this project aims to provide research that is more exploratory.

Sustainable soil management and an ideal regulatory system are major topics of interest on many administrative agendas. Sustainability can be defined most generally as purposive social change in which short-term benefits do not reduce long-term opportunities. The Regional Municipality of Waterloo has expressed concern about the rising costs of composting and the importance of soil quality in the light of economic, environmental, and social factors. Since 1996, the Municipality has been providing composted leaves to area farmers to ensure adequate crop nutrition, thereby increasing soil quality and encouraging the limited use of chemical enhancers. Currently, the regulatory system applied to this process is the Certificate of Approval (C of A), which is authorized by an administrative process that has provincial jurisdiction over these matters. Although the Permit by Rule has not been approved and practiced, it has been conceptualized so that it is in accordance with the stringent quality management standards that oversee the C of A. Also, the Permit by Rule concept is different from the C of A in that, it is modeled for smaller scale, lower-impact projects. Most importantly, it is based on standardized regulations rather than site-by-site ones. As mentioned before, the three major stakeholders involved in the leaf land spreading procedure are: the Regional farmers, the Municipality of Waterloo, and the Ministry of Environment. Each stakeholder has a defined role, which will be explained later. The implementation of a leaf-composting program has become complex and therefore causes difficulty to each party due to varying perspectives. This research project aims to uncover the issues preventing implementation of leaf land spreading and to make recommendations to each stakeholder in an attempt to receive results that would complement the goals of each group.

An examination of the dynamics of the leaf land spreading program is important so that the following results are facilitated:

(1) an improvement of the condition of the soil and to help prevent topsoil erosion of farmlands

(2) a decrease in landfill bulk thereby lengthening landfill capacity and

(3) a reduction of the use of artificial conditioners like fertilizers, thus lessening the risk of run-off and contamination of water supplies.

The literature available for the understanding of this project is very limited because of the relational and analytical stance that the group members are aiming for. As such, the available documentation is descriptive and lacks investigative depth. Consequently, it includes information about the current regulatory processes for biosolids management in Canada, the Nutrient Management Act, the Certificate of Approval and the Permit by Rule systems and government reform in view of social deregulation. Though it is not sufficient, the available literature is very applicable to this project because it provides background information for the baseline studies that have been performed for leaf land-spreading practices. It is not a comprehensive set of data because it does not make mention of detailed research that has been credible and persuasive enough to lead case studies (where improvements to the regulatory system have been incorporated) into full implementation.

This fault further indicates a lack of accountability on the part of government’s duty, and the increased need to see a more active role played by the citizenry, in ensuring that research to better the lives of the population is continued. In light of the latter, the existing information implies that reconstructive work to the regulatory system for leaf land-spreading has not been given serious consideration.

In this respect, this project aims to target the loopholes of previous research on this topic by addressing areas of alternative regulatory systems specifically the Permit by Rule system, increased public education, consultation and involvement and actor communication. Therefore, the chief expectation of this project is to provide solutions and recommendations that would improve the stakeholder relationships of the leaf land-spreading program and ultimately, lengthen the lifespan of its practice. In general, this project is target towards a readership that includes members of the farming community, the Ministry of Environment, residents of Waterloo and the Regional Municipality of Waterloo Waste Management Facility. With this accomplishment, the group members of this project are hoping that the work that they have done for this project would be persuasive enough to create a mobilization towards a sustainable leaf land-spreading program.


The main objective of this study is to examine the issues affecting the social acceptance and sustainability of leaf land-spreading practices in the Region of Waterloo from a multi-stakeholder perspective. The idea of sustainable soil management and an ideal regulatory system using an exploratory approach based more on qualitative research methods was employed. In order to derive at recommendations that would improve stakeholder communication, increase public education, awareness, involvement and consultation, government accountability and the effectiveness of the leaf land-spreading program for the Ministry of the Environment, the farmers, Waterloo community and Regional Municipality of Waterloo Waste Management Facility.


The main question of this study is: What are the issues affecting social acceptance and sustainability of leaf land-spreading practices in the Region of Waterloo from a multi-stakeholder perspective? Hence, the sub-questions of this study are as follows:

1. What is leaf land-spreading and how is such a program practiced in the Region of Waterloo?

2. What is the current regulatory process that oversees the program and what role does each stakeholder have in this program?

3. What are the disadvantages to this program and how can a Permit by Rule system be a more effective replacement?

4. What are the obstacles that prevent this Permit by Rule system from being implemented?

5. What recommendations can be given so that legislative and administrative changes could be made to have the Permit by Rule system implemented?



Current leaf land-spreading program

and regulations


E.R.S. 250 project

Issue Identification

Policy Analysis and Options

Internal Ministry of Environment

information and perspectives

Literature review such as government

document (e.g. CIELAP, Nutrient Management Act)

Farmer Interviews

Environmental Consultant interviews

Information from Regional Municipality

of Waterloo Waste Management Office




Leaf land-spreading program Re-Design

and implementation planning




A strong Policy Analysis and Program Capacity












Definition of terms

Leaf land-spreading The practice of collecting leaves from the yards of

Private home owners by the town’s Waste Management Facility, which in turns, oversees the composting of the material to be sold for profit or otherwise

Sustainability The strategic use of present day resources so that future day reserves are enough for the population

Nutrient Management12 A plan for storing, handling and land application of manure, sludge or other nutrients used for agricultural fertilizer, while minimizing adverse environmental effects. Such plans should take into account variables such as soil, water and weather conditions.

Permit-by-Rule12 A regulatory system that "deems" regulatory approval to exist where a company operates within parameters set by regulation, rather than requiring individual Certificates of Approval or other permits for each case.

Certificate of Approval12 A permit issued by a Ministry under a specific provision in an Actor regulation that allows the permit holder legally to discharge a limited volume of polluting substances or carry out an activity that may have an adverse effect on the environment, according to terms and conditions set out in the permit.

Land doctoring Measures taken to treat environmental problems on a superficial level rather than getting to the root of the problem







Scope of the study

The boundaries of the study are very restrictive. This study can be categorized as a case study and as such, the geographical boundaries are demarcated as the municipality of Waterloo. The time given to execute this project was three months as the exercise of this project is contained within the winter term of 2002. Because the purpose of this project is to analyze the leaf land-spreading program in Waterloo and to make recommendations on how it can be improved with regards to stakeholder relationship, the units of analysis are measured as responses to the various questionnaires and interviews conducted. This data is not quantitative and therefore cannot be aggregated or easily misconstrued. Particular attention is paid to this matter because it is very important that the opinions of each stakeholder in this project are clearly stated so that information transfer between the actor groups is made possible. Therefore, the methods of this project are constructed in such a way as to promote the attitudes of the respondents and apply an analytical approach so that revisions can be made.

The conceptual framework presented above is based on the concept of eco-development. Unlike land doctoring, principles embedded in this framework deal with environmental management; on the basis of taking active steps towards treating the root of environmental problems instead of the symptoms. As such, the conceptual framework used for this project builds on the foundations of baseline data to produce an ideal regulatory that is sustainable and mutually beneficial to all stakeholders. As opposed to this conceptual framework used in the past was insufficient. Its deficiencies are evident in the respect that the regulations and programs borne out of this framework are symptomatic in its treatment of environmental problems. Generally, C of A and other command-and-control regulations are "termed negative because it institutionalized an approach that focused on damage control: on repairing and setting limits to human activity. Rather than focusing on ways to improve both development actions and ecological resilience, this approach was inherently defensive or remedial in practice".

The main assumption at the basis of this framework is that, through exploratory research and integrative modeling, soil management and other environmental practices would be propelled from a state of institutional paralysis to sustainable capacities. The framework provided in this project is very well suited for the objectives which the group members would like to achieve. Furthermore, this framework is geared towards expanding the restrictive limits of previous ones, to mechanisms for increasing the efficiency of the leaf land-spreading program.



This was considered one of the major limiting factors of our project; it had to be completed within a time span of under four months. The nature of our project was such that we needed to get in touch with and interview several people. This is a lengthy procedure. Our work would have been nearly impossible to complete if we had not been part of an iterative study framework.. This allowed us to target specifically those farmers who were interested in participating in this program. Restraints on the total amount of time that we could spend on the data collection portion of our study forced us to make the decision to cut out several qualitatively oriented interviews. Increased time would have also enabled the researchers to contact various NGO’s such as local farming organizations in Waterloo and larger ones such as OMAFRA (The Ontario Ministry of Agriculture, Food and Rural Affairs.) These would have further contributed to the breadth of information that we collected for this project.




Money is considered a restraint to this study for several reasons. There could have been some sort of financial remuneration for the participation in this project of the farming community members. We could have probably persuaded more members of the farming community to participate had we said we are going to reimburse you for your time spent in this interview session. The reason for this is that the people who we got through to who did not participate were not able to because of being too busy otherwise. In other words we need to somehow make participation worth their while.

If we had a budget to work with we could have interviewed consultants who work independently on the C of A process. A meeting could have been scheduled with these persons, and then they would be reimbursed for their participation, at what ever their rate is for an hour of their time.

Scheduling of Interviews

The actual scheduling of times and locations for interviews was a major problem. We were unable to get through to several of our informants to arrange for this project. The reasons for this are that some of the consultants we were planning on interviewing were on vacation/out of the country etc. also trying to find a time and location that would be suitable for both the researchers (ourselves) and our interviewees was a tiring process.


Ministry Strike

At the time of our conducting this experiment we were unable to get through to our key informant in the Ministry Of Environment (MOE). At the commencement of interviews the MOE workers were on strike. This had the effect of us not being able to obtain the perspective of someone who was involved in the process locally — the Guelph office of the MOE. Up until the writing of this final report, the MOE was still on strike, and thus unable to conduct more than one interview.


The literature and information available on this topic is extremely limited, there has been very little external research done on the administrative systems in place. Any information that we gathered about the C of A regulatory system came directly from the Ministry of the Environment or through the Regional Municipality of Waterloo. Even after conducting searches on the internet for our information in this field; we found very little, most of the data that was found online came from the Ministry of Environment website. The only aspect of our project on which slightly larger amounts of data were uncovered was on the physical rather than the administrative processes of leaf land spreading. Information on the Permit by Rule system was non- specific and we found that a lot of the information gathered was not applicable to the Regional Municipality of Waterloo’s situation. This was due to most of the information coming form the US and the UK which do not share the same administrative framework as Canada. The only examples of Municipalities employing the Permit by Rule system in Canada were those dealing with Biosolid waste material. A major problem that arose in the literature search was that no coherent set of guidelines for the implementation and administration of the Permit by Rule system could be found. Searches of the government publications section of the Dana Porter library at the University of Waterloo yielded no relevant results.

There were also attempts to research another system, which was similar to the Permit by Rule system. This system is called SAR (Standardized Approval Regulations). Searches at the library at the University of Waterloo and journals again yielded no relevant results. The only information that was found on this system was on the Ontario Ministry of Environment website. This information did not describe the system, it merely made reference to what the system was designed to achieve. Below is an abstract of the information that was gathered on the admistrative processes.





Overview of Leaf Land Spreading

What is leaf land spreading?

A historical prospectus of leaf land-spreading shows it to be a multi-leveled process with many stakeholders involved. First, the Municipality collects leaves from its ratepayers through a process of curbside vacuumed collection or pre-bagged bundles. The next stage involves the transportation of the leaves to the composting facility at the Waterloo Landfill. The appropriate conditioners such as nitrogen are added to achieve a balance with the high carbon levels found in the mulch/compost. The leaves are placed into long columns or windrows until the conditions are deemed suitable by an onsite agronomist. The leaves are then transported from the windrows to farmers who subsequently spread the material with a front loader or a conventional manure spreader on their fields. This is followed by some form of tilling into the topsoil to a depth of less than 10 cm. This process can be summed up as a soil conditioner improving the general quality of topsoil (See Appendix B).



Advantages/ Disadvantages




The Ontario Ministry of the Environment.

The Ministry Of The Environment is the overseer and enforcer of all waste management related regulations in the province. It is associated with the government of Canada and therefore has the power to create or eliminate any policy or regulation. The Ministry is responsible for the issuing of the Permit By Rule or Certificates Of Approval. Its role is not limited to the issuing of these certificates; it is subsequently responsible for monitoring through such tools as on site scientific analyses. In the context of leaf land spreading, an agronomist or soil/chemical analyst reports to the Ministry about the sites compliance to the relevant regulations.

The project scope aims to achieve a comprehensive overview of the administrative perspective of the Ministry Of The Environment. As the primary decision making body, the Ministry of the Environment’s primary objective is to ensure the facilitation of all participating stakeholder requirements and this is addressed with due consideration of the appropriate regulations. The main goal is to achieve a balance between regulations and stakeholder requirements. The motivation for the Ministry, that is, to ensure that stakeholder requirements are met, lies in the fact that without stakeholder approval the project would not take place. This however is not always the case, and many times the lackadaisical bureaucratic nature of government sometimes disregards the other stakeholders’ objectives.

The "final word" nature of the Ministry translates into the facilitator of the leaf land spreading project being responsible for ensuring compliance before it goes under the scrutiny of the Ministry approval process.

The main sources for obtaining a further understanding of how these administrative perspectives function will be obtained from interviews with Greg Athron, the Senior Environmental Officer at the Guelph office of the Ministry of the Environment and Graham Whitelaw, an adjunct lecturer with the Faculty of Environmental Studies at the University Of Waterloo. Mr. Whitelaw has several years of experience working in the Ministry of the Environment. A background foundation of the functions of the Ministry will be obtained by performing relevant literature searches.


The Municipality/Consultants

Our project aims to produce an unbiased perspective. To achieve this end, we are going to perform interviews with people who have experience and expertise in the areas of administrative and regulatory functions. The intent is to interview three people to further this aim.

Graham Whitelaw (previously mentioned) will provide project focus with an outsider’s perspective of the advantages and disadvantages of the bureaucratic nature of the MOE. Allison Huntley is a professional consultant who has an intimate knowledge of the C of A approval process, due to her independent work in this field. Mike Birett is the project manager for the Regional Municipality of Waterloo’s waste disposal system. Mr. Birett will help us obtain the views of the main facilitators’ standpoint on the leaf land-spreading program. His goal is to increase the sustainability of the Region’s waste disposal system and to this end he is the main proponent of the leaf land-spreading program.

We hope to corroborate the perspectives gained from these interviews into an informed, unbiased viewpoint of the issues involved in the administrative and regulatory processes of leaf land spreading.

Farming Community

The outcome of the MOE approvals process and the roles of the facilitator have a direct impact on the Regional farming community. Farmers designate land to be harvested, are responsible for various agricultural processes such as crop rotations, and the purchase and maintenance of the necessary machinery. This stakeholder provides the physical labor necessary to obtain agricultural produce and is a beneficiary of all the funds allotted from crop production. The Regional farmer will maximize crop output with adequate facilitation, and standards that are practical, simple and within their annual budgets. Overly strict regulations will cause increased difficulty and inadequate regulations may affect the health and safety of the community at large.

With regards to the purpose of this research, gaining the personal opinions of the actual harvesters could lead to efficient and viable policies being put into effect. This will uncover the issues preventing farmers from participating in a leaf land spreading program. To gain this perspective we plan to review and possibly re-evaluate past farmer surveys supervised by the Regional Municipality of Waterloo’s Composting Coordinator, Clark Riechert. We intend to re-evaluate the representativeness of, and update the information presented in the past surveys. This however will be limited by the financial and temporal limitations of the project. The perspectives gained from these surveys will aid in re-establishing the issues facing the leaf land-spreading program. This information will be shared with the other stakeholders and in order to achieve an equitable balance between all participants. (See Appendix C for illustrative diagram of the interaction of these roles. All of these perspectives take into account the issues of the general community).

Certificate of Approval (C of A)

A C of A must be obtained before waste can be applied to agricultural land. The application process involves compliance with the 1996 guidelines for the utilization of bio-solids and other waste on agricultural lands. Once compliance is met, the completed C of A document must be submitted to the local Ministry of the Environment (MOE) district office for review. This application process has to be completed for every site that the Regional Municipality of Waterloo proposes to use in its leaf land-spreading program. It is a costly, time-consuming procedure that threatens the very viability of the leaf land-spreading program.

Permit By Rule

The permit by rule concept is based on the investigative analyses of compatibility with guidelines. Issued by the Ontario Ministry of the Environment, this regulatory system is based on the demonstrated responsibility of the applicant. It is determined by the compliance of the applicant with the appropriate guidelines, and an adequate mitigation of (possibly adverse effects) found during effects analysis. The effects analysis is performed in both the biophysical and the socio-economic realms. The permit by rule concept attempts to address the regulatory needs of small-scale projects that are hindered by the C of A system. It is a customized regulatory policy that has its basis in sound scientific evidence; it assumes the perspective of the precautionary principle. The Permit by Rule concept incorporates flexibility into the regulatory process, allowing for a shortened application process.


The study consists of three main areas that enabled the research to achieve a triangulated approach. Literature searches, interviews, and surveys were the components of data gathering that helped to formulate the perspectives of each stakeholder. Firstly, we undertook various literature searches to gain a foundation for the systems that would be dealt with in the surveys and interviews. This was necessary to achieve before the interview/ survey process to identify ambiguities and clarify any questions that the participants had. The interviews were done on a face to face basis or if scheduling posed a problem, were conducted over the telephone. Interviews were primarily for the regulatory bodies of consultants, the Ministry, and the Municipality. The questions aimed to undercover the issues preventing the implementation of the system. Scaled and open ended questions were used as well as a section for further remarks on any of the issues discussed. Finally, the surveys given to the farmers were undertaken by telephone communication and asked the farmers various scaled questions pertaining to sustainability issues as well as open ended questions to identify the reasons preventing them from implementing a leaf land spreading system on their properties. All the participants from the farming community were chosen because of interest that was expressed previously and gain an accurate representation of the views of willing participants and the issues that they felt were major obstacles associated with this system.


Iterative Process

This study is mainly qualitatively based and therefore takes on an iterative process or more simply, a cyclical process that is based on the refinement of previous studies that were undertaken. In context with our research, the leaf land spreading area has been researched previously by the Municipality, the report entitled, Leaf Land Spreading Initiatives, deals with the process of certification, scientific regulations, surveys to farmers undergone by the Municipality, costs associated with the program, and the results and recommendations of the findings. As a result, the next phase of the researching was to undercover the issues hindering implementation. Interest within the farming community existed but had to be further evaluated. This past study compiled 73 completed surveys to farmers, of those, 6 were interested in the program and had telephone numbers. We surveyed these interested individuals and aimed to further gain an understanding of their perspectives. The question was refined into finding out the specific issues that were stalling leaf land spreading within the community. The interviews given to the Municipality, Ministry of Environment, and the Consultants were done on an exploratory basis to compare and contrast the responses of the farmers and those of the regulatory sectors. A large problem preventing the program is the complexity and inflexibility of the regulations involved. To discover the different perspectives recommendations could then be made that would encompass the concerns of each stakeholder.


The composition of the methodology takes many facets into account. Upon the start of the study we conducted literature searches to gain an understanding of the information to be utilized in the data gathering processes. When the interviews were created we aimed to find participants would have an understanding of the Certificate of Approval and the Permit by Rule procedures. Intensity sampling was used to save time educating participants with the details of the program which only had a span of approximately 3 and 1/2 months. Intensity sampling methods involve, "sampling people whose interests or vocation make them experiential experts because of their frequent or ongoing exposure to a phenomenon." Hence, we surveyed farmers directly impacted by the regulations set out by the Ministry and the programs and guidelines enforced through the Municipality and Environmental Consultants. We also interviewed employees the Ministry of Environment dealing specifically with the current regulatory process (C of A) and how they their decisions affect the other stakeholders and ways upon the current system could be approved upon. The Municipality and Consultative actors were asked for their specific opinions on the current system and basically the issues that are preventing the program. These stakeholders have to make sense out of the Ministry guidelines and cater to the wishes of the farmers. Although these participants had an understanding of the regulatory systems, a definition of the Certificate of Approval and the Permit by Rule were provided before the questioning began. Essentially the participants were chosen specifically for their knowledge in the research area and to undertake meaningful valid research under the time constraints that were set out.


The three researchers of this study are Ross Gardner, Melanie Nunez, and Nicole Weaver who are in their second year of environment and resources studies all minoring and specializing in various other areas. The report and presentation were worked on together as well with some individuals undertaking work alone. Ross Gardner, who had a specific interest in the consultative and regulatory sectors of the project agreed to contact these participants and interview them also complete the write up for this section. Melanie Nunez, the lead proofreader, re-evaluates the compiled data for submission. She conducted many of the farmers by telephone and questioned them as well as completing the write up for this section. Nicole Weaver, the secretary, is responsible for posting information on the web board and conducted the Municipality and Ministry of Environment interviews. The ethics submission was completed by all members as well as the creation of the interview questions and surveys based on interest and background information of the researcher associated with that specific area.


With respect to our research topic, our main selected strategy is to conduct a nomothetic analysis. Nomothetic analysis involves, "the analysis of relationships between variables." This would pertain to our survey and interviewing results and the analysis between the given responses in relation to one another. Through the response analysis, we will be able to make recommendations to each stakeholder on behalf of the others, basically drawing conclusions that take all the stakeholder responses into account. Another option we had was to identify case studies, contact these facilities and gain a greater knowledge of how they dealt with stakeholder issues with respects to creating a leaf land spreading program. The Regional Municipality of Waterloo was researching the formation of a Permit by Rule system for the program and due to the infancy of this system, no case studies existed in Canada, in the United States and the United Kingdom, however, there were numerous using the Permit by Rule system. These case studies would have aided in our recommendation portion to the Region, however the politics of the Unites States and the UK Permit by Rule system do not apply in Canada. Perhaps the Region could draft a model Permit by Rule using examples from the following case studies:

    1. En Vision Project, Middleton County, Cork, UK- landfill with composting
    2. Withering Garden Club, England- composting mixed with manure
    3. Greenwaste Recycling Depot, St. Annes Park, Rahey, Dublin- licensed and use windrows, charge small fee to drop-offs and pick-ups.
    4. Maine Department of Environmental Protection Permit by Rule NRPA

5. Virginia Department for Environmental Quality, Permit by Rule for Yard Waste Composting Facilities

With regards to these case studies of international composting, many agricultural groups also research this area. Ron Fleming, a compost researcher at the University of Guelph, a relatively local community, is discovering ways to optimize composting in the area. The most relevant strategy to use in context with our research topic is the nomothetic analysis as case studies for on-site composting using the Permit by Rule system are non-existent in Canada aside from the use dealing with Biosolid waste management


The data collection began with our research gaining approval from the University of Waterloo Office of Ethics and Research. Ethics is a process that must be undertaken when human participants are being used for any part of the study either physically or mentally. We submitted out Ethics Proposal in Early March, it was returned to us asking for corrections with our questionnaires and participant letters. The corrections were made and our study was approved by Ethics on March 20, 2002. This posed a problem for our data gathering and will be further explained in the limitations portion of this submission. The interviews and surveys were created by group members who had relevant experience thus far with regards to researching. The questions were reviewed by all group members and also looked over and pre-tested with the Region participants, Mike Birett and Clark Reichert.

Our chosen participants were given an information letter detailing the project and why their input was requested (See Appendix B for all relevant information). At the end of the project details, the participant was to sign a consent form. (NOTE: only those participants questioned with face to face methods were asked to sign the consent, all others were asked for consent over the telephone.) If the interview date was not set up ahead of time, this usually took place all at once if the interviewee had time. The questions were asked verbatim of what was lined out with a normal tone of voice and no inclusion of extra wording that may or may have not been bias. For each stakeholder group there were scaled and open ended questions to gain a greater understanding as researchers of the different perspectives and the way each group chose to answer the questions (See Appendix B for Survey and Questionnaire). Following the questioning, the participant was either given an appreciation letter with all the relevant contact information to gain further to information access to the study. If addresses were available, the farmers and the Ministry will be mailed appreciation letters.


For the research we conducted surveys and questionnaires were used. Surveys were give to the farmers and were questioned over the phone. The telephone gave the interested farms a sense of anonymity for their personal practices and names were collected if the farmer was interested. Due to the nature of the farming practices it was difficult to consult the farmers with on-site questioning and finding an appropriate time. This also gave the surveyor direct monitoring of the questions being asked and to clarify any questions or unclear responses. Due to the Ministry of Environment strike, finding participants was challenging, once the key informant was identified specific times had to be arranged to contact these individuals. For the Region and Consultative participants, face to face group or self administered interviews were conducted. This was chosen to obtain high response rates for the data. There was initial conflict with the interpretation of questions by other participants and after the pre-test some questions were eliminated due to duplication. This approach of questioning had a more relaxed atmosphere compared to the telephone interview and overall the responses were of better quality. At the conclusion of the interview a comments section was included for the participants to further elaborate on any of the previous material and this section gave us further information to research for the final submission.



To record the accumulated responses, the interviews were mainly conducted with two researchers, one to ask the questions and the other to record the responses. The completed data was kept together in a folder to be later evaluated.

Because of the qualititative nature of our study, our analysis of the data would involve compiling similar responses and comments taking into account suggestions for the system; and coming up with a comprehensive strategy for the further development of the program. We intend to put forward a set of recommendations which are based on our findings. We will also discuss the views of each of our interviewees.



In the summer of 2000, employees of the Regional Municipality of Waterloo Waste Management Facility undertook a survey involving local farmers and their current agricultural practices and willingness to participate in the leaf land spreading program. There were 73 telephone interviews completed, of those 43 declined to listen or participate in the program, 6 were interested, and the remainder could not participate due to various other reasons pertaining to their personal properties. Some of the reason they could not participate were issues such as the land being too small, the soil type was inappropriate, the system incorporation was difficult and/ or too much work was involved. For our project the 6 interested farmers from the past surveys were contacted to get further information with regards to their current perspectives of the leaf land spreading program. Out of the 6, we were successful in contacting and surveying 3 via telephone. The farmers were questioned on:

        1. Their current soil management practices
        2. Their considerations of leaf land spreading for their farms
        3. The issues that were preventing them from participating this far.

Due to the conservative nature of the farmers and the information given to us from the analysis of the previous survey and the surveyors, the farmers would pose a challenge getting in contact with and probably be adamant to incorporate a new system on their farm if they have not heard about it from other farmers who already used the program. Results remain the same from the previous survey and to confirm that interest was still present.

The results were that 2 out of the 3 farmers were not interested in considering the program for their farms. The reasons were those of liability, soil compaction by the Municipality trucks unloading the leaves onto farmland, and contamination of the soil by the leaves themselves. To begin, the number of farmers interested for further questioning was small. The number of successful interviews was very small and much of the results from the farmer’s perspectives had to be sought from the previous survey. It can be assumed that most farmers are not interested in a leaf land spreading program. The current regulatory system, the C of A does not encourage the farmers to accept this program due to the strictness, length, and simplicity. On the other hand, if a Permit by Rule system can eliminate most if not all of the disadvantages that a C of A has to a leaf land spreading program.



Results (Municipality and Consultant)

Due to the nature of our interviewing portions, questions were asked to gain an increased understanding of the systems at hand as well as a perspective of the Municipality and Environmental consultant with regards to the issues preventing the program from being applied in the Region. Taking all the project limitations into account 3 interviews were conducted with this group: Mike Birett, the Senior Project Coordinator for the Regional Municipality of Waterloo Waste Management Facility, Clark Reichert, the Senior Composting Coordinator for the Regional Municipality of Waterloo Waste Management Facility, and Graham Whitelaw, a professor at the University of Waterloo Faculty of Environmental Studies, who also has extensive experience with Environmental Assessment and Environmental Consulting. Initially, the project predictions were that all three of the participants from these sectors would have generally the same opinions about the systems at hand, however, this was not the case and data aggregation was rather challenging. Also due to the nature of the research topic, asking scaled questions would not provide the appropriate background information or give the sense of a perspective from these stakeholders. The results focus in the issues preventing the leaf land spreading program that have the most combined responses from both groups or those responses that were repeated various time by the interviewed.

Unfair Risk Management

This can easily be defined as, " a process that weighs risks about what often is an uncertain event, that could possible happen against factors such as societal values, economic costs, technological and political feasibility, legal considerations, effectiveness of the actions and fairness." According to the data gathered from the interviewees, the C of A system does not take into account the risks for sites, "the same C of A exists for a drop of nuclear waste and a barrel of nuclear waste. There is no tailoring to substances used under the system and although the Region uses the C of A system currently, they still must complete the same certification as a nuclear waste manager. This was rated as the most important for wanting to implement the Permit by Rule, which would take into account the use of different substances. This system, "is not worth it to us to use a non-hazardous ecological system and have to deal with the standard C of A, there is an absence of logic, the system needs to be simpler and it costs too much money."


This was another major concern that was made apparent thorough the interviews. Also the certification relies strongly on regulations and discourages from adaptive learning. Any changes to the C of A, no matter how minor, require "a stringent amendment process that may involve waiting for many months to receive. It is unreasonable for what we are trying to achieve". This process is also costly and technical to process. A main reason these changes are so hard to achieve is, "the inconsistency of the protocol which needs to be re-evaluated every 5 years, to address successes and pitfalls of leaf land spreading". "There is also a fear of job security and accountability." The ministry tends to suffer from inertia, with no one who has the authority willing to take the initiative for fear of repercussions. Sadly this is a by product of our reactively oriented democratic society. We need to orientate the decision making process to one that is preventative and proactive rather than remedial and reactive. Only then will we be able to avoid such sad incidents as the Walkerton crisis.


This was a result that was not predicted but gives added insights to the C of A process and regulation. The Regional Municipality of Waterloo is currently operating in compliance with C of A #A140301, issued in November 1993, this C of A has been operating for approximately 8 years with minor changes being made. There have been no problems or adverse effects with their experiences. Due to the stringent guidelines in the Certificate of Approval again there is no room for change and to those that have been successful with the system, it offers not ease of technicalities or room for change, nor does it offer specific tailoring to their specific needs.




Time and Money

The lengthy approval process was an issue for all the interviewees. The time span of waiting for an approval or changes takes too much time. The certifications are costly to complete comprising $1000 of the total $2,938 of the cost estimate per farm site. As well the certification must be completed every 5 years with no changes being made to their specific sites. Many of the stakeholders believe that monetary incentives should be given for achieving a higher level of performance than the C of A

Simplicity and Clarity

The Municipality would like to see some sort of simplification of the paperwork involved in the process. This would lead to lead to an immense reduction in the amount of time spent on the approval process and reduce the chances of error. A simple framework with clear guidelines would also allow for greater control of the monitoring and implementation of this system. Overall, this would lead to a significant reduction in administrative and implementation costs.

Results (Ministry of Environment)

We targeted people in the Ministry who have worked with or are currently working with the Certificate of Approvals Process, this would enable us to gain information pertaining to the current process and assess the feasibility of implementing an easier system. Also it questions their perspectives of the implementation of the Permit by Rule System as an alternative. Due to the strike within the Ministry was Allison Verbaas. The information that we obtained from her was very vague and she feared giving us specific information as it may get back to her. She did not want to speak on behalf of the Ministry and therefore our interview portion for this stakeholder was very vague, she did however direct us to some important government documents that would be of assistance. We had hoped to obtain a comprehensive overview of the administrative system and hopefully gain an idea of what changes to the current regulatory system are possible. According to Alice Verbaas, the questions that were asked and many of the information that was gained to formulate the questions was contradicted. When asked if the Ministry would be in support of providing farmers monetary incentives to use environmentally friendly means on their properties, the answer was ‘no comment, as the Ministry’s opinion could not be demonstrated through one of the employees.’ Contradictory to this account the upcoming Kyoto crisis has showed concern for agricultural practitioners and guaranteed to compensate them if they use environmentally friendly practices on their farms to further promote sustainability and also to help eliminate further emissions. Essentially the results gained from the Ministry were insufficient to draw upon any real conclusions except that of government complexity and fear of accountability.


The following set of recommendations pertains to all the stakeholders involved in the leaf land spreading process that the group has comprised following the data gathering and analysis. To fully implement a leaf land spreading program with the Municipality of Waterloo, including the appropriate regulatory systems, Ministry protocol, and values of the farmers these recommendations serve as a starting point to achieve increased communications between stakeholders and acknowledgement of values of each of group.

Feedback from Farmers

The farming community is one of the essential components to achieve a successful leaf land spreading program, the interest of this group extends the collected compost into the community and would further be encompassed into sustainability issues surrounding agricultural practices, rather than just providing compost for giveaway functions. Due to the nature of the farming community, they are conservative and essentially fear change and the adoption of new ideas into their farm. With this idea in mind, efforts must be made to make participation and implementation of the program an easy and practical process. The regulations are somewhat difficult to organize and obtain certification, however aside from this issue, further educational campaigns must be undertaken to demonstrate to the farmer just how easy and how sustainable this process would be on their farm and all the benefits that would result from the use of leaf compost. This has already begun with the previous Regional survey that was undertaken in 2000, in which an educational package was sent along. A continuous educational campaign, and possible continued surveys or even site visits, would help the farmers gain a better understanding of the processes; and although they usually communicate through word of mouth from other farmers, it just takes a few successful systems to demonstrate this to the others.

Increased Actor Communication

To maintain and further promote the leaf land spreading program communications between all stakeholders must be emphasised. A consensus building process in the form of roundtable negotiations would help to bring all the involved parties together and perhaps allow for real progress in dealing with the set backs of the leaf land spreading program. Although a recommendation like this may seem unattainable it can begin on small scale initiatives. Clark Reichert, the composting coordinator for the Region, and one of our interview participants identified a problem of differing perspectives and goals pertaining to the different Municipalities. The Region of Waterloo is the one that wishes to implement the program but other smaller Municipalities are responsible for picking up the curb-side leaves and transporting them to the various farms. It was made aware to the group that the surrounding Municipalities are concerned with travel distances, and therefore, farms that require a distance to transport the leaves who are interested are not accessed by the truck drivers. A consensus decided upon agreement that is created by the Region of Waterloo and the other Municipalities could be a basis to increase communications between the groups and create standardized boundaries rather than settling with quasi- established ones. This could also lead to a vision for the future of leaf composting and waste management in the Region and the creation of 3 or 5 year vision plans. Achieving this kind of decision with other participants of transportation would be an achievable commencement to implement the leaf land spreading program.

Permit by Rule (Case Studies)

Upon undertaking the literature search for background information, it became very apparent that the Permit by Rule system had insufficient data. All examples of currently functioning Permit by Rule pertained to bio-solid management uses. To gain a complete comprehension of the system all examples should be gathered and with multi-stakeholder participation, lead to the creation of a single standardized Permit by Rule. This would formalize the process and make the system implementable for projects in Canada. Extensive Permit by Rule application exists in the United States and a draft permit in Canada could be established using these guidelines such as those existing case studies that were mentioned earlier from the UK. The creation of a collaborated Canadian Permit by Rule system developed from research of existing systems and using the input of various stakeholders will promote the system in Canada and make it available for use not only the in leaf land spreading program but other areas as well.

Further Research

Due to the limitations of the project, a complete research analysis was not completed and therefore to implement the leaf land spreading program, further research is needed to fill the gaps. Our hopes are that this project would be the starting point for an iterative process of research in this field. This would hopefully lead to a point where all of the problems and issues associated with this program are analyzed and further presented with solutions. Some areas to be further researched would be the Permit by Rule system using current case studies and possibly leading the formation of a draft Permit, farmer willingness and re- evaluation of the successfulness of the educational programs, increase knowledge of site —specific composting scientific guidelines and organization into practical categories, ways that the current Certificate of Approval system may be improved upon or changed with meaningful results, and to gain an increased understanding of Ministry proceedings through conducting successful interviews to undercover the complexities that exist within the government and what it would take for the Region to effectively and efficiently implement the leaf land spreading program or to improve upon the current system to ease the process.

Public Consultation and Involvement

The public are the primary producers of the leaves into this system. Our hopes are that they could be involved to a greater level in the decision making processes of the program, which would essentially lead to a greater sense of responsibility for what they put into the system. As well educational campaigns would lead to a higher participation rate, as many homeowners throw out their leaves the garbage which additionally augments the 15% of organic wastes that are already in the landfill in Waterloo. This could also increase the quality of material that is being picked up the Municipalities.

Public Education/ Promotion

The establishment of an educational program for the general public concerning health and safety issues would increase their comfort and familiarity of the system leading to its overall success. With a focus on sustainable soil management it may help the public realize the importance of using environmentally safe and renewable materials on their own properties and also increase knowledge of organic farming. The city of Waterloo is a very dynamic community and with an appropriate educational campaign or environmental fair, the results would further help to implement leaf land spreading. It could also lead to the formation of individual groups forming for specific interests preventing the progress of the program with a focus on activism activities or lobbying and essentially volunteers taking on problems for the Region.

PROGRAM OF EVENTS- see program of events diagram below

The first part of our project consisted of the formulation of a project research question; we needed a focus for our project so we could begin more detailed work in this project. This in itself allowed us to begin the process of defining the boundaries and scope of our project. We settled on a qualitative analysis, as this topic was not one that could be analyzed from a quantitative perspective. Most of the quantitative work that could be done in this area was already completed by a previous study of the Regional Municipality of Waterloo’s waste management division. Once we identified the research question, we shifted our focus to identifying the sources of relevant information.

In other words, we began our literature search and research into the field. This was especially difficult as it was a new topic for us; we did not have the benefit of prior knowledge that other research teams had. We completely immersed ourselves in to the relevant literature, most of it consisting of government documents and completed certificates of approval. This allowed us to gain a functional understanding of the topic; a large amount of background information had to be digested, in a relatively short period of time. Once we had done this background reading we became more knowledgeable of the specific issues that plagued the system, and gather together several alternatives that we could analyze to see if they were a more flexible option that provided the same measure of security. Once the information had been gathered, the next phase was sorting through the gathered literature and selecting what was appropriate for this project. Concurrently with this portion of our project we drafted a proposal for our research design.

Once the proposal was completed, and our literature search completed we were able to decide what information we still needed to gather, and what perspectives to analyze in further detail through the questionnaire and survey portion of our study. All of this work was consolidated into one document and submitted to the Office of Research Ethics. Once we received the necessary clearance, we began the interview and survey portion of our study. Once this process was completed we analyzed the various perspectives that had arisen from that stage of our study, and compiled them into a coherent set of recommendations. These recommendations and a further distilled set of literature on the subject were the material upon which we based our presentation of findings. All of this led to the final stage of our study - the report.





Three major nutrients — nitrogen, phosphorous and potash — are used as synthetic chemical fertilizers in industrial agriculture. According to the OECD, the application of these fertilizers "reflects the specialisation and intensification of cropping practices."28

These chemical fertilizers pose a threat to human health and the environment, particularly with respect to water quality. Nitrates from fertilizer can accumulate in groundwater and can reduce the ability of human blood to carry oxygen. Infants are particularly susceptible to nitrate poisoning — a phenomenon known as blue baby syndrome.

Canada’s OECD Ranking
Canada ranks 25th out of 28 OECD nations in terms of consumption of commercial fertilizers (both on a per capita and a total basis). Canada used 90 kilograms of commercial fertilizers per capita in 1997. Only Australia, New Zealand and Ireland use more fertilizer per capita.

In total, Canada used 2,753,000 tonnes of commercial fertilizers in 1997, with only the United States, France and Germany using larger amounts.

Canadian consumption of commercial fertilizers increased by 42% between 1980 and 1997. In contrast, the OECD as a whole experienced a 10% decrease in fertilizer use. Nineteen out of 28 OECD nations decreased their fertilizer use between 1980 and 1997.



Obtained from www.oced.org. 2001












Biological Systems




















































































Information Letter, Ministry of Environment Questionnaire, Municipality/ Consultant Questionnaire, Farmer Survey, Appreciation Letter






University of Waterloo

Waterloo, Ontario

Faculty of Environmental Studies

Research Supervisor: Susan Wismer, Professor, (skwismer@fes.uwaterloo.ca)

Researchers: Nicole Weaver, (loca_86@hotmail.com)

Ross Gardner, (rgardner@fes.uwaterloo.ca)

Melanie Nunez, (melanie_nunez@hotmail.com)

Date March 21, 2002



We are conducting a research project at the University of Waterloo pertaining to Leaf Land Spreading practices in the Region for a Department of Environment and Resource Studies 250 course under the supervision of Professor Susan Wismer, Department of Environment and Resource Studies 888-4567 ext. 5795. Our research aims to uncover the multi-stakeholder perspectives pertaining to this process. The stakeholders in involved in this program are: The Ministry of Environment, Environmental Consultants, Regional Farmers and the Regional Municipality of Waterloo. We have developed this project in collaboration with Mike Birett, Senior Project Manager, Regional Municipality of Waterloo, Waste Disposal (519) 883-5150 ext. 233. the final copy of this project will be filed confidentially at the Regional Municipality of Waterloo’s Waste management administrative building. Based upon your responses/interest, you may be contacted at some point in the future by the Regional Municipality of Waterloo to further the development of this program. All information collected from interviews/questionnaires, will be utilized only by the Regional Municipality of Waterloo, and ourselves, the student researchers. There are no known/anticipated risks involved in your participation with this study.


Our research objective is to identify the issues that are preventing the implementation of a leaf land spreading program on agricultural fields in the Region. You have been contacted because of your expertise or direct association in this area. We are requesting your voluntary input as someone who would has an interest in the outcome of this project. The questionnaire/interview that we are asking you to voluntarily participate in should take no more than 20 minutes of your time. For facilitation of discussion and minimization of total time spent in the face-to-face interviews, we will record (audio only) these face-to-face interviews. Once the interviews have been completed, the information will be transcribed and all audiotapes erased.


This project has been reviewed by, and received ethics clearance from the University of Waterloo Office of Ethics and Research. If you have any questions/concerns resulting from your participation in this study, please contact Susan Sykes at the University of Waterloo Office of Ethics and Research, 888-4567 ext. 6005. We are requesting a personal or telephone interview that will be arranged at a date and time that is convenient to you. Upon completion of this study, the results can be made available to you.









Thank you in advance for you co-operation and time.




Nicole Weaver

Ross Gardner

Melanie Nunez














I agree to participate in a study being conducted by Environment and Resource Studies students from the course Environment and Resource Studies 250, University of Waterloo under the supervision of Professor Susan Wismer. I have made this decision based on the information I have read in the Information letter and have had the opportunity to receive any additional details I wanted about the study. I understand that I may withdraw this consent at any time without penalty by telling the researcher(s). I also understand that this project has been reviewed by and received ethics clearance from the Office of Research Ethics at the University of Waterloo, and that I may contact this office if I have any concerns or questions about my involvement in the study.


Name:_____________________________ Witness Signature______________________



Signature:_________________________________ Date:___________________





























Ministry of Environment Interview/ Questionaire

Leaf Land Spreading Perspectives

University of Waterloo, Ontario, Canada

ERS 250, Faculty of Environmental Studies

Supervisor Susan Wismer- skwismer@fes.uwaterloo.ca

Group Members, Ross Gardner, Melanie Nunez, Nicole Weaver


  1. Strongly Agree
  2. Somewhat Agree
  3. Neutral
  4. Somewhat Disagree
  5. Strongly Disagree


  1. Do you think the spreading of leaves on agricultural land will help the area achieve, sustainability or the ability to provide for present generations without jeopardizing the needs of the future, in the Region of Waterloo? ______ (1-5)
  2. In your perspective, is sustainable soil management a goal that you are trying to achieve _____(1-5)

    A Certificate of Approval (C of A) is defined as "a permit issued by a Ministry under a specific provision in an Act or regulation that allows the permit holder legally to discharge a limited volume of polluting substances or carry out an activity that may have an adverse affect on the environment, according to terms and conditions set out in the permit.



  4. How effective, useful, and applicable does the Ministry feel the Certificate of Approval is for Leaf Land Spreading? ______ (1-5)

  6. How effective, useful, and applicable does the Ministry feel the Permit by Rule is for Leaf Land Spreading? ______( 1-5)

    A Permit-by-Rule is defined as "a regulatory system that "deems" regulatory approval to exist where a company operates within parameters set by regulation, rather than requiring individual Certificates of Approval or other permits for each case"




  8. Does the Ministry feel farmers should get incentives for using organic leaf compost on their fields? _______(1-5)
  9. Do you think the Ministry ‘s policies/regulations could be improved to tailor to farmers and the Municipality of Waterloo? ______(1-5)
  10. Are you in support of Waterloo launching a pilot project to adopt a Permit by Rule system in regards to leaf land spreading?_______(1-5)


Open Ended/Opinion

Would the Ministry be interested in reducing the number of C of A approvals needed, if quality of projects could be maintained?


What is the feasibility of replacing the C of A system with a permit- by- rule for the process of leaf land spreading?


Have any other municipalities approached the Ministry of the Environment, considering a Permit-by- Rule method towards developing sustainable waste systems?



Who in the Ministry has final approval powers, and does anyone outside the ministry have veto powers over such decisions?



Would you consider a pilot project of a permit- by- rule system for leaf land-spreading in the Regional Municipality of Waterloo? If yes or no, explain the reasons




To the best of your knowledge, have any other projects under municipal direction had proposals for a permit by rule system been rejected?

If so what were the grounds for dismissal?




What is the ministry’s standpoint with regards to leaf land spreading as a process to introduce sustainability into the waste disposal system?

What are the 4 main issues preventing the implementation of the Permit by Rule system from the perspective of the Ministry?

Additional comments?


Thank you for your time and consideration. The results of all the surveys will be directed available to you upon conclusion of the research.






Consultant/ Municipality Questionaire

Leaf Land Spreading Perspectives

University of Waterloo, Ontario, Canada

ERS 250, Faculty of Environmental Studies

Supervisor Susan Wismer- skwismer@fes.uwaterloo.ca

Group Members, Ross Gardner, Melanie Nunez, Nicole Weaver



Have you ever had any experience with a Permit by Rule system?

Yes No

A Permit-by-Rule is defined as "a regulatory system that "deems" regulatory approval to exist where a company operates within parameters set by regulation, rather than requiring individual Certificates of Approval or other permits for each case"


A Certificate of Approval (C of A) is defined as "a permit issued by a Ministry under a specific provision in an Act or regulation that allows the permit holder legally to discharge a limited volume of polluting substances or carry out an activity that may have an adverse affect on the environment, according to terms and conditions set out in the permit.


Could you list four criterion which you consider to be important, which can compare the efficiency of both the C of A and the Permit by Rule system.



How would you rate each objective with 1 being least important and 5 being most important?




What considerations, if any, are given to ways in which the regulatory systems can be improved?

-Permit by Rule


-C of A


Have any of these considerations been implemented? If so, when?




Were there any recognizable changes to the efficiency of the Leaf Land-spreading system after these changes were made?



Comparing the Permit by Rule system to that of the C of A, do you think that there is a trade-off of monitoring quality to time? Please provide three reasons.



How would you rate these three reasons with 1 being least important and 3 being most important?



Are there any immediate advantages/disadvantages of a Permit by Rule system?








Are there any immediate advantages/disadvantages of a C of A system?








Considering the disadvantages, are there any efforts being made to improve these states?



Are there any examples of Canadian municipalities which have made the

Transition from a C of A system to a Permit by Rule one?



How would you describe the level of regulation for the C of A system?


Should this system be applicable to both private and public sector



What steps do you think could be taken in order to hasten the time taken for a C of A to be processed?


How feasible do you think these steps are? Please provide your answer on a scale of 1 to 5, with 1 being not at all feasible and 5 being very feasible.




Are you aware of any current administrative problems with the C of A process?



Are there any other options that the Ministry of Environment has not considered as alternatives to the current C of A process?



One of the main concerns mentioned with the C of A, is the length of time required to get approval. Is this an administrative concern or just simply the natural time span of

the C of A?



Regardless of your previous response, do you think the length of time taken to process a C of A could be shortened?

Yes No

If Yes, how do you propose that this can be done?


Are any considerations being given to a Class C of a C of A system, i.e. submitting one document for all leaf land spreading done by Regional Municipality of Waterloo during a defined time span rather than one for each of the properties on which it is




What are the legal requirements involved in this process, i.e. what is required by the law, and what is admissible?



What are the issues preventing the implementation of a leaf land spreading program from the perspective of (MOE, Consultant)



















Returning Farmer In/ Questionnaire

Leaf Land Spreading Perspectives

University of Waterloo, Ontario, Canada

ERS 250, Faculty of Environmental Studies

Supervisor Susan Wismer- skwismer@fes.uwaterloo.ca

Group Members, Ross Gardner, Melanie Nunez, Nicole Weaver


1. What are your existing soil management practices?

à Please circle 1) No-Till

2) Conventional Till

3) "zone" or "strip" tillage

2. Are you considering switching your soil management to no-till practices in the near future? Y/N?


  1. Have you considered the leaf land spreading program for your farm?
  2. YES: _____

    NO: ______ What are the top three reasons preventing you from considering the program








  3. Considering all of the types of policies and regulations, would sustainability be important to your farming practices if it balanced the costs?
  4. 1-strongly agree, 2- somewhat agree, 3 neutral, 4- somewhat disagree, 5- strongly disagree

    5. Do you think that the government should give farmers incentives for using organic leaf compost for fertilizer?

    1-strongly agree, 2- somewhat agree, 3 neutral, 4- somewhat disagree, 5- strongly disagree

  5. Would you be interested in participating in a pilot project for the Region of Waterloo Waste Management Facility incorporating a Permit by Rule system for leaf land spreading or like further information about the program? Y/N (if yes, get contact information).





University of Waterloo

Waterloo, Ontario

Faculty of Environmental Studies

Research Supervisor: Susan Wismer, Professor, (skwismer@fes.uwaterloo.ca)

Researchers: Nicole Weaver, (loca_86@hotmail.com)

Ross Gardner, (rgardner@fes.uwaterloo.ca)

Melanie Nunez, (melanie_nunez@hotmail.com)


Date March 21, 2002


Dear ………………

On behalf of my fellow colleagues, I would like to thank you for your participation in the ERS 250 interview exercise for our project on Leaf Land-Spreading. This project has been reviewed by, and received ethics clearance from the University of Waterloo Office of Ethics and Research. If you have any questions/concerns resulting from your participation in this study, please contact Susan Sykes at the University of Waterloo Office of Ethics and Research, 888-4567 ext. 6005.

The information, which you have provided, is very important and helpful. Further information about outcomes of the project is available from Mike Birett, Project Manager, Regional Municipality of Waterloo (519-883-5150 ext. 223)


Again, we thank you for your time and patience.



Nicole Weaver

Ross Gardner

Melanie Nunez






Anonymous, The Physical and Economic Dimensions of Municipal Solid Waste Management in Ontario, Ontario Ministry of Environment, 1991.

Anonymous, The State of the Environment Report 1992, Ontario Ministry of Environment and Energy Website, http://www.ene.gov.on.ca/envision/status/soe.pdf, viewed on 27-2-2002

Birett, M. Municipal Perspectives in Waste Management, Presentation in E.R.S. 218 lecture, Overheads on E.R.S. 218 Website, http://manu.uwaterloo.ca/crs/ers218.f2001/, viewed on 27-2-2002.

Birett, Reichert, Hesch, and Ainsworth. The Regional Municipality of Waterloo Waste Diversion Association. Leaf Landspreading Initiative. Report November 2000.

Birett, M. Senior Project Coordinator, Regional Municipality of Waterloo Waste Management Facility. Personal Communication. 21 March, 2002

Boothroyd, P. "On Using Environmental Assessment to Promote Fair Sustainable Development" from Sustainable Development and Environmental Assessment: Perspectives on Planning for a Common Future, 1991, P. Jacobs and B. Sadler.eds. Environmental Assessment Agency 1991.

Cielap. Environmental Agenda for Ontario. Section 2.4 Environmental Approvals Online Publication. 2002, http://www.cielap.org

Colby, M.E. "Environmental Management in Development: The Evolution of Paradigms" from Ecological Economics, Vol. 3, No. 3 Pp. 193-213. 1991

Eichom, Evert and Raven, Biology of Plants. 6th Edition 1999, W.H. Freeman, New York

Fleming, R. University of Guelph. Environmental Engineering. 2000. http//:www.ridgetownc.on.ca/rfleming/default.htm


Gerry Gillespie, Biocycle, Feb. 2002. Vol. 43, no.2, P 73.

Palys, Ted. Research Decisions: Qualitative and Quantitative Perspectives. Second Edition. 1997. Toronto: Canada

Riechert, Clark. Composting Co-coordinator, The Regional Municipality of Waterloo. Personal communication.

Maine Department of Environmental Protection. Permit by Rule NRPA. 1999


Virginia Department for Environmental Quality. Permit by Rule for Yard Waste Composting Facilities. 2001. http//:www.deq.state.va.us

Verbaas, Alice. Ministry of the Environment. Personal Communication. 22 March, 2002.

Whitelaw, Graham. Professor. University of Waterloo Faculty of Environmental Studies.

Personal Communication. 21 March, 2002.