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RCO Submission on Reducing Coal Use in Industry

Submitted June 16, 2014

Resubmitted Feb. 11, 2015

EBR Registry Number 012-1559: Reducing Coal Use in Energy-Intensive Industries

In April 2014, the Ontario Ministry of the Environment and Climate Change (MOECC) requested feedback for a proposal to allow energy intensive industries and trade-exposed manufacturing industries (such as cement, lime, iron, and steel sectors) to take advantage of opportunities to reduce the use of coal and petroleum coke by substituting them with alternative, low carbon fuels such as biomass (corn stover); and non-recyclable, non-hazardous residual waste.  


This notice was initially posted for a 45-day comment period in April 2014 to consult on a proposed framework for reducing coal use in energy-intensive industries. The notice was reposted December 2014 for an additonal 60-day comment period to consult on  proposed regulations that were developed based on the comments received through the initial consultation.


RCO understands and supports the environmental benefits of reducing coal as a fuel, we have concerns surrounding the Government of Ontario facilitating the use of non-recyclable materials as fuel substitutes. 


In summary:


Implementation of one-off regulatory initiatives in the absence of an integrated waste reduction strategy risks undermining environmental outcomes that might otherwise be achieved through an integrated waste management strategy.


RCO considers the proposed regulation a significant shift in policy because it circumvents many of the regulatory checks and balances that are afforded by the requirement to otherwise secure an Environmental Compliance Approval under section 27 of the Environmental Protection Act. It follows the permissions flowing from the proposed regulations must be narrowly and clearly defined and enforceable.


The proposed regulation’s sourcing of residue waste can also be strengthened:


1. Redraft schedule 1 as an inclusion list rather than exclusion list. An inclusion list, identified in short-, mid-, and long-term list of materials provides better transparency and controls necessary to ensure valuable recyclables are being utilized.


2. Limit the sourcing of residue materials to secondary, rather than primary, processers of IC&I, Blue Box, and WEEE materials. This ensures:

  • dedicated processes for fiber, plastics, and electronics are not placed in the position of competing with energy alternatives
  • materials are directed to the highest possible recovery option; and,
  • residual material sources are readily identified and tracked.

3. Require registration for residual waste generators and the characterization of residual streams.


4. Require facilities support the placement of an on-site MOECC inspector to monitor incoming waste and operations. 


Facilities should also be required to report as part of their application submissions to the MOECC as part of their demonstration project assessment and annually for approved facilities on such matters as:

  • source, characterization, and quantity of alternative and conventional fuel used at the facility;
  • description of the alternative low carbon fuel process, including changes to the operation;
  • description of point-of-impingement air emission impacts; and, calculation of GHG emissions.


Read our full response from February 2015 (PDF, 9 pgs, 375 KB)


Read our full response from June 2014 (PDF, 6 pgs, 436 KB)









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