The Ontario government has now filed Ontario Regulation 79/15 – Alternative Low Carbon Fuels and O. Reg. 80/15 (Amending O. Reg. 681/94 (Classification of Proposals for Instruments)). The regulations create a new regulatory approvals pathway to help energy-intensive industries (i.e., cement, lime, iron and steel – our local example is Holcim) reduce their emissions of greenhouse gases by facilitating the switch from coal and coke to alternative low-carbon fuels. The regulations took effect on May 1, 2015.
Cement plants use coal to fire the rotating kilns used in the production of cement. Based on information received from Holcim, coal is used for approximately 55% of the thermal energy required for cement production, and the use of cement (from mining through final installation) has an influence on 35% of global emissions of CO₂. Canada is lagging in adopting the use of alternate fuels for such energy-intensive industries. As noted in the letter that JCRA sent to the MOE in June, 2014 (appended below), the cement industry in many countries (e.g., U.S., U.K., Switzerland, Austria, France, Germany) are already permitted to use Substitute Fuels (SFs) to reduce greenhouse gas emissions, and in some cases have been doing so for up to 20 years. So this is not a new concept globally, just for Canada.
JCRA also noted that the critical issue for us is that the already stressed Clarkson Airshed not be subject to additional stress and that any use of SFs must result in reduced emissions not only of CO₂ but also of other potential contaminants (e.g., particulate matter, other organic and metallic species such as mercury). These benefits need to be measurable and monitored continuously during operation. It is important to note that the use of SFs is likely to require the need for new, modern kilns designed for the purpose, not simply repurposing of existing facilities. Hence the need for extensive testing under controlled conditions, as set out in the new Regulations.
Alternate low-carbon fuels could include fuels composed of, or derived from, materials such as:
- Non-recyclable and non-hazardous residual wastes
- Non-recyclable industrial, commercial or institutional residues/waste such as unsaleable finished goods
- Non-recyclable wastes generated by construction and demolition activities
- Biomass, such as agricultural by-products or residues
The Regulations would only allow alternative low-carbon fuels to be used at a facility to replace coal or petroleum coke for the purposes of manufacturing a physical product as opposed to electricity generation or waste disposal, and would specifically exclude recyclable material such as:
- Blue box recyclables
- Hazardous waste
- Soil, compost and organic waste
- Residues from waste incineration
- And certain liquid industrial wastes
Holcim expects that by –product fuels (e.g., petcoke, used oils) could reduce coal consumption by up to 50%, and alternative low-carbon fuels could eventually eliminate the use of coal in the production of cement.
Under the new Regulations, facilities wanting to include the use of alternative low-carbon fuels in their operations need to meet Ontario’s standards for air emissions and wastewater discharges; however, they would no longer be required to obtain approval to operate a test facility at their plant (classified as a ‘waste disposal site’) and would have more flexibility to assess different fuels at their operations before they apply for approval to use them on a long-term basis. This would allow them to examine the best option for reducing their emissions, without having to go through the permitting process each time. The public, municipalities and other stakeholders will continue to be consulted on facility proposals for long-term use of alternative fuels, and Holcim has committed to proper education, consultation and technical validation before implementing any permanent changes at the Mississauga plant.
JCRA will continue to monitor Holcim’s plans and update you. Should you note any changes in particulate matter or air quality please send us an email at: firstname.lastname@example.org
For further detail, please visit the Environmental Registry, which includes a link to the regulations: http://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTIyMDkz&statusId=MTg3NzM5&language=en