The ministry received 20 public comments on the proposal, 17 comments received during the 45-day ERO commenting period and 3 comments received after the 45-day commenting period ended. All comments received were reviewed and considered by the ministry. The concerns expressed and ministry responses are summarized below:
Concern #1: Public consultations conducted on the proposal and information provided to the public on the proposal.
Response: The proposal was posted on the Environmental Registry for public commenting in accordance with the requirements. Public consultation in accordance with O. Reg. 79/15 - Alternative Low-Carbon Fuels was conducted by the proponent before the submission of the proposal to the ministry. Project information was made available by the proponent on their website in accordance with O. Reg. 79/15 public consultation requirements. Information on the proposal was also made available to the public when requests were made to the ministry.
Concern #2: Commercial aspects of Alternative Low Carbon Fuel (ALCF) proposed in the proposal e.g. sources of ALCF and agreements between parties.
Response: This concern is not included within the jurisdiction of this approval.
Concern #3: Impacts of the use of ALCF at the facility on Ontario’s efforts on waste reduction, reuse and recycling.
Response: The proposal was submitted following the requirements of O. Reg. 79/15 and this concern was already considered when O. Reg. 79/15 was developed. The regulation prohibits the use of reusable and recyclable materials as alternative low carbon fuels.
Concern #4: Methodology used in the proposal to estimate greenhouse gas emissions, reduction potential and monitoring.
Response: The proposal was submitted following the requirements of O. Reg. 79/15. The regulation includes the methodology of carbon dioxide emission intensity reduction calculation. The proponent has demonstrated meeting the requirements set out in O. Reg. 79/15 and the approval includes terms and conditions to require continual assessment of carbon dioxide emission intensities for ongoing verification of compliance with O. Reg. 79/15 requirements.
Concern #5: Impacts of use of ALCF at the facility on air quality assessed in the proposal and the terms and conditions that would be required in the Approval for performance monitoring and reporting.
Response: The proposal was reviewed by the ministry to confirm the demonstration of compliance with all applicable ministry requirements including but not limited to O. Reg. 419/05: Air Pollution- Local Air Quality, performance requirements and NPC-300 noise guideline.
The approval includes terms and conditions, including but not limited to the following:
- source testing and continuous monitoring for the verification of air emissions and process conditions
- sampling and analysis of the ALCF material used
- implementing operational procedures for ALCF use, storage and inspection of facilities
- documentation and record-keeping
- reporting to the ministry and the public including annual compliance reporting
- complaints response and reporting
Concern #6: Ministry air standards and discharge requirements applicable to the facility and the difference between Ontario requirements and federal requirements such as Canadian Ambient Air Quality Standards (CAAQS)
Response: The proposal was reviewed by the ministry to confirm demonstration of compliance with current regulatory requirements of Ontario applicable to the facility, including but not limited to the air standards in O. Reg. 419/05. It is the responsibility of the applicant to demonstrate continual compliance with the requirements in O. Reg. 419/05, including but not limited to that for sulphur dioxide that would be phased in on July 1, 2023. Compliance with federal requirements is not within the jurisdiction of this approval.
Concern #7: Emission monitoring and ambient air quality monitoring requirements of the facility, as compared with monitoring requirements for the Durham York Energy Center west of the facility.
Response: The proponent has demonstrated that the cement manufacturing facility, when properly operated and maintained, would be in compliance with the ministry’s applicable air and noise requirements, namely O. Reg. 419/05 and NPC-300 noise guideline.
The approval includes terms and conditions that are considered required for the facility, including but not limited to source testing, ALCF analysis, continuous emission monitors for the verification of air emissions and process conditions and compliance reporting requirements.
Concern #8: Combined impacts of air emissions from use of ALCF at the facility and expansion of the Durham York Energy Center.
Response: The proposal included a cumulative effects assessment study of community impacts due to the combined emissions from Durham York Energy Center and the facility, to demonstrate insignificant change in local air quality in the community as a result of the use of ALCF material proposed.
Concern #9: Compliance with other regulations and requirements such as building permits under the Ontario Building Code, potential impacts on surface water from ALCF storage areas, and soil monitoring.
Response: Municipal requirements applicable to the proposal and surface runoff impacts are not within the jurisdiction of this approval.
Comments received
Through the registry
12By email
5By mail
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