Subject: Opposition to ERO…

Subject: Opposition to ERO 025-0009 – Reject the Use of Lime Kilns for Burning Waste

I am writing to voice my strong opposition to the proposal outlined in Environmental Registry of Ontario notice 025-0009, and in particular, Section 6, which would allow the burning of unrecyclable materials in lime kilns.
This proposal poses unacceptable risks to public health, the environment, and the long-term sustainability of Ontario’s waste management system. It fails not only in its design but in its principles — promoting a polluting, short-sighted solution to a growing systemic problem.

1. Toxic Emissions and Public Health Hazards
Allowing lime kilns to burn garbage introduces significant health risks to nearby communities. These facilities are not designed to handle complex and hazardous waste streams, and without meaningful requirements for filtration, emissions control, or real-time monitoring, the potential for releasing carcinogens and other harmful pollutants into the air is high. Dioxins, furans, heavy metals, and fine particulates can have long-term impacts on respiratory health, neurological development, and cancer rates — particularly among vulnerable populations.

2. Risks to Water, Land, and Agriculture
The proposal also disregards the environmental consequences of burning waste. Contaminated ash and by-products threaten local water tables and agricultural soil, introducing toxins that can persist for years. This places Ontario’s farms, food systems, and rural communities at serious risk, compounding environmental damage and eroding our ability to steward land responsibly for future generations.

3. Encouraging Pollution, Not Prevention
Fundamentally, this plan does not encourage producers to reduce the volume of unrecyclable materials they put into the market. There are no measures to phase out non-recyclable packaging, reform manufacturing standards, or shift industries toward reusable or biodegradable materials. Instead, the proposal provides producers with an easy off-ramp for poor design decisions, allowing harmful materials to be incinerated rather than eliminated at the source.
Similarly, there is no strategy in place to engage or support consumers in changing consumption behaviors. A true circular economy must start with reducing the creation of waste, not finding new ways to dispose of it through harmful industrial processes.

4. No Meaningful Oversight or Regulation
This policy lacks enforceable standards for emissions, technological upgrades, or community protection. It offers no transparency, no guarantees of independent monitoring, and no way for affected residents to hold operators or the government accountable. It is an open invitation for industry to cut corners — with the public bearing the cost.

In Conclusion
This is not a circular economy strategy. It is a pollution plan disguised as progress. Burning unrecyclable waste in lime kilns — or anywhere — cannot be the foundation of responsible waste policy. Ontario needs to focus on upstream solutions: reducing waste creation, improving product design, investing in truly sustainable materials, and ensuring environmental justice for all communities.

I urge the Ministry to withdraw Section 6 of this proposal and pursue policies that prevent waste before it starts, rather than deepening our dependence on destructive end-of-pipe practices.
Sincerely,
R S