The Ontario Pulp and Paper…

The Ontario Pulp and Paper Coalition (the Coalition) thanks you for the opportunity to comment on the Proposal ERO number: 013-4551 – Making polluters accountable: Industrial Emission Performance Standards (the Proposal).

The members of the Coalition include the following pulp and paper companies: Atlantic Packaging, AV Terrace Bay, Cascades, Domtar, Rayonier Advanced Materials, Resolute Forest Products, and the Ontario Forest Industries Association. The Coalition operates mills in all regions of Ontario. These mills are part of a broader highly integrated forest products sector that includes:

• Sustainable forestry operations
• Sawmills and wood product mills
• Paper recycling
• Bio-energy, biochemical and bio-fuel sectors
• Green energy for the electricity grid

Currently, the Ontario forest products sector represents $15.5 billion of economic activity and provides over 170,000 direct and indirect jobs in every region of the province. The sector is heavily trade exposed and subject to international commodity pricing which they have no control over for the products they manufacture.

The Coalition feels that in order for our sector to take full advantage of the opportunities in GHG reductions and low carbon contributions that are available, it is critical that the government of Ontario develops a regulatory policy and framework that is effective and aligned with the business realities of our sector and the jurisdictions in which we must compete with and potentially trade with in the future. It should also recognize and reward companies that have made the necessary investments to improve energy efficiency reducing their carbon footprint and providing jobs in the province.

The Coalition has developed the following Climate Change Policy Principles that we believe must be met in order to have an effective and successful greenhouse gas emissions reduction policy:
1. Recognition of Early Actions in GHG Reductions
2. Recognition of Biomass’s Contribution to Lowering Emissions
3. Recognition of Co-generation's Contribution to Energy Efficiency and Greening the Grid
4. Recognition that Each Facility is Unique
5. Mitigation of Economic and Compliance Impacts

Details for each of these principles are included in the attached submission.

The Coalition looks forward to continuing to work with the Ontario government and the Ministry of the Environment, Conservation and Parks on the development of a Climate Change Policy that meets the above principles.