The Ontario Environment…

ERO number


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Commenting on behalf of

Ontario Environment Industry Association

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Comment approved More about comment statuses


The Ontario Environment Industry Association (ONEIA) appreciates the opportunity to provide input to the Ministry of the Environment, Conservation and Parks (MECP) proposal to update the environmental assessment requirements for advanced recycling facilities. Members of ONEIA are committed to engaging with governments as they develop policies and regulations that are consistent with our principles of sound science, sound environment, and a sound economy.

ONEIA has reviewed the published materials, attended the webinar, and participated in a meeting with MECP staff to review the proposal. We understand and fully support modernizing regulations and reducing red tape to support business investment in Ontario. However, we are extremely concerned with the reach that this proposal encompasses, specifically the contemplated inclusion of anaerobic digestion technologies (AD) into a thermal treatment regulation.

While we feel that the proposal represents advanced recycling of wastes such as plastics and chemicals utilizing new thermal treatment technologies, we do not support the application of this proposal to include AD technologies, which are, at their core, biological treatment processes. A regulatory framework for AD already exists, and we strongly believe a thermal treatment classification will unintentionally diminish the desire of AD developers to invest in Ontario.

We recommend that this proposed regulation explicitly exclude AD. At the same time, we recommend the development of a clear delineation for organics recovered from residential, commercial, institutional, industrial, and agricultural sources to reflect the unique treatment technologies and applications available for different materials. Linking AD, regardless of whether it is a mesophilic or thermophilic process or a technology like plug flow, continuously stirred, and others under the legacy term “Energy-From-Waste (EFW) / Thermal Treatment”, will impede the opportunity for Ontarians to accrue AD’s unique benefits and value in the development of circular economy solutions.

We welcome the opportunity to discuss our position and recommendations further. Please contact our office at or at (416) 531-7884 should you have any questions.

Supporting documents