Redpath Sugar Ltd. Re: MECP…

**SENT ON BEHALF OF REDPATH SUGAR LTD**

Redpath Sugar Ltd.

Re: MECP Proposed Industrial Emission Performance Standards

During the emission performance standards consultation with the food sector it was noted that under the proposed system Redpath Sugar Ltd. is being categorized under the Facility-Specific Standard. We have the following feedback for your consideration:
• We agree with our placement under the Facility-Specific Standards under Ontario’s proposed OBS.
• Under the facility based system, the company would like have our product/process parameter be recognized as “Raw Sugar” melted or refined or used as a raw ingredient.
• We would like the product/process parameter to be in the unit of “Metric Tonnes”.
• As such, the intensity unit would be: Tonnes CO2e per tonne of raw sugar refined or melted or used as a raw material.
• The rational for using Raw Sugar as the product/process parameter is due to the following:
o This would be in keeping with the prior Ontario Cap and Trade product/process parameter and product unit.
o Raw sugar is the most suitable parameter to use as it is most directly correlated to the energy consumption and natural gas use in the refining process. The quality of raw sugar purchased and received can have a significant impact on the energy required to process this raw material into the various finished products.
o In addition, the raw sugar melted or refined is a very accurate measurement that is easily and readily generated.
o Using Raw Sugar also allows for the most simplistic, representative single unit of measure, while the use and sum of other refined product steams may not include byproducts that are utilized in other beneficial reuse pathways.