1. This change may have a…

1. This change may have a significant impact on the market and significant potential environmental impacts. Public consultation has been limited. Ontario should publish the proposed draft regulation for consultation.

2. To “make the province a North American leader in the biogas sector” and enable “ways to boost biogas sector revenues by up to 50 per cent in five years” the province should facilitate and support an informed, integrated approach to managing organics to maximize resource recovery, quantifying the current and potential capacity for anaerobic digestion (including co-digestion at existing wastewater facilities). Only such an approach would actually boost biogas without disrupting the market, and allow appropriate considerations of solutions that will maximize benefits and revenues for municipalities and for the province.

3. You are proposing a two tier system for approvals where non-farm digesters need to go through a more rigorous process for approvals and testing of materials.

4. In the meantime, we recommend that the province:
a. Maintain restrictions against on-farm digesters accepting source-separated organics or any feedstocks derived from SSO
b. Commit to implementing the previously proposed ban on the landfilling of organics over an appropriate period; and
c. Implement a minimum renewable content in natural gas.