December 11, 2017 …

December 11, 2017

Submitted Electronically to lubna.i.hussain@ontario.ca

Lubna I. Hussain
Manager
Ministry of the Environment and Climate Change
Environmental Sciences and Standards Division
Standards Development Branch
40 St. Clair Avenue West
Floor 7
Toronto, Ontario
M4V 1M2

Subject: EBR Registry Number 013-0903, Regulatory amendments related to air emissions of sulphur dioxide and other items

Dear Ms. Hussain:

Domtar appreciates the opportunity to submit comments to the Government of Ontario on the proposed regulatory amendments to air emissions of sulphur dioxide and other items. Domtar is very willing to engage in dialog with the Province of Ontario to discuss aspects of the proposed amendments to support industrial competitiveness and sustain economic growth while protecting human health and the environment.

Domtar is a leading provider of a wide variety of wood fiber-based products, including communication, specialty and packaging papers, market pulp and absorbent hygiene products. The foundation of our business is a network of fiber converting assets that produce papergrade, fluff and specialty pulps. While most of our pulp production is consumed internally to manufacture paper and consumer products, we are also a large volume pulp exporter. Domtar is the largest integrated marketer of uncoated freesheet paper in North America. With approximately 10,000 employees serving customers in more than 50 countries around the world, Domtar is driven by a commitment to turn sustainable wood fiber into useful products that people rely on every day. In Ontario, Domtar operates mills in Dryden (a pulp mill) and Espanola (a pulp and paper mill). Together these two operations directly employ over 925 people in the North and indirectly employ an estimated 3,000 additional workers people through harvesting contractors, vendors, suppliers, contracted services and more. Domtar has similar pulp and paper making operations in other Canadian provinces and the United States.

Domtar supports air standards that are appropriate to protect public health - including sensitive populations - and the environment. Domtar, like others in the industrial sector, have taken actions to reduce emissions of sulphur dioxide, as part of modernizing and improving our processes. We have fuel switched to lower sulfur containing natural gas and increased our reliance on renewable biomass fuels to run our facilities with more green energy. While we understand the science reviewed for the proposed standards, we are concerned with how MOECC set the proposed standards. It appears MOECC was more focused on the current standards and did not take into consideration actual performance factors when setting the proposed standards.

MOECC is seeking input from stakeholders on whether to apply the proposed standards to Southern Ontario and have the current standards apply to Northern Ontario. Domtar would support this regional approach providing the definition for identifying the northern Ontario region and the southern Ontario region is consistent with the definitions on the Northern Ontario Heritage Fund Corporation (NOHFC) website: https://nohfc.ca/en/about-us/northern-ontarion-districts . NOHFC defines northern Ontario as all areas north of, and including, the districts of Parry Sound and Nipissing. The website noted above contains maps indicating where the division between northern and southern Ontario occurs. Domtar supports this definition for identifying the northern and southern regions of Ontario for purposes of applying and implementing the proposed standard.

MOECC is seeking input on this regional approach for applying the proposed standard, but our review of the available consultation documents included on the EBR website for the proposal, did not identify any further discussion on MOECC’s reasoning or justification for taking a regional approach for implementing the proposed standards. From Domtar’s perspective, we feel the regional approach makes sense given the types of industries located in the northern region compared to the southern region, the difference in population density between northern and southern Ontario, the ability for all industry in the northern region to a have access to lower sulphur containing fuels such as natural gas and the trans-boundary pollution and long-range transport of air pollutant issues that could impact the southern Ontario region from countries located south of Ontario. We would appreciate receiving additional clarification from MOECC on their reasoning and justification for considering this regional approach.

Once MOECC finalizes the regulatory amendments for the sulphur dioxide standards, Domtar would like the ability to apply for an alternate standard under the existing Pulp & Paper Technical Standard should we find we are unable to comply with the new sulphur dioxide standards. The Pulp & Paper Technical Standard includes sulphur dioxide in Appendix A. While no one has yet to register for sulphur dioxide under the existing technical standard, we are willing to work with MOECC to put in place systems that are economically and technically feasible for our mills and our operating processes to limit emissions of sulphur dioxide. If we determine an alternate sulphur dioxide standard is needed, we would like the ability to look for a technology-based compliance approach under the existing pulp and paper technical standard.

MOECC is also proposing amendments to clarify requirements for assessing transient operating conditions such as start-ups, shut downs and some non-routine operations. The proposed regulatory amendments identify sulphur dioxide as a key concern and are proposing a 3-prong approach; with one specifically addressing petroleum facilities and the other 2 requirements applicable to all facilities. Since these requirements are intended to impact all facilities and could expand to include other pollutants, we feel additional detail and clarity for the proposed transient operating conditions is needed before we can provide detailed comments. We encourage MOECC to engage in authentic consultation with impacted stakeholders prior to finalizing amendments addressing transient operating conditions that are intended to affect a large number of facilities. There are some fairly fundamental issues that we feel need to be discussed before finalizing requirements that place additional administrative burden on facilities with no environmental benefit.

Thank you for the opportunity to provide comments on the proposed regulatory amendments related to air emissions of sulphur dioxide and other items. We look forward to further engagement with MOECC on this matter.

If you have any questions about these comments or would like to further discuss, please contact me at (715) 886-7785 or via email at annabeth.reitter@domtar.com.

Sincerely,

Annabeth Reitter
Corporate Manager, Environmental Regulations

[Original Comment ID: 211511]