Re ERO #019-8010 CRH Canada…

Re ERO #019-8010 CRH Canada Group Inc.

I am not sure why CRH’s formal Proposal is not available online, on the Environmental Registry website. I am therefore commenting on CRH’s Plain Language Summary handout provided at their open house on December 6, 2023.

The final sentence of their Proposed Action Plan reads: “…it is expected that the facility would achieve compliance with the 1-hr average Schedule 3 (general) for SO2 and NOx by the end of the 10 year site-specific standard process”. Their Summary of Request is:
- SO2 1-hr average 1256 ug/m3
- NOx 1-hr average 1653 ug/m3
There is no time frame stated for their Request, but given their Action Plan statement, it seems they’re requesting those limits for the next 10 years

I object to that request for the following reasons:

1. Their Request far exceeds even the old limits of 690 ug/m3 for SO2 and 400 for NOx.
2. The new 100 ug/m3 standard for SO2 was announced in 2018, so CRH has already had 5 years to prepare for the tighter requirement, and now they want 10 more years to meet it.
3. CRH states that the Provincial measurement criterion (CALPUFF) for shoreline facilities is unreasonable, so they proceeded to develop their own criteria. They also state that the 100 ug/m3 SO2 standard is “one of the strictest in Canada and the world”. It is highly inappropriate for them to dismiss the Province’s environmental rules and lobby for their own.
4. Even though they show dotted line reductions in SO2 and NOx over 10 years in their own graph, they’re asking that the maximum limits (1256 and 1653 ug/m3) be fixed for 10 years, with no step-downs.
5. Their Action Plan summary above is equivocal: “it is expected the facility would achieve compliance…”. There need to be hard limits to be met.
6. They state their limestone quarry in Colborne, Ontario produces “high pyrite sulphur”. They also state they evaluated 60 different options for reducing emissions, including using different materials. Did they consider obtaining low sulphur limestone from other sources?
7. They address only SO2 and NOx. I presume their cement plant meets all other air emission regulations, including CO2 even though about 1/3rd of the fuel used in the plant is coal.
8. They state they will spend $100 million to achieve their 10-year Action Plan. It will undoubtedly cost them more to meet Provincial regulations more quickly. Is this not just a trade-off of the health interests of residents versus the economic return on equity of CRH’s shareholders? Has CRH suggested that it will be uneconomic to spend more than $100 million and they’ll shut the plant if required to do so?

I request that CRH be required to meet the Provincial test criteria for SO2 and NOx much more quickly than 10 years, and subject to firm stepdown limits.