EBR RESPONSE TO THE Draft…

EBR RESPONSE TO THE Draft Forest Biomass Action Plan

Walker Industries, based in Thorold, ON is over a century old and is still a privately held family business. It is a value-driven business employing over 1200 people and the key value for the company is “Building a Sustainable Future – Together” (www.walkerind.com). That means all Walker holdings and investments are scrutinized for Social, Environmental and Economic Sustainability benefits to employees, clients and communities.
The Walker Environmental Group is a major operating division of Walker Industries Holdings Inc. The Walker Environmental Group has two business units that would be considered stakeholders in Ontario’s Draft Forest Biomass Action Plan.
• Walker subsidiaries Gro-Bark (Ontario) Ltd. and All Treat Farms Inc. produce soil and mulch products for the Ontario market at more than 15 sites across southern, eastern and northeast ON. They employ over 350 Ontarians in a business that uses forestry biomass and municipal compost as the primary raw materials.
• The Technical Services unit of Walker Environmental is the major Canadian producer of Renewable Natural Gas (RNG) from landfills across the country, and thus a current player in the bio-economy.
Walker is a proud member of the Ontario Forestry Industry Association (OFIA) and supports the sustainable forestry industry of province. One of the principal strategic 20 year goals of Walker Industries as a company is to be a “North American Scale Leader in Recovering Resources”. As such, Walker’s is pleased to have the opportunity provide comments on the Draft Forest Biomass Action Plan (“FBAP”).

1. THE FBAP IS OFFERING ONLY ‘POTENTIAL’ LONG TERM SOLUTIONS TO A PRESENT AND ‘ACTUAL’ ISSUE – ie. THE ONGOING NON-RENEWAL OF POWER PURCHASE AGREEMENTS (PPAs) FROM BIOMASS
- Biomass PPAs in the Kirkland Lake – Cochrane – Hearst region have been cancelled or are pending cancellation and the fruition of new bioenergy and bio-product businesses is still years away, if they happen at all. In the meantime, wood processing operations in that region have lost their major regional outlets for wood processing residues and low value forestry fiber. This policy direction has failed these communities in social, economic and environmental terms.
- Biomass PPAs in Northwestern Ontario are under threat of non-renewal which poses a clear and present danger to the forestry sector in that part of the province. Presently, there are no alternative markets to utilize the surplus forestry biomass that would result from the disappearance of biomass energy facilities in this region.
- Why is there no transition period, for a reasonable duration, to allow for the ongoing flow of biomass materials via existing PPAs, until such a time that new bio-economy or other markets?

2. THE FBAP IS ARTIFICIALLY NARROW IN SCOPE AND IGNORES KEY EXISTING MARKETS FOR ONTARIO’S FOREST BIOMASS – ESPECIALLY THE LANDSCAPING INDUSTRY
- The use of bark, wood chips and log ends have been used in the production of soil and mulch products since the 1980s. Currently, soil and mulch producers in Ontario utilize at least 25% of the annual volume of bark produced in the province, and the prices paid for bark by these producers in comparison to power generators means that soil and mulch producers account for approximately 50% of the total dollar purchases of bark generated annually in Ontario.
- Walker’s Resource Recovery division is believed to be the single largest bark purchaser in the province.
- Ontarians spend over $4 billion on landscaping service and supplies annually (Statisca 2020).
- The use of forestry biomass in landscaping materials is a highly beneficial use of carbon in that it decomposes slowly over time, adding much needs organic matter and carbon to soil. Secondly, it potentiates the growth of an ‘urban canopy’ which is in itself a carbon sink and climate change modifier. Thirdly, processed bark and wood fiber are substitutes for the non-renewable ‘peat’ materials in soil products and that trend promises to grow the market for processed bark as the carbon impacts of peat harvesting come to public attention.
- The Statscan report cited in the Draft Forest Biomass Action Plan failed to consider and thus ignored the landscaping sector as a user of forestry biomass (written communications with Statscan).
- There are other significant users of Ontario forestry biomass that also appear to have been ignored in the preparation of the Draft Forest Biomass Action Plan (eg. particle board, animal bedding).
- A major British producer of bark and wood fiber based soils reports that government intervention in the UK, designed to promote forestry biomass in community heat and power projects, has disrupted their access to bark and wood fiber for horticultural purposes. (www.floraldaily.com/article/9301804/a-perspective-on-peat-free-growing-…)
- How is the Draft Forest Biomass Action Plan going to ensure that thousands of Landscaping Industry sector jobs, as well as other forestry biomass using sectors, are not adversely effected by interventionist policies to promote a promising but economically unproven ‘bioeconomy’ sector?

3. THE FBAP DOES NOT APPEAR TO CONSIDER THE USE OF ‘RECYCLED’ WOOD PRODUCT AS A COMPETITIVE FEEDSTOCK FOR BIOENERGY PROJECTS
- New bioenergy start-ups in Ontario are looking to access recycled wood waste from construction, demolition, landfills and secondary wood processors for feedstock, rather than green forestry biomass. They are attracted by the lower moisture content of recycled wood which is <20% compared to forestry biomass which is >40%.
- Studies of recycled wood generation in Southern Ontario estimate that 800,000 to 1,000,000 MT are generated annually.
- Recycled wood costs start at negative value and are less expensive to transport due to significantly lower moisture content in the material
- Transporting green forestry biomass from Northern Ontario to bioenergy start-ups in Southern Ontario appears to be cost prohibitive given the presence of available alternative recycled wood

June 18, 2021