Dear Honorable Rod Phillips,…

Dear Honorable Rod Phillips, Minister of the Environment, Conservation and Parks;

The following are my comments on Bill 54, the Green Energy Repeal Act, 2018, to amend Renewable Energy Approvals Regulation (O. Reg 359/09), and that if passed the legislation would amend the Environmental Protection Act, “to enhance the government’s authority to prohibit issuing renewable energy approvals, including when the demand for the electricity has not been demonstrated”.

We at Bradam Canada Inc. agree renewable energy approvals FOR ELECTRICITY PRODUCTION, should be prohibited, including when the demand for ELECTRICITY has not been demonstrated. Please note our stress on ELECTRICITY.

However, there are other forms of energy than electricity as you are aware, including fossil-carbon natural gas, AND renewable natural gas from renewable ('organic'), non-fossil carbon materials.

Bradam Canada Inc will be submitting requests for approval from the Ministry of Environment, Conservation and Parks for Steam Reforming Plants for the production of two different types of natural gas:
1. Renewable Natural Gas (RNG) produced from renewable ('organic') non-fossil carbon (primarily food wastes, sewage sludge and paper processing sludge);
2. Substitute Natural Gas (SNG) produced from waste, non-recyclable plastics which are currently creating significant waste management issues in Ontario and elsewhere.

These projects will produce natural gas in Ontario, using Ontario feed stocks and in Steam Reforming Plants with equipment manufactured in Ontario, and operated by Ontarians (4 plants employing about 60 Ontarians each).

In our opinion is should be made clear and in Bill 54 that the projects for the production of these two sources of natural gas should not be included in Bill 54. You need to make Bill 54 very clear that the restrictions related to the production of electricity, not other forms of energy such as natural gas.

Thank you and best regards;

Bob Willes, CTO, Bradam Canada Inc. (bobw@bradamgroup.com)