On behalf of the Cement…

On behalf of the Cement Association of Canada and our member companies in Ontario, I am pleased to submit comments on the proposed Emissions Performance Standards (EPS) program regulatory amendments for the 2023-2030 period. We look forward to ongoing discussions with the Ministry of the Environment, Conservation and Parks.

Our top priorities, as outlined in greater detail in the attached are:

1. Ensure proposed stringency does not negatively impact the competitiveness of industry.
2. Recycle revenue back into industry, to support economic competitiveness as Ontario competes with other jurisdictions for investment in low-carbon technology.
3. Provide additional support for the deployment of carbon capture, utilization and storage (CCUS) in Ontario, as a compendium to an effective carbon pricing system.
4. Develop an offset system, both to support compliance and the deployment of necessary emissions reducing technology.

We appreciate that the Ministry is prioritizing principles of continuity and predictability for Ontario businesses and minimizing the risk for carbon leakage, considering competitiveness impacts to Ontario industry, especially Emissions Intensive and Trade Exposed (EITE) sectors.
Ontario’s cement industry remains a strong proponent of climate action, including carbon pricing. We look forward to working with you to ensure Ontario’s industrial pricing regime maintains the right balance between establishing a meaningful price signal to encourage emissions reductions while supporting competitiveness for industry.

Our sector has declared our commitment to charting a path to net-zero cement and concrete by 2050, including a commitment to reduce emissions by 15MT CO2 cumulatively by 2030. Our ambition includes maintaining competitiveness throughout the transition, but this is at risk in absence of significant evolution in Ontario’s industrial policy. To support decarbonization and economic competitiveness in the cement industry, we need funding and regulatory support to accelerate the deployment of transformational technologies including, but not limited to, Carbon Capture Utilization and Storage (CCUS); increased scope and ambition on low-carbon procurement; recognition that the codes and standards system must prioritize the uptake of lower carbon construction materials as a core metric; a policy and regulatory environment that allows for development and increased use of advanced lower carbon fuels, and consideration of enhanced measures to protect EITEs from carbon leakage. To help achieve this, we therefore offer the following comments in the attached document as Ontario considers the next stage of the EPS.