OMNI applauds the MECP’s…

OMNI applauds the MECP’s recent proposal on regulatory amendments to clarify program requirements and improve program efficiency for Emissions Performance Standards (EPS) and GHG Reporting programs. As an advanced technology provider of equipment for clean fuel production, including RNG, we would like to present the following comments on the MECP’s recent ERO #019-7649. A more detailed submission with background is also being attached.

Comments in response to ERO #019-7649:

OMNI does not have any specific comments regarding the first two questions for discussion in the proposal.

Question for Discussion #3: Should RNG procured by an EPS facility and injected into the Ontario natural gas system be eligible to be considered as if it is being used directly at an EPS facility? Are there any circumstances where this approach would affect the integrity of the EPS program?

OMNI strongly agrees that RNG procured by an EPS facility and injected into the Ontario natural gas system should be eligible to for consideration, as if it is being used directly at an EPS facility.

This accommodation would spur innovation and broaden market opportunities to produce and sell RNG within Ontario. As covered in the attached submission’s introduction, OMNI’s innovative technology directly addresses Ontario’s mandate to reduce GHG’s and increase the production and use of clean fuels, like RNG, while also tackling the province’s landfill capacity issues and associated methane emissions.

Additionally, GHG emissions from the combustion of RNG produced by the gasification of municipal solid waste should be deducted from the EPS facility’s verified emissions in full, including RNG produced from the non-biogenic portion of this waste. The profile of OmniSyngas, even when considering the non-biogenic component, results in a net negative CI score (much lower than most biomass fuels which are currently fully exempt).

Municipal solid waste (MSW) has more than 50 per cent biogenic content. Our technology harnesses this trapped energy source to produce green fuels and avoid the problems methane poses by diverting waste from landfills, proactively tackling emissions from the source. Since methane has 25-times the GHG effect of CO2, our technology allows us to produce these fuels with a negative carbon footprint.

Currently, Ontario is falling behind. In February 2023, the EU specified a methodology for assessing GHG emissions savings from renewable liquid and gaseous transport fuels of non-biological origin and from recycled carbon fuels. Similarly, in the United States, both the State of California and the Inflation Reduction Act embrace full life cycle impacts in determining carbon intensity (CI) scores and emissions calculations. We have active RNG projects in the United States and Europe, but none in Ontario due to the gaps or restrictions in the current legislation.

Ontario can promote innovation and substantial GHG emission reductions by permitting the full deduction of RNG produced from the gasification of municipal solid waste from a facility's verified emissions, ensuring that the Emissions Performance Standards do not inadvertently hinder advanced technological and environmentally superior solutions.

Ontario has the target of achieving a 30 percent reduction in greenhouse gas emissions below 2005 levels by 2030 and ensuring that Ontario does not deter solutions that divert waste from landfills is essential to achieving this target. MECP can advance this goal by not only ensuring that GHG emissions from the combustion of RNG can be deducted from the EPS facility’s verified emissions, but also ensuring that RNG produced through the gasification of municipal solid waste is included in that deduction.

This proposed change would also enable energy autonomy and job creation for the province by allowing waste-to-RNG solutions like OMNI’s to be located across Ontario for purchase and use by heavy industrial users looking to reduce their carbon emissions.

OMNI thanks the MECP for this proposal and opportunity to comment. We believe that the proposed accommodations will increase Ontario’s production and use of RNG and will not only drive a positive environmental impact but also foster innovation, job creation, and economic growth within the province.