I do NOT support these…

I do NOT support these changes. If this change allows for the burning of non-recyclable plastic waste in incinerators or to fuel lime kilns, this will be a disaster for the environment and, more specifically, to my local community. We live in Greensville Ontario right in the middle of the “Green Belt”. We live in an area called Spencer Gorge which is home to some of Ontario’s most iconic waterfalls and nature reserves. This area receives visitors from all over the world and significant tourism revenue is derived from our beautiful parks and unique geological sights. Unfortunately, this area is also home to Lafarge quarries and Carmeuse (a known polluter), a producer of cement and lime products. Two years ago the community was in a fight to stop Carmeuse from using non-recyclable materials (aka, GARBAGE) including plastic waste to fuel their lime kilns. Luckily, and with the firm support of the community and local politicians, Carmeuse (the polluter), was forced to reconsider their plans. This change in re-cycling policy only supports a stupid and myopic practice that will endanger the health of our communities and degrade the already fragile ecosystem that forms the basis for a thriving tourist attraction. There are several reasons this policy change is short sighted and should NOT be enacted:

Burning non-recyclable plastic waste as fuel in lime kilns has been promoted by some as a form of “chemical recycling” or “waste-to-energy,” but there are several advanced, science-based arguments against this practice. These arguments draw from environmental science, toxicology, public health, materials science, and climate science.

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🔬 1. Formation and Release of Toxic Pollutants

▪️ Scientific Basis: Incomplete combustion & high chlorine content
• Plastics like PVC contain chlorine and other halogens, which, when burned, produce toxic compounds such as:
• Dioxins and furans, which are highly toxic and persistent organic pollutants (POPs).
• Hydrochloric acid (HCl) and other corrosive acid gases.
• Even at high temperatures (~1450°C in lime kilns), transient cooler zones can lead to incomplete destruction of these toxics.
• Peer-reviewed data: Studies (e.g., Wikström et al., 2004; Costner et al., 2001) show elevated dioxin/furan emissions when burning chlorinated plastics.

Implication: These pollutants bioaccumulate, travel long distances in the environment, and are linked to cancer, endocrine disruption, and developmental toxicity.

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🌍 2. Lifecycle Greenhouse Gas (GHG) Emissions

▪️ Scientific Basis: Fossil carbon content of plastics
• Plastics are fossil-based hydrocarbons; burning them releases CO₂, contributing directly to climate change.
• Studies (e.g., UNEP, 2021) show that incinerating plastic emits more CO₂ per unit of energy than coal or diesel.
• E.g., Polyethylene emits ~2.9 kg CO₂ per kg burned.
• Co-processing in kilns may replace fossil fuel, but it does not offset the total carbon burden because:
• The plastic’s carbon is not biogenic (unlike some biomass fuels).
• No carbon sequestration benefit exists; it’s a one-way emission stream.

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🏭 3. Dilution of Cement Product Quality

▪️ Scientific Basis: Incorporation of impurities into clinker
• Burning plastic can introduce metallic and non-metallic impurities, including:
• Heavy metals (e.g., lead, cadmium) from colorants or additives.
• Chlorine and sulfur, which affect clinker quality and increase kiln corrosion.
• Studies (e.g., Schneider et al., 2011 in Cement and Concrete Research) note chloride limits must be maintained to avoid product degradation.
• Toxic fly ash or clinker dust can be harder to manage than controlled industrial waste.

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🧪 4. Microplastic and Nanoplastic Residue

▪️ Scientific Basis: Incomplete combustion and particle formation
• At suboptimal burn conditions, micro- and nanoplastics may form and be released in flue gas.
• These particles:
• Can carry heavy metals and persistent organic pollutants.
• Penetrate deep into the lungs and bloodstream upon inhalation.
• Recent studies (e.g., Prata et al., 2020) suggest incineration and co-processing may not eliminate all microplastics.

Implication: Emissions monitoring often does not detect nanoplastics, underestimating environmental health risks.

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👩‍⚕️ 5. Public Health Risks Near Kilns

▪️ Scientific Basis: Proximity exposure to complex emissions
• Communities living near cement plants or lime kilns report:
• Higher respiratory illness rates
• Elevated cancer risks associated with exposure to VOCs, PAHs, and heavy metals.
• Epidemiological evidence: WHO and EEA reports link industrial incineration emissions to local health burdens.
• Lime kilns often lack the scrubbing systems found in dedicated waste incinerators.

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🧾 6. Regulatory Gaps and Inadequate Monitoring

▪️ Scientific Basis: Enforcement vs. capability
• Many lime kilns are not designed or permitted for waste incineration.
• Emissions monitoring (e.g., dioxins, metals, ultrafines) is often intermittent or limited, missing peak releases.
• Peer-reviewed studies (e.g., Zero Waste Europe, 2020) show non-compliance with EU Waste Incineration Directive in many co-incineration scenarios.

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📉 7. Discouragement of True Circular Economy Solutions

▪️ Scientific Basis: Systemic feedback loops
• Treating plastic as “fuel” disincentivizes upstream interventions such as:
• Material redesign
• Advanced mechanical recycling
• Extended producer responsibility
• According to the Ellen MacArthur Foundation, burning plastic locks us into a linear economy, undermining long-term sustainability

RECONSIDER YOUR POLICY AND DO NOT ALLOW THE BURNING OF NON-RECYCLABLE WASTE TO FUEL LIME KILNS