To whom it may concern, At…

To whom it may concern,

At Vale Base Metals Ltd. (Vale Canada Limited) we are committed to reducing our scope 1,2 & 3 carbon emissions. In line with this commitment our Ontario operations are actively pursuing decarbonization opportunities for our operations in Sudbury and Port Colborne. Being the supplier of choice for low-carbon critical minerals is our ambition. Reducing these emissions from our facilities in Ontario is fundamental to our ability to produce low carbon intensive nickel, copper and cobalt products from our refineries in Canada.

We support the Ministry of the Environment, Conservation and Parks’ regulatory proposals to the Emissions Performance Standard and GHG reporting programs, specifically expanding the eligibility for renewable natural gas (RNG).

The opportunity for our Emission Performance Standards (EPS) facilities in Sudbury and Port Colborne to purchase RNG through contract with a gas utility as displacement fuel for our higher-carbon natural gas consumption, and to account for the associated emission reductions as part of our facility’s verified emissions, has the potential for sizable carbon reductions (>100kt CO2e) at our Ontario operations in the short/medium term.

Under the current regulation, we need to purchase and physically consume RNG at each of our EPS facilities in order to account for the associated emissions reduction from displacing the currently-used higher-carbon natural gas. However, given the large volume of natural gas that our operations consume, which is in the range of 100-150 million m3/year, and their remote geographic locations, producing and sourcing an adequate local supply of RNG that we would be able to consume directly is currently very cost prohibitive and thus not feasible.

The proposed regulatory amendment to expand the eligibility of RNG will allow us to account for a switch from a higher to a lower-carbon fuel source at a significant scale, generating demand across the province for an increased production of RNG volumes that will displace higher-carbon natural gas. This portfolio approach is a net benefit across the system in the province and would lead to significant industrial emission reductions.

Vale Base Metals appreciates the opportunity to comment on the proposed amendments to the GHG Reporting Regulation and the guideline to expand eligibility for RNG. Specifically, we support the move to allow EPS facilities to procure traceable RNG (as well as lower grade biogas) and deduct the emissions resulting from its combustion from our EPS facilities, even if not directly used at these facilities.

We would like to note that the criteria of ‘the RNG was injected into the Ontario natural gas distribution system’ is unclear. If the requirement is to have the physical gas molecules available within Ontario natural gas pipe network, consideration for eligibility should be given to RNG producers injecting in locations that are outside of Ontario but still interconnected to the distribution network (e.g. western Canada or the United States).

Additionally, for the purposes of GHG reporting and accounting requirements within Ontario, we would encourage and support regulation changes that would also allow Ontario gas users to contract a virtual supply of RNG from a user that is NOT connected to the Ontario natural gas distribution system while allowing the virtual user the ability to claim the associated carbon savings. This would need to follow a transparent and auditable process to ensure compliance with GHG reporting requirements. This could potentially enable further industrial decarbonization of Ontario based gas users in the event that ‘local’ producers (i.e. producers with access to Ontario distribution network) are unable to generate the supply required by Ontario based consumers.

Thank you.

Vale Base Metals