LETTER:Lehigh plan should include demonstration project

The Lehigh Cement Plant in Picton is seeking approval from the Ontario government to add non-recyclable material to its current fuel mix of natural gas, petcoke (petroleum coke) and coal.

The company is applying under Ontario Regulation 79/15 of the Environmental Protection Act. Lehigh’s Cement’s first public meeting was held last week. As noted by Lehigh’s Permitting Project Team, this meeting was being held in accordance with O. Reg. 79/15. This is true to a point but is also misleading. In fact, there are two types of Environmental Compliance Approvals under this Regulation. One type of approval is “in respect of a Demonstration project” which is basically a pilot project that proponents undertake over a 3-year period – a trial run to test the project, iron out the glitches and report back on the results. The other type of application is for a “Non-Demonstration project”. If approved, proponents are permitted to use ALCFs (Alternative Low Carbon Fuel) on a long-term basis.

As part of the application process, proponents must fulfill specific requirements for public notice and public consultation.

Since Lehigh Cement is holding public meetings at this time, it appears the Company decided to not undertake the preliminary Demonstration project. The Project Teams’ failure to mention the Demonstration project option at the public meeting – and more importantly to explain why they chose to skip this step, is concerning.

This suggests lack of transparency for one thing: decisions being made behind closed doors about what the PEC public needs to know, and by extension doesn’t need to know. But the more important question is why the Company isn’t doing this pilot project, and whether not doing so could potentially pose any risk to the PEC public.

It would seem reasonable, and in everyone’s best interests, to undertake a pilot project when just starting out from scratch. Other cement plants in Ontario including St. Mary’s Cement certainly thought so, as they have chosen to undertake Demonstration projects prior to applying for a Permit to Use Alternative Low Carbon Fuel (ALCF) at their plants. Undertaking a Demonstration project gives Lehigh Cement more time to prepare as well. As of the first public meeting the company has not yet identified a supply source for this non-recyclable fuel. The Project Team suggested at the public meeting that potential sources could be 50 to 100 kilometres away: “some could be farther and some closer”; Buffalo, New York is the farthest at “probably 100 – 200 kilometres away”.

The Project Team noted three technical reports would be provided prior to the second meeting but made no mention of a Traffic Report. Other responses from the Project Team were sketchy on details, including their responses about storage and the number of trucks involved on a daily basis. After making some calculations the estimate was 10 – 12 trucks per day, each carrying 20 ton loads and no trucks on weekends. But their estimates are based on their proposal to burn 200 tons of ACFLs per day. Can we count on that?

If the application is approved there doesn’t seem to be anything standing in the way of burning more. We were informed by the Lehigh Project Team that low carbon fuel has been used for a long time in Europe. The inference of course is that we need to step up our game here and get serious about reducing carbon emissions and landfill waste. But my impression is that it’s really Lehigh Cement that needs to step up its game.

As a first step, Lehigh Cement Plant needs to undertake a Demonstration project. Once that’s been done, just give us the facts instead of empty assurances that there’s no cause for concern.

Paula Peel

Prince Edward County