Joint submission from environmental groups on Environmental Assessment requirements for “advanced recycling” facilities

Sierra Club Ontario joins 16 other environmental groups in submitting a joint letter against the provincial proposal.


February 28, 2022 

Ian Drew 
Resource Recovery Policy Branch 
40 St. Clair Avenue West, 8th floor 
Toronto, ON 
M4V 1M2 

Re: ERO #019-4867 Environmental assessment requirements for  advanced recycling facilities under the Environmental Assessment Act (EAA) 

Thank you for the opportunity to comment on the proposed changes to  environmental assessments under the Environmental Assessment Act (EAA)  for projects that claim to engage in “advanced recycling.” 
We oppose the proposal to reduce environmental assessment requirements  for any thermal treatment or waste management facilities. We also oppose  any move to reclassify projects that purport to turn waste to fuel as  anything other than disposal. 

The importance of the environmental assessment process 

The environmental assessment process is intended to allow for public  scrutiny of facilities that are likely to have an impact on the environment and  the local community. The phrase “Advanced recycling” covers a wide range  of technologies that remain experimental for the purposes of treating waste.  That means each project requires a fulsome assessment to determine  whether it is able to deliver what the proponent suggests and what the  emissions profile is likely to be and therefore whether the project should go  ahead and, if so, what mitigation efforts are needed. For this reason, a  project of any size should be subject to public scrutiny, monitoring and  reporting to ensure it is not creating unintended harm to the environment  and the health of the surrounding community.

“Advanced recycling” does not merit regulatory streamlining

The backgrounder accompanying the Notice indicates that the purpose of  “advanced recycling” is to “recover and recycle materials back into our  economy.” This approach to “advanced recycling” is much broader than the  definition of recovery set out in the Resource Recovery and Circular  Economy Act (RRCEA) and accompanying regulations for packaging, which  state that “recovered resources must be (i) marketed for re-use for their  original purpose or function, or (ii) marketed for use in new products or  packaging. The purpose of “advanced recycling” does not correspond to a circular economy approach. 

“Advanced recycling” is promoted by the plastics and petrochemical  industries as a solution for “hard-to-recycle” plastics (1). It is not contemplated  or needed for other materials that are covered under the RRCEA, including  metals, paper, glass or organics. These materials can be recycled through  mechanical recycling processes and turned back into similar or the same products.  

“Advanced recycling” is an umbrella term, sometimes also called “chemical”  or “molecular recycling” that encompasses an ever-growing list of  technologies that are speculative when it comes to recycling plastic. The  reality is that there is no known commercial example of an “advanced  recycling” facility anywhere in the world that turns plastic waste back into  plastic products or packaging (2). 

The most common form of “advanced recycling” uses gasification or  pyrolysis technology to turn waste into fuel (3). This is, in essence, a thermal energy-intensive and polluting and require robust public oversight,  environmental safeguards and community consent (4). 

As noted above, other technologies contemplated under the “advanced  recycling” banner are experimental and little information is available publicly  about the yields from existing operations or the amount and nature of waste byproducts, which include toxic slag and ash that require disposal in  specialized landfills (5). 

The Notice reflects the goal of reducing waste going to landfill but makes no  mention of the need to reduce waste for final disposal. The most likely  projects that the proposed changes are intended to encourage must still be considered final disposal, as noted in the recent decision to reject a gasification and “advanced recycling” project for plastics in Lewisporte, Newfoundland (6). 

Producing fuel from plastic waste does not displace the raw materials needed  to make new plastic products or packaging. It is also unlikely to produce a  fuel clean enough to displace virgin fossil fuels. Despite fanfare about  producing alternative fuels for aviation fuel from waste, only 0.3% of  aviation fuels come from alternatives to crude oil (7). 

What’s more, fuels produced from plastic waste contain more toxic  substances, including carcinogens, than regular diesel (8). There is no provision  for monitoring emissions from these fuels if they are burned in a different  location from where they are produced. 

In addition, “[t]he process of converting plastic waste to fuel demands considerable energy, which is supplied by burning fossil fuels. Burning the  resulting fuel releases additional greenhouse gas emissions. Instead of  conserving the material in a circular process, burning plastic-derived fuel  adds to the carbon footprint of the plastic lifecycle and stimulates  further virgin plastic production to replace the plastic lost as fuel” (9). In other words, plastic-to-fuel is not a climate solution. 

We believe the net effect of streamlining approvals for experimental  “advanced recycling” projects will result in at least three harmful outcomes:

1. Increased pollution, including greenhouse gas emissions, from thermal  waste treatment. 
2. A missed opportunity to focus on reduction and reuse of plastic  packaging and products, including through elimination of plastics that  are not fit for conventional recycling, by pretending that these can be  effectively recycled another way instead. 
3. Continued growth of throwaway plastic use and waste. 

For these reasons, we urge you not to proceed with the proposed changes to  environmental assessments for waste projects. 

Answers to the questions posed in the Notice: 

Is the proposed approach to EA streamlining reasonable? 

No. “Advanced recycling” is an umbrella term for a set of speculative  processes about which there is little data available on things like  emissions and yields. In our view, these projects are experimental at  best, unproven and pose risks to the environment and to the health of  workers and nearby residents. For these reasons proposals require  significant public and environmental oversight and should not be  “streamlined” into existence. 

Is an 80% recovery rate based on the ministry’s proposed  criteria realistically achievable for companies proposing this  technology? 

We have absolutely no way of knowing whether an 80% recovery rate  is achievable, and we argue the ministry would also have no way of  judging whether a proponent could reach such a recovery rate  considering the experimental nature of the broad range of technologies  covered by this proposal. ChemTrust and Eunomia have noted that  virtually no data is available on yields and emissions from “advanced recycling” projects in operation (10). 

The rate of recovery will also depend on what is measured as input.  We would argue that net recovery is the value to be considered. The  input would need to include all of the waste delivered for processing,  including any materials removed prior to processing that are sent for  disposal in landfill or an incinerator, as well as the energy inputs  required to run the process.  

In any case, recovery rates will be impossible to assess until a facility  is up and running and receiving and processing waste. We don’t believe there are any yield measures, verified by a third party, that  could be used as a proxy recovery rate in applications. Each situation  is very different depending on the exact technology to be used and the  exact waste input. That means the recovery rates are also likely to  vary according to the composition of waste inputs over time.  

We believe the ministry cannot possibly base assessment requirements  on a recovery rate claimed by a proponent. 

Do the proposed definitions for advanced recycling site and  recovered materials accurately capture advanced recycling  technologies? 

“Advanced recycling” is a moving target with no accepted definition  across jurisdictions. It is also misleading: The phrase implies that the  processes are good for the environment when, as we’ve described  above, that’s not the case. A range of technologies are associated with  “advanced recycling,” including pyrolysis, gasification, solvolysis,  thermal and/or chemical depolymerization, plasma arc gasification  and, as in the recent proposal in Newfoundland cited above,  hydrothermal liquefaction. These processes generally employ some  combination of heat, pressure, controlled oxygen and catalysts and/or  solvents, to break down plastic waste and produce chemicals, fuels  and waste byproducts (including slag, tar and/or ash) fit for disposal (11). 

Any project that turns waste into fuel, or lubricants and waxes, is not  recycling and should not be included in the definition of “advanced  recycling.” 

We thank you once again for the opportunity to comment on this proposal  and ask that you not proceed to streamline the environmental approvals  process for experimental and potentially hazardous facilities that are, in any case, not consistent with recycling and the circular economy.


Lucy Bain, Ontario Chapter Co-ordinator, Sierra Club Canada Foundation

Karen Wirsig, Plastics Program Manager, Environmental Defence Canada

Emily Alfred, Waste Campaigner, Toronto Environmental Alliance

Sarah King, Head of Oceans & Plastics Campaign, Greenpeace Canada

Linda Heron, Chair, Ontario Rivers Alliance 

Gloria Marsh, Executive Director, York Region Environmental Alliance

Duncan Bury, Waste Watch Ottawa  

Olga Speranskaya, Co-Director, Health and Environment Justice Support

Sue Maxwell, Chair, Zero Waste BC 

Bill Cole, Board Chair, Clean North 

Kerry Meydam, Founder/Chair, Durham Environment Watch 

Amy Schnurr, Executive Director, BurlingtonGreen Environmental Association 

Linda Gasser and Louis Bertrand, Zero Waste 4 Zero Burning

Lynda Lukasik, Executive Director, Environment Hamilton 

Dr Yannick Beaudoin, Director of Innovation and for Ontario, David Suzuki  Foundation 

John Jackson, Co-ordinator, Citizens' Network on Waste Management


1 See the American Chemistry Council: america/news-trends/blog-post/2021/what-is-advanced-recycling-and-why-is-it-so important-for-meeting-the-growing-demand-for-recycled-plastics 

2 28-1.pdf 

3 Waxes and lubricants are sometimes also produced from “advanced recycling” processes.

4 Takada, H. and Bell, L. Plastic Waste Management Hazards. International Pollutants Elimination Network (IPEN), June 2021. 

5 Hann S. and Connock, T. Chemical Recycling: State of Play, Chem Trust/Eunomia, December 2020. 

6 rejected-1-6344970-1.6344970 


8 Patel, D., Moon, D., Tangri, N., Wilson, M. (2020). All Talk and No Recycling: An Investigation of the U.S. “Chemical Recycling” Industry. Global Alliance for Incinerator  Alternatives.  

9 Ibid.

10 Hann S. and Connock, T. Chemical Recycling: State of Play, Chem Trust/Eunomia, December 2020. 

11 GAIA, Technical Briefing, 2020: Briefing_June-2020.pdf

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