Good afternoon. Thank you very much for having me here today, Mr. Chair.
My name is Scott Thurlow. I am a senior adviser for government affairs for Dow Canada.
For more than 75 years Dow has been proudly innovating in Canada. We develop basic chemicals and polymers used to make a broad range of innovative and technology-based products and solutions in the packaging, industrial, infrastructure and consumer care industries. We are one of the largest resin producers in the world.
We are here today to talk about how a regulatory initiative can have multiple goals and simultaneously solve several different environmental problems. We believe that the recently proposed clean fuel regulations can do just that. It is our view that another problem that we could be addressing through the CFR is plastic waste, and this is an issue of paramount importance for our company.
How a product's life cycle is defined is very complex. It is true that fuel derived from recovered plastic will have a modest GHG improvement when contrasted to fuels derived without any recovered plastic content, but that GHG reduction is modest when compared to the overall social benefit of having reduced waste in landfills and preventing fugitive plastic waste from entering the environment.
The CFR should allow for compliance credits to be generated for environmental benefits that are not as clearly tied to GHG reduction but have other demonstrated environmental benefits. Rewarding the potential for products from the pyrolysis of plastic waste, such as fuel oil or diesel, to meet the standard for compliance category 2 low-carbon fuels can do just that.
At Dow we have taken many steps to address the plastic waste problem. One such example is our leadership in the development and implementation of the “Hefty Energy Bag” program in London, Ontario, in October 2019. The purpose of this program is to collect hard-to-recycle plastics at residential curbside and to divert plastic from landfills. The process could not be any easier for everyday consumers who want to do their part to create a circular economy.
It offers more than 13,000 households in London a distinguishable orange bag to discard their clean and dry plastics that are not normally accepted in the recycling bin. These include plastic wrap, flexible plastic reusable pouches, foam takeout containers, plastic utensils and snack food bags. How does it work? Once the hard-to-recycle plastics are collected, our project partners allow for the use of the existing waste management infrastructure to seamlessly collect and repurpose these plastics into valuable resources. Around the world we have used plastic waste to build roads and fuel municipal buses.
That said, this committee needs to know that investments in advanced recycling facilities are difficult to secure. Chemical depolymerization is energy-intensive, and that makes it very difficult for the recovered product to compete with virgin resin from a financial perspective. That is where the compliance pathway for the clean fuels regulations can come in. The opportunity to generate CFR credits would create an additional incentive to create the supply in Canada. In turn, this would enable a supply chain for hard-to-recycle plastics and enable an earlier transition to a circular economy for hard-to-recycle plastics.
With that having been said, I want to take a moment to discuss the Prime Minister's pledge to ban certain single-use plastics by the end of this year. A ban will not deal with the fact that our waste management processes need improvement. A ban should be the last step that a government takes as it works to deal with an issue, not the first.
The minister has proposed regulations under CEPA to give life to this ban. We do not believe CEPA is the right tool for regulating plastic. We believe that this is an issue that is fundamentally an issue of waste management, a provincial responsibility. We believe that there is a federal role through the CCME, but we do not support banning certain plastics. We certainly don't agree with making a legal determination that plastic manufactured items are toxic substances. The issue with plastic waste is not the plastic itself but the behaviour that allows it to leak into the environment. As a criminal law statute, CEPA is meant to punish actions, not objects.
In conclusion, no one believes that plastic belongs in the natural environment. We support actions to protect the world's oceans. We think that the clean fuel regulations can help achieve that goal.
I would welcome the opportunity to answer your questions on any of these vitally important issues.