Pre-Budget Consultations: Ontario must act to ensure industry investment

There is a wave of chemistry facility investment taking place globally and Ontario could see an infusion of investment, jobs and tax revenue, but it must improve its competitiveness, Don Fusco, Director, Government and Stakeholder Relations – Ontario told the Standing Committee on Finance and Economic Affairs as part of its Pre-Budget Consultations for the Ontario 2019-20 Budget on February 7, 2019.

Mr. Fusco pointed out that there is a wave of new chemistry investments being made in the North America driven by the low carbon shale gas phenomenon. The U.S. has seen over 320 new global-scale chemistry investments completed, under construction or announced with a cumulative total of more than $250 billion – of which 60 per cent is foreign direct investment.

“But what about Ontario? NOVA Chemicals’ is making a $2 billion investment to expand its operations in Sarnia. This project is the second biggest manufacturing investment made in Ontario in a century,” Mr. Fusco told the committee. “However, had we kept our historical share of new investments, we could have realized another eight global scale investments worth more than $10 billion.”

Mr. Fusco urged the government to maintain their focus on competitiveness and investment attraction through tax credit measures (as has recently been done in Alberta and other jurisdictions), continue their Open for Business Action Plan of modernizing and streamlining regulations, improving electricity costs, and capitalizing on potential innovation surrounding plastic waste and the circular economy.

CIAC appears before Senate Committee studying Bill C-74 to discuss carbon-pricing legislation

Isabelle Des Chênes, CIAC Executive Vice-President, and Shannon Watt, Director of Environment and Health Policy, appeared before the Senate Committee on Energy, the Environment and Natural Resources on May 3, 2018. Senators are conducting a pre-study of the provisions of Bill C-74, the budget implementation bill, that deal with the government’s plan to price greenhouse gas emissions.

CIAC and its members support efforts to reduce global carbon emissions and have worked collaboratively with both provincial and federal officials to ensure that carbon policies and pricing mechanisms improve environmental performance, avoid double-regulation and maintain Canada’s competitiveness.

Ms. Des Chênes noted that “Canada should support a carbon policy that recognizes emission-intensive, trade-exposed sectors and encourages investments in the Canadian chemistry sector. Additionally, given the incredible investments in innovations and technologies to improve performance around air emissions and climate change, Canada’s proposed output-based allocation process should focus on benchmarking Canadian chemistry operations and performance against global competitors.”

Additionally, Ms. Watt reinforced the point that government needs to provide a comprehensive analysis of the cumulative impacts of the suite of climate change policies including the proposed Clean Fuel Standard.

Watch the CPAC recording: Fuel Suppliers Discuss the Carbon Tax

CIAC comments on draft regulations related to the Environment Quality Act (French only)

Au cours de l’année 2016, le Gouvernement du Québec a publié le Livre Vert ayant pour objectif de moderniser le régime d’autorisation environnementale.  À ce moment, l’ACIC avait présenté un premier mémoire.  De là est né la nouvelle Loi sur la Qualité de l’environnement (LQE), adopté le 23 mars 2017 et mise en vigueur le 23 mars 2018.

Dès l’automne 2017, le Ministère du développement durable, de l’environnement et de la lutte contre les changements climatiques (MDDELCC) a mis à jour vingt-deux (22) projets de règlements pour assurer la cohérence avec la nouvelle loi.  Des journées de consultation ont été organisées auprès des différents groupes d’intérêts, des associations sectorielles et des entreprises pour obtenir leurs commentaires.  En collaboration avec le Conseil Patronal de l’environnement du Québec, l’ACIC, avec la précieuse collaboration de ses compagnies membres, a amorcé la rédaction de mémoires pour ces projets de règlements.  En priorité, l’ACIC a présenté un mémoire en collaboration avec le CPEQ quant aux mesures transitoires à mettre en place dans le cadre de la nouvelle loi et a présenté trois mémoires afin de présenter des commentaires spécifiques à ses opérations.  Les trois (3) mémoires présentés visaient les projets de règlements suivants :

  • Projet de règlement relatif à l’évaluation et à l’examen des impacts sur l’environnement de certains projets ;
  • Projet de règlement relatif à l’autorisation ministérielle et à la déclaration de conformité en matière environnementale ;
  • Règlement modifiant le Règlement sur les attestations d’assainissement en milieu industriel.

D’autres projets de règlements on fait l’objet d’analyse mais n’ont pas fait l’objet de mémoires considérant leur absence d’impact sur les opérations de notre industrie.

Tout au long de la rédaction de ces mémoires les objectifs de l’ACIC étaient :

  • Assurer la compétitivité de notre industrie chimique au Québec ;
  • Favoriser la simplification du régime environnemental ;
  • Assurer l’utilisation efficiente des ressources en environnement de nos entreprises et du gouvernement ;
  • Assurer la valeur ajoutée des demandes du ministère de l’environnement aux activités d’amélioration du développement durable.

Un travail de collégialité ayant permis de servir les intérêts de nos compagnies membres.

Senate report looks at how chemistry sector can reduce carbon emissions

CIAC President and CEO Bob Masterson underscored the chemistry sector’s crucial role to achieving Canada’s emission reduction challenge when he appeared before the Standing Senate Committee on Energy, the Environment and Natural Resources in February 2017.

The resulting recommendations were published earlier this month in a report called Decarbonizing Heavy Industry: The Low-Carbon Transition of Canada’s Emission-Intensive and Trade-Exposed Industries.

“We have among the highest and richest reserves of natural gas and natural gas liquids that allow for chemical production from methane, ethane and propane, which have the lowest greenhouse gas potential of all the remaining chemical feedstocks,” Mr. Masterson told the Committee.

However, he raised concerns that the uncertainty over carbon pricing after 2020 created a poor environment to attract investment.

“When we can’t tell people what the regulatory and pricing environment looks like after three years from today, in 2020, they’re going to be very hesitant to put their money into Canada,” he said.

Read the full report here.

CIAC voices budget recommendations to Ontario’s Finance and Economic Affairs committee

On January 17, 2018, CIAC President and CEO Bob Masterson addressed Ontario’s Standing Committee on Finance and Economic Affairs. The committee was in Ottawa on their province-wide pre-2018 budget consultation tour.

Masterson’s key message was that only robust economic growth, driven by new investment, would provide the economic opportunities and prosperity Ontarians want and desire.

He reminded the committee the chemistry industry already plays an important role Ontario’s fiscal equation — a $22 billion industry directly employing 45,000 well-paid employees — but noted that more has to be done to retain and attract new investment dollars from the global chemistry industry. In fact, Masterson noted, the province should be attracting a larger portion of the North American chemistry industry investments.

“We would have expected to see 12 to 15 global scale investments totalling $15 billion or more. Instead, until late last year, the province saw no global scale investments, and only about $1.5 billion or 10% of expectations in capital investment.”

CIAC’s recommendations are focussed squarely on improving Ontario’s fiscal and regulatory policies to make the province the “jurisdiction of choice” for new chemistry industry investments.

Read our submission to learn more: Ontario Chemistry Industry 2018 Pre-budget consultation.

Ontario’s Red Tape Challenge – Have you made your submission?

On August 1, 2017, the Chemistry Industry Association of Canada (CIAC) provided comments to the Ministry of Economic Development and Growth Red Tape Challenge consultation of the chemical manufacturing sector (the submission is available here).

CIAC strongly urges member-companies to help raise the profile of the Association’s comments and recommendations by creating your own user profile and providing your support, anecdotes and company stories along with those posted by CIAC. The consultation period ends on September 30, 2017.

The instructions for creating a profile and hyperlinks to CIAC’s online comments are provided below.

Creating a user profile:

  1. Go to the Red Tape Challenge homepage
  2. In the top right corner select “Login or Register”
    1. You will be prompted to create a new user account. This account can either be individual specific, or you can choose to make it a company account – which is what CIAC has done – by filling out the online boxes
    2. Follow the prompts and await a confirmation email to activate your account

​Submitting comments:

  1. Once your account is activated and you are logged in, please use the hyperlinks listed below to find CIAC’s postings within the different acts and regulations.
    1. Ministry of Environment and Climate Change O. Reg. 455/09: Toxic Reduction Act

    2. Ministry of Environment and Climate Change O. Reg. 455/09: Toxic Reduction Act  – NPRI and Time Filling Out

    3. Ministry of Environment and Climate Change O. Reg 63/95 and O. Reg 64/95 Effluent Monitoring (Organic and Inorganic Chemical Manufacturing Sectors) Municipal Industrial Strategy for Abatement (Comment 742)

    4. Ministry of Environment and Climate Change O. Reg 63/95 and O. Reg 64/95 Effluent Monitoring (Organic and Inorganic Chemical Manufacturing Sectors) Municipal Industrial Strategy for Abatement (Comment 757)

    5. Ministry of Environment and Climate Change Environmental Protection Act Environmental Compliance Approvals (Comment 755)

    6. Ministry of Environment and Climate Change Environmental Protection Act Environmental Compliance Approvals (Comment 765)

    7. Ministry of Environment and Climate Change O. Reg 347 Waste Manifests

    8. Ministry of Labour Occupational Health and Safety Act, R.S.O.1990

    9. Technical Standards and Safety Association (TSSA) – various aspects

In the specific screens, you will be able to submit your own comments or you will be able to add to existing submissions. CIAC recommends utilizing the submissions that we have already made based on our formal document, but if there are other company specific measures you would like to see included feel free to initiate a new comment.

Addressing regulatory burden in Ontario a priority for the chemistry sector

On August 1, 2017, the Chemistry Industry Association of Canada (CIAC) provided comments to the Ministry of Economic Development and Growth Red Tape Challenge consultation of the chemical manufacturing sector.  CIAC strongly urges member-companies to submit their own comments and suggestions during the consultation period: August 1 to September 30, 2017
Below is a summary of the key regulatory burdens impacting the competitiveness of the sector and the Association’s recommendations included in the submission (the full submission is available here).

BURDEN: Ministry of Environment and Climate Change (MOECC) O. Reg. 455/09: Toxic Reduction Act (TRA)

  • Strongly consider alternative compliance pathways to achieve the same policy objectives.  CIAC’s Responsible Care® initiative should be recognized by the Province as an equivalent oversight and public reporting measure in place of the Toxic Reduction Plans and Reports. 
  • Adjust the Reporting Cycle to require triennial, rather than annual reporting and/or require updated reporting in year following any (operational) approval amendment.
  • Develop a provision for exceptions from the regulation where a company can show that a substance required to be included in the Toxic Reduction Plan is an integral part of their business or a commodity for sale, such as a feedstock for manufacturing an intermediate or end product.
  • Eliminate the TRA as firms already report the same information into the National Pollutant Release Inventory (NPRI) and develop an information-sharing protocol with the federal government for the NPRI information as noted in the Red Tape Challenge Auto Parts Manufacturing consultation.

BURDEN: Ministry of Environment and Climate Change O. Reg 63/95 and O. Reg 64/95 Effluent Monitoring (Organic and Inorganic Chemical Manufacturing Sectors) Municipal Industrial Strategy for Abatement

  • Eliminate the MISA regulations and transfer all relevant water discharge requirements into each facilities’ Environmental Certificate of Approval to enable greater adaptability and Ministry engagement based on changes to operational or other factors.
  • Enable facilities to analyze water discharges using technology that meets current industry standards rather than force facilities to use outdated analyzer technology and processes.
  • Update MISA regulations to ensure all relevant and up-to-date requirements are in place for covered facilities and establish a protocol for managing amendments in a timely manner.

BURDEN: Ministry of Environment and Climate Change Environmental Protection Act Environmental Compliance Approvals

  • Reduce the 1-year service standard for complex approvals.  Strive to set lower service standards as other jurisdictions in Canada and the United States process environmental permits much quicker.
  • Prioritize and expedite approvals for projects involving new capital investments, job creation and retention, and improved environmental performance ahead of other applications.  

BURDEN: Ministry of Environment and Climate Change O. Reg 347 Waste Manifests

  • Automate and make online the manifest process to enable simple electronic data protocols which include pre-populated fields, drop-down boxes and electronic file tracking.

BURDEN: Ministry of Labour Occupational Health and Safety Act, R.S.O.1990

  • Repeal Section 34 regulation and establish an information sharing protocol with the federal Ministry of the Environment and Climate Change Canadian Environmental Protection Act New Substances Notification Regulations (Chemicals and Polymers).

BURDEN: Technical Standards and Safety Association (TSSA) – various aspects   

  • Develop, publish and implement consistent standards and related requirements with TSSA.
  • Embark on a culture change initiative within TSSA, increasing awareness of their role in being solutions-oriented in their interactions with regulated entities.
  • Ensure new project proponents are given a central point of contact within government to rationalize conflicting requirements within and between government regulatory authorities such as the TSSA, the Electrical Safety Authority, the Ministry of Labour and MOECC.

BURDEN: Ministry of Municipal Affairs O. Reg 311/06: Transitional Matters – Growth Plans

  • Enact a buffer zone regulation which would explicitly enshrine public safety practices and Ontario’s manufacturing heritage and thereby reduce uncertainty in land planning decision making, both within municipal governments and at the OMB.   


For more information on the Red Tape Challenge visit:

Masterson at CERI Petrochemical Conference: “Canada’s federal and provincial governments need to row in the same direction.”

On June 6, Bob Masterson, CIAC president and CEO, gave the keynote address at the CERI Petrochemical Conference in Kananaskis, Alberta: “Rowing in the Same Direction – What’s Needed to Realize Petrochemical Investment in Canada.” He addressed concerns related to the changing nature of Canada-U.S. relations and the potential impact on Canadian industry. He also highlighted how industry and government can – and need – to work together for Canada to keep its place in the global economy. 

“The lack of new investment at a time of re-investment in the U.S., combined with policy choices in central Canadian provinces that have left investors and operators scratching their heads, makes for a highly uncertain future for Canada’s chemistry sector,” Masterson said. “If we are to succeed and float a credible plan, it is going to take unprecedented coordination between business and government, and between governments at all levels.”

At the conference, Dylan Jones, Deputy Minister, Western Economic Diversification Canada – who reports to Innovation, Science and Economic Development (ISED) Minister Navdeep Bains – suggested CIAC’s Ottawa advocacy campaign had caught the attention of government decision makers. The government is beginning to change how it views the chemistry sector and is willing to support the industry in the future because of CIAC’s advocacy efforts.

Key messages from the Deputy Minister included:

  • Chemistry is far from the only sector seeking subsidies or investment assistance, but providing that assistance is a role of government; 

  • Government needs sound data to make good decisions and industry and government need to work together on the interpretation of data; and, 
  • The government makes investments, sector comparisons and policy decisions on which sectors to fund/not fund.  

Masterson’s full speech is available here, and his presentation slides are available here.

Unnecessary regulatory burden in Ontario adds time, effort, complexity and costs to chemistry sector’s operations.

On May 18, CIAC participated in meeting with the Ministry of Economic Development and Growth’s Open for Business Division, in preparation for the Red Tape Challenge (RTC) chemicals manufacturing consultation. 

At the meeting, Don Fusco, Director, Government and Stakeholder Relations – Ontario, led a discussion session on a list of regulatory burdens for the chemistry industry.  Member representatives described how these burdens cause additional time, effort, complexity and costs to their operations.

The Ministry’s Red Tape Challenge team appreciated CIAC’s comments on the key burdens facing the industry and will engage with partner Ministries to address these comments. 

Kevin Perry, Assistant Deputy Minister said the Ministry values the contribution of the chemical manufacturing sector to the provincial economy and is looking for industry input to reduce unnecessary regulatory burden without sacrificing policy outcomes. He is pleased that the CIAC is taking a proactive approach to the RTC.

While CIAC will submit comments to the RTC reflecting the discussion, the Association strongly urges member-companies to submit their own comments and suggestions during the consultation period (August 1 to September 30, 2017). 

You can view the list of regulatory burdens CIAC discussed at this meeting here.

For more information on the RTC visit:

CIAC meets with Ontario Premier Kathleen Wynne to discuss Ontario-U.S. chemistry industry trade issues

On May 5, CIAC hosted a roundtable with Ontario Premier Kathleen Wynne and representatives from the Sarnia-Lambton chemistry cluster at Lambton College to discuss the importance of the cluster to the local and the Ontario economy, the importance of unfettered access to the U.S. and global markets, as well as investment and growth opportunities to support the continued evolution of the cluster.

“I’m working with the Great Lakes governors to impress upon them how much we want to continue to have an open border and how important it is to us that we keep that integrated relationship that we’ve kept over the past decades,” Wynne said. “When it comes to trade, we need a two-prong approach where the industry and government are saying the same thing to U.S. officials.”

Ontario’s $22 billion chemistry sector is the Province’s third largest manufacturing sector.   The chemistry industry is also Ontario’s second largest manufacturing exporter. In 2016, Ontario chemistry sector trade imports from the U.S. totalled $23 billion, while exports to the U.S. totalled $16.1 billion. The top Ontario-U.S. trade partners include Texas, Ohio, New Jersey, and Pennsylvania., among others.

“More than 70 per cent of all the chemistry we make in Ontario is exported to the United States. In short, nothing is more important to our sector’s economic well-being than maintaining free and open access to our US markets,” said Bob Masterson, President and CEO of CIAC. “Ontario’s engagement in the issue is an important complement to the efforts of the federal government in Ottawa.”

At the roundtable, Don Fusco, CIAC’s Government and Stakeholder Relations – Ontario, noted that there have been over $1 billion in chemistry sector investments in Ontario over the past five years and acknowledged the Province’s support through programs, including the Jobs and Prosperity Fund.    Don emphasized that the industry is looking to continue to work with the Provincial officials and lever investment attraction programs to secure additional investments as our sector growth opportunities are aligned with the Province’s economic and innovation goals.  

Participants from the chemistry industry included anchor members and key partners in the Sarnia Lambton cluster, demonstrating the strength, integration, collaboration and diversity of the cluster: ARLANXEO, BioAmber, Cabot Canada, Imperial Oil, NOVA Chemicals, Shell Canada, Lambton College and Bioindustrial Innovation Canada. 

CIAC will continue to work with Ontario government officials to strengthen the Province’s competitiveness to achieve the shared objective of future investments and growth.