Burning of Waste Oil

 The Works and Utilities Committee reports having directed that the reports dated April 8, 1998, from the Commissioner of Works and Emergency Services, and April 16, 1998, from the City Solicitor be submitted to Council without recommendation.

 The Works and Utilities Committee further reports having:

 (1)referred the aforementioned reports and communications and the following motions to a special meeting of the Committee to be held on May 11, 1998, for the hearing of deputations:

 Moved by Councillor Bossons:

 AThat the report dated April 8, 1998, from the Commissioner of Works and Emergency Services be amended by:

 (i)striking out the words Awhere re-refining facilities are available@ in Recommendation No. (1) and inserting in lieu thereof the words Awhere access to re-refining services exists@;

 (ii)striking out Recommendation No. (2) and inserting in lieu thereof the following:

 A(2)the Minister of the Environment be requested to ban the use of waste oil burners in the urban area of Toronto, as already defined in Ministry of the Environment regulations which prohibit the sale of high sulphur gasoline;@ and

 (iii)adding thereto the following recommendations:

 A(6)the Commissioner of Works and Emergency Services and the City Solicitor be requested to prepare a draft by-law which would have the effect of banning the use of waste oil burners in the City of Toronto; and

 (7)if the City of Toronto takes the position that waste oil burners should be banned, it advise the members of the Association of Municipalities of Ontario and invite their support@; and

 Moved by Councillor Walker:

 AThat the Commissioner of Works and Emergency Services and the City Solicitor be requested to develop a draft by-law on the banning of space heaters, and that a public hearing take place at that time@;

 (2)requested that all interested parties be advised accordingly; and

 (3)invited the Medical Officer of Health to provide her comments in connection with the foregoing matter to the special meeting of the Committee scheduled to be held on May 11, 1998.

 The Works and Utilities Committee submits the following report (April 8, 1998) from the Commissioner of Works and Emergency Services:

 Purpose:

 The purpose of this report is to recommend against the burning of waste oil where re-refining is available and cost-competitive compared with virgin motor oil, and to emphasize that waste oil should be recycled safely and not discharged into the sanitary or storm sewer system or the ground water.

 Funding Sources, Financial Implications and Impact Statement:

 There are no direct funding implications of this report.

 Recommendations:

 It is recommended that:

 (1) the Minister of the Environment be requested to discontinue the issuance of air approvals for waste oil burners where re-refining facilities are available;

 (2)the Minister of the Environment be requested to consider placing a sunset regulation on existing air approvals for waste oil burners in urban areas;

 (3) communications to the public should continue to prevent the dumping of waste oil into sewers or the environment;

 (4) all City fleets adopt the use of re-refined oil that meets manufacturers warranty requirements, subject to availability and reasonable cost differential;

 (5) if the Minister does not discontinue the approval of waste oil burners permanently, the Province of Ontario be requested to give Municipalities the option to adopt by-laws that prohibit the use in their respective jurisdictions and that take precedence over approvals issued under the Environmental Protection Act, Section 9; and

 (6)if the Minister does not discontinue the air approval of waste oil burners permanently, the Province be requested through an appeal under the Environmental Bill of Rights to give municipalities standing in the review and setting of new more stringent air emission standards under Regulation 346.

 Council Reference/Background/History:

 The March 25, 1998 agenda for the Works and Utilities Committee included an item on the burning of waste oil requesting a staff report to:

 Aidentify options to ban or grandfather the operation of used oil furnaces within the City of Toronto; and identify options to increase the recovery of used motor oil and thereby divert it from burning in space heaters and from fouling the City of Toronto=s sewage treatment facilities.@

 Waste oil burners are subject to the Ontario Environmental Protection Act under two sections:

 Section 9 -Air Emissions and Regulation 346 which establishes point of impingement standards; and

 Section 27 -Waste Management and Regulation 347.

 Waste oil burners must have a certificate of approval under Section 9 - Air Emissions and comply with the standards in Regulation 346.

 Section 27 refers to the management of used oil as a waste. Waste oil burners are exempt from the requirement to obtain a certificate of approval under Section 27 if less than 10 tonnes is burned per day and if only oil generated on site is burned. Regardless of the exemption from obtaining a certificate of approval, waste oil burners must still meet the standards under Section 27, Regulation 347.

 The Ministry is undergoing a three-year review of all standards. The air standards for waste oil burners are due for a review. Municipalities have the option of requesting a review of the standards through the Environmental Bill of Rights.

 The Minister of the Environment has placed the issue of ASmall Used Oil Space Heaters@ on the Environmental Bill of Right Registry for public comment by May 31, 1998. To comment by that deadline, this item would have to be considered by City Council at its meeting on May 13, 14 and 15, 1998, and by Works and Utilities Committee on April 22, 1998.

 Comments and/or Discussion and/or Justification:

 Approximately 500 million litres of lubricants are sold in Ontario each year. Approximately half are lost in use. Between 1995 and 1996, the quantity of re-refined oil fell from approximately 87.5 million litres to approximately 68 million litres, and the quantity of waste oil burned increased from approximately 10 million litres to approximately 18 million litres.

 Approximately 75 million litres are unaccounted for. It has been estimated that one litre of oil can contaminate one million litres of ground water. Disposal of oil into sanitary sewers can interfere with the operation of wastewater treatment plants.

 There are 47 existing waste oil burner locations in the City of Toronto. Referring to census data distributed geographically in the City of Toronto, there are 32,469 Toronto citizens living within 250 metres of waste oil burners.

 The burning of waste oil releases the following contaminants to the atmosphere:

 -Sulphur Oxides;

-Nitrogen Oxides;

-Carbon Monoxide;

-Fine particulate;

-Carbon Dioxide;

-Volatile Organic Compounds;

-Arsenic;

-Chromium;

-Cobalt;

-Lead;

-Manganese;

-Nickel; and

-Zinc.

 Health Impacts:

 The Ontario Ministry of Health will be requested to comment on the waste oil burner issue. Staff of the City Medical Officer of Health have expressed concern about the potential health effects to populations in close proximity to existing waste oil burners in the City of Toronto. Fine particulate is invisible and enters deep into the lungs and can cause asthma and other respiratory ailments.

 Positions of Stakeholders:

 City of Toronto vehicle fleet operators return used motor oil for re-refining. Operators use either re-refined oil that meets manufacturers warranty requirements or virgin motor oil depending on low bid. Often re-refined oil has been less expensive than virgin motor oil. The amalgamated City of Toronto has significant purchasing power and will benefit from bulk purchasing of re-refined oil. Other fleets in Toronto, if not already doing so, should be encouraged to return used oil for re-refining and to use re-refined oil in their fleets. There is surplus capacity for re-refining in Ontario and therefore capacity is not an issue. On the contrary, supply of used oil is sometimes limited and restricts supply of re-refined oil. The number of waste oil burners is increasing and the supply of used oil for refining is falling. This trend should be reversed to improve air quality and reduce CO₂ emissions.

 The following organizations support a moratorium on the issuance of new approvals for Waste Derived Fuel (WDF) heaters in Ontario until the emissions of these heaters are fully studied and understood. In addition, these organizations recognize recycling as the preferred management option for used oil:

 -Canadian Automobile Association;

-Canadian Petroleum Products Institute;

-Canadian Re-Refiners Association;

-The Lung Association;

-Ontario Natural Gas Association;

-Pollution Probe; and

-Recycling Council of Ontario.

 The Canadian Petroleum Products Institute (CPPI) has written to the Minister of the Environment to state concern about the approval of waste oil burners by the Ministry of the Environment. The CPPI represents marketers of lubricants.

 The Recycling Council of Ontario (RCO) promotes the recycling of waste oil. The RCO advocates initiatives to prevent waste oil disposal in landfills.

 The Canadian Council of Ministers of the Environment published the ACode of Practice for Used Oil Management in Canada@, in 1989. The following provincial policies arose as a result.

 Summary of Provincial Policies:

 Generally the western provinces, where new virgin oil is produced, have been promoting the proper management of used engine oil. A table in the Appendix to this report summarizes provincial regulations across Canada.

 Sewer Use By-law:

 Toronto Sewer Use By-laws prohibit the discharge of engine oil into the sewer system for treatment at the City wastewater treatment plants. There is a low limit of 15 ppm of mineral or synthetic oil. Engine oil is well over 15 ppm. Dumping of engine oil into catch basins directs engine oil to the water courses and waterfront of the City. When notified, industrial waste control staff pump out catch basin sumps to remove engine oil.

 By-law Enforcement/Licensing:

 The City Solicitor has been requested to confirm that municipalities have the power to pass a by-law under the Municipal Act governing waste oil burners. However, Legal staff have advised that, if a by-law is not consistent with provincial legislation or regulation, the provincial requirement supersedes the municipal by-law. Specifically, if the Province approves a waste oil burner, the operation of the waste oil burner cannot be prevented by a municipal by-law. If the Minister continues the hold on new approvals indefinitely, then a municipal by-law would govern. Regarding future approvals, a City by-law prohibiting waste oil burners would be a clear policy statement to the Minister not to allow the approval of additional waste oil burners in the municipality. Regulation of vehicle maintenance facilities for emissions protects neighbouring residents by establishing emission standards.

 Public Communication:

 The public regularly receives a clear message not to dispose of waste oil in sanitary or storm sewers through City communications . For example, the newsletter AWater Watch@ has included articles on water quality every year. Samples of communications materials available to the public include the booklet ARecipes for a Cleaner Planet@, and advertisements that appear regularly in the daily newspapers. The public is invited to contact the Household Hazardous Waste Hotline at (416) 392-4330 to find out the location of the nearest depot accepting used oil and other household hazardous wastes.

 Smog Plan:

 The Province, in cooperation with business, industry, government and the public, has proposed a Smog Plan earlier this year. The Smog Plan consists of many component initiatives all of which when added up will significantly reduce smog in Ontario.

 The elimination of the burning of waste oil where re-refining facilities are available will contribute to the overall reduction of smog precursors including NOx and fine particulate. The Minister should be requested to include in his Smog Plan the elimination of waste oil burners where re-refining exists.

 There is the broader issue that each of the approximately 1.1 million vehicles registered to Toronto residents has varying investments in pollution control equipment depending on model year. Burning of used oil in waste oil burners releases to the atmosphere contaminants in the crankcase oil. Organizations representing vehicle dealerships and maintenance facilities are promoting the early implementation of mandatory vehicle emissions testing and maintenance. The same group of businesses should be encouraged to discontinue the use of waste oil burners.

 Climate Change:

 Councils have supported and promoted vehicle emissions testing and maintenance not only to reduce emissions that result in smog, but also to increase overall fleet fuel efficiency. Vehicle emissions testing and maintenance programs in other jurisdictions have realized overall fuel savings of approximately 10 percent. For individual vehicles, the savings has exceeded 61 percent. Less fuel burned means less emissions of CO₂. The burning of waste oil increases CO₂ emissions and negates the gains from tune-ups. The energy required to process oil from the ground is greater than to re-refine used engine oil. Use of re-refined engine oil reduces overall CO₂ emissions.

 Information Sources:

 Sources of information for the preparation of this report include the following organizations:

 -City Solicitor=s Department;

-Medical Officer of Health=s Department;

-Works and Emergency Services: Interim Lead Commissioner, Fleet Management;

-Interim Functional Lead, By-law Enforcement/Licensing;

-Works and Emergency Services: Communications, Waste Management and Water and Wastewater;

-Ministry of the Environment: Approvals Branch and Waste Reduction Branch;

-Ontario Environmental Bill of Rights Registry;

-Provincial Ministries of Environment in Canada;

-Ontario Smog Plan Steering Committee;

-Canadian Petroleum Products Institute;

-Safety Kleen Canada, Inc.;

-Recycling Council of Ontario;

-Canadian Institute for Environmental Law and Policy;

-Consultant: General Science Works Inc.; and

-Consultant: Paul H. Scrivener and Associates.

 Conclusions:

 Fleet managers specify re-refined engine oil for fleet vehicles subject to availability and cost. Fleet managers should return engine oil to be re-refined.

 There is a strong consensus in support of the proper management of used oil in provinces across Canada. The Minister of the Environment should be requested to make permanent the hold on issuance of approvals for new waste oil burners in areas where access to re-refining facilities is available. The Minister of the Environment should be requested to establish a sunset regulation for the existing approvals of waste oil burners after a suitable cost recovery period.

 Businesses offering vehicle maintenance services that promote use of re-refined oil should be showcased as leaders in the industry. Automobile manufacturers that ship new vehicles with re-refined oil in the crankcase should be showcased as leaders in the industry. Automobile manufacturers that discourage the use of waste oil burners in their dealerships should be showcased.

 The public should be informed that approximately 75 million litres of used engine oil is unaccounted for each year in Ontario, and that every effort should be made to direct used oil to re-refining.

 Contact Name:

 Kevin Loughborough, P. Eng. - Works and Emergency Services

Tel. No. (416) 392- 8845; Fax No. (416) 392-4540

         Appendix

 Provincial Regulations for the Management of Used Oil in Canada

  The Works and Utilities Committee also submits the following report (April 16, 1998) from the City Solicitor:

 Purpose:

 The purpose of this report is to provide information on the identification of options to ban or grandfather the operation of used oil furnaces within the City of Toronto for consideration by Committee in conjunction with the report dated April 8, 1998, from the Commissioner of Works and Emergency Services.

 Funding Sources, Financial Implications and Impact Statement:

 There are no funding implications of this report.

 Recommendation:

 That this report be received for information.

 Council Reference/Background/History:

 The March 25, 1998 agenda for the Works and Utilities Committee included a communication from Councillor Sgro on the burning of waste oil, and requested a staff report to:

 Aidentify options to ban or grandfather the operation of used oil furnaces within the City of Toronto; and identify options to increase the recovery of used motor oil and thereby divert it from burning in space heaters and from fouling the City of Toronto sewage treatment facilities.@

 The Committee will have before it a report, dated April 8, 1998, from the Commissioner of Works and Emergency Services on the matter. This report is intended to be considered in conjunction with that report.

 Comments and/or Discussion and/or Justification:

 The communication from Councillor Sgro is addressing waste oil heaters which are typically used by small businesses such as automobile service stations and car dealerships. The used oil taken from cars in oil changes is utilized as a fuel or fuel supplement in heating the premises of these operations. The concern relates to the toxins that exist in used oil.

 (a)Provincial Regulation of Oil Heaters:

 Businesses burning used oil in these heaters must have a certificate of approval (AC of A@) (air) for emissions under the Environmental Protection Act (AEPA@). The issuance of these C of As has been placed on hold and the Ministry of the Environment (AMOE@) is now consulting with the public on the environmental impacts of these heaters through the Environmental Bill of Rights Registry. Under the EPA, used motor fuel is considered a waste-derived fuel and a site where such fuel is utilized is defined as a waste derived fuel site. By the EPA, a waste derived fuel site is for the most part exempt from the need to have a C of A for a waste disposal or waste management site.

 (b)Possible Municipal Options:

 Three suggestions have been made about the City=s own ability to ban or grandfather the operation of the heaters. The options are:

 (1)the use of the Health Protection and Promotion Act;

 (2)the use of paragraph 156 of section 210 of the Municipal Act (Regulation of Heating Appliances); and

 (3)the use of the licensing provisions contained in the Municipal Act.

 (1)Health Protection and Promotion Act:

 This option exists but requires an order of the Medical Officer of Health on an individual basis.

 (2)Regulation of Heating Appliances:

 Paragraph 156 of section 210 of the Municipal Act provides for the power of a municipality to pass a by-law as follows:

 A156.For regulating, controlling and inspecting heating and cooking appliances, or any classes thereof, the installation thereof and the storage of fuel for use in connection therewith.

 158. For the purposes of any by-law passed under paragraph 156, for adopting by reference to the Ontario Regulations as amended from time to time the codes and standards or the parts thereof as adopted and changed by regulation under the Ontario Energy Board Act. R.S.O. 1980, c. 302, s. 210, para. 156".

 Under this option, a by-law could be passed regulating the use of waste oil heaters, as a class of heating appliance.

 (3)The Licensing Provisions of the Municipal Act:

 Section 257.2 of the Municipal Act provides for the general licensing powers of municipalities. By-laws may be passed for licensing, regulating and governing any business carried on within the City. "Business" does not include a manufacturing activity or an industry except to the extent that it sells its products or raw material by retail; nor does it include the selling of goods by wholesale. Classes of businesses may be defined with separate licensing and regulation of each class. The suggestion being made is that the conditions of licensing can be wide-ranging and, in particular, may relate to the regulation of equipment and other personal property used in the business. Public garages and automobile service stations are currently licensed under the City=s Licensing By-law.

 (c)Conflict with Provincial Approvals:

 The problem that will exist if either Option (2) or (3) is utlilized, relates to the issue of conflict as enunciated by two Ontario Court of Appeal cases - Superior Propane Inc. and Propane Gas Association v. Corporation of the City of York and Re. Attorney-General for Ontario et al. and City of Mississauga. There may well be conflict in that the purpose of any proposed by-law appears to be the prohibition of the burning of waste-derived fuel. Section 9 of the EPA states as follows:

 A9. (1)No person shall, except under and in accordance with a certificate of approval issued by the Director,

 (a) construct, alter, extend or replace any plant, structure, equipment, apparatus, mechanism or thing that may discharge or from which may be discharged a contaminant into any part of the natural environment other than water; or

 (b)alter a process or rate of production with the result that a contaminant may be discharged into any part of the natural environment other than water or the rate or manner of discharge of a contaminant into any part of the natural environment other than water may be altered.@

 In short, the issue appears to fall squarely within the Mississauga case where the court held there was a conflict between the predecessor of section 9 and a Mississauga by-law banning the burning of PCBs. The Mississauga by-law was based on explicit statutory authority under the Municipal Act (now paragraph 134 of section 210) which provided for by-laws to be passed as follows:

 AFor regulating manufactures and trades that in the opinion of the council may prove to be or may cause nuisances of any kind, and, without restricting the generality of the foregoing, for prohibiting or regulating the erection or continuance of gas works, tanneries or distilleries or other manufactories or trades that, in the opinion of the council, may prove to be or may cause nuisances.@

 Mr. Justice Morden of the Court, in holding the Mississauga by-law to be invalid, stated:

 AIn a case where no certificate of approval is issued the two laws practically duplicate each other and there is no room for municipal regulation. Where a certificate had been issued then, it appears to me, the absolute prohibition in the by-law clashes with the legislative scheme embodied in the statute and the proper implementation of this scheme. The two pieces of legislation, in this regard, are at cross purposes. They are repugnant to each other. They both are intended to protect the environment and it cannot reasonably be thought that the issuance of a certificate of approval involves any diminishment of this policy.@

 This statement was also referred to in Superior Propane in holding that a City of York land use by-law restricting and regulating propane storage and dispensing facilities was at cross purposes with regulations under the Energy Act. The Court also held that the by-law was improper, having as its basic and predominant purpose the advancement of safety concerns respecting the handling of propane and not land use planning. The Court also felt there was no reasonable basis for the argument that the by-law merely enhanced a law.

 All of the above principles on conflict enunciated by the Court of Appeal would likely be brought to bear in attacks on either a by-law under paragraph 156 of section 210 (option 2) or section 257.2 (option 3) of the Municipal Act. The fact that there is at present a moratorium on the issuance of new approvals for these facilities does not legally alleviate the conflict on the basis of the principles set forth in the above cases.

 The new Draft Municipal Act (hereinafter referred to as the ADraft Act@) has been released for public consultation. While the Draft Act would confer on municipalities the capacity, rights and powers of a natural person for the purpose of exercising its authority under any Act, there are statutory restrictions surrounding the mandates that are granted. In particular, a by-law would be without effect to the extent of any conflict with a provincial Act, or a regulation or enactment (e.g., approval or permit) made under such an Act. If a matter is subject to Provincial regulation, a by-law (including licensing conditions) would be without effect to the extent that it prohibits or regulates the matter in substantially the same way, or in a more restrictive way, than the Provincial regulation. The provisions of the Draft Act, then, may be considered to be a codification of the principles in the Superior Propane case and perhaps more restrictive.

Subject to the above, option (2) may be preferable to option (3) based on the reasoning that option (2) provides specific authority to regulate any class of heating appliances; an argument could at least be made that it is the equipment which is being regulated not the burning. A regulation would have to prohibit any heating equipment which utilizes used oil. The use of licensing as a regulatory mechanism may be more problematic given the competing interests of section 9 of the EPA and the generality of the licensing provisions.

 One other option that bears mentioning surrounds the utilization of land use regulations under the Planning Act. In 1996, the former City of Toronto enacted an Aanti-incineration@ land use by-law prohibiting incineration of waste within the City of Toronto (it also enacted other Municipal Code by-laws on the basis of its private legislation). Under the by-law, Awaste@ includes waste-derived fuel. The by-law was appealed by a number of persons, including The Municipality of Metropolitan Toronto. The by-law remains in abeyance before the Ontario Municipal Board.

 While the principle of conflict remains an issue in relation to land use regulation (particularly as the Superior Propane case dealt with a York land use regulation), there may be an option of examining the expansion of the by-law, if enacted, as part of the policy review relating to the whole issue of incineration. The advantage of the utilization of the Planning Act is in the fact that it has its own paramountcy clause.

 Conclusions:

 Any regulatory option by the City of Toronto to prohibit the burning of waste oil in space heaters is likely invalid on the basis of conflict with regulatory approvals under the Environmental Protection Act as enunciated in the Superior Propane Inc. and Propane Gas Association v. Corporation of the City of York and Re. Attorney-General for Ontario et al. and City of Mississauga cases. The principle of conflict as enunciated by the Superior Propane case, in particular, would apply notwithstanding the present moratorium on certificates of approvals (air) for the burning of waste oil. The Draft Act expressly incorporates the principle of conflict.

 Contact Name:

 J. Anderson, Senior Solicitor, 392-8059

 The Works and Utilities Committee also submits the following communication (February 19, 1998) from Councillor Judy Sgro, North York Humber:

 Please find attached several recent articles and documents pertaining to the management of used oil. Please note the rather disturbing comments made by the Minister of the Environment in the February 18th issue of The Record regarding this issue.

 A recent report by the Canadian Institute of Environmental Law and Policy identified the pollution from uncontrolled burning of used oil as a major hazardous waste issue. There are 42 used oil furnaces operating in garages and other automotive facilities within the City of Toronto=s boundaries (see the December 3, 1997 NOW magazine article attached).

The City of Toronto has a progressive policy of requiring the use of re-refined motor oil in its vehicles. Collection and re-refining diverts used oil from sewers and from becoming an air pollutant once burned in space heaters. An environmental group has given me some recent articles and technical papers on the subject and I would suggest that staff undertake the following analyses:

 -identify options to ban or grandfataher the operation of used oil furnaces within the City of Toronto; and

 -identify options to increase the recovery of used motor oil and thereby divert it from burning in space heaters and from fouling the City of Toronto=s sewage treatment facilities.

 I hope the attached information is useful.

 The Works and Utilities Committee reports, for the information of Council, having also had before it during consideration of the foregoing matter the following communications, a copy of which has been forwarded to all Members of Council, and a copy of which is on file in the office of the City Clerk:

 (i)(March 23, 1998) from Mr. John Hanson, Executive Director, Recycling Council of Ontario, expressing support for a proposed Toronto by-law to address the issue of waste-derived fuel furnaces, and for re-refining as the preferred option for dealing with oil; and requesting the opportunity to make a deputation when the Committee discusses this issue;

 (ii)(March 20, 1998) from Mr. Ken Ogilvie, Executive Director, Pollution Probe, advising that Pollution Probe is a very strong advocate for improving air quality and encouraging governments at all levels to take actions that support this objective; and requesting the opportunity to make a deputation to the Committee regarding the burning of used oil in Toronto;

 (iii)(March 23, 1998) from Mr. Gord Perks, Toronto Environmental Alliance, recommending that the Committee direct staff to develop options for the banning of burning of used motor oil, and direct the Medical Officer of Health to report on the health and environmental consequences of burning used oil in Toronto;

 (iv)(March 23, 1998) from Mr. Ian C. Morton, Community Service Project Manager, Ontario Provincial Office, The Lung Association, in support of banning the sale of new waste derived fuel furnaces and to grandfather existing ones; and encouraging the Committee to urge the Ministry of the Environment to establish a mandatory used oil collection program, where feasible, to replace the voluntary approach currently in place;

 (v)(March 25, 1998) from Mr. Usman A. Valiante, General Science Works Inc., submitting maps showing the location of used-oil furnaces within the City of Toronto and population statistics;

 (vi)(April 20, 1998) from Mr. T. R. Clapp, Vice President, Ontario Division, Canadian Petroleum Products Institute, requesting the opportunity to appear before the Committee with respect to the issue of the burning of used oil; and advising that the Canadian Petroleum Products Institute supports recycling as the best practice for managing used oil, and endorses the current provincial ban on permitting new used oil fired space heaters; and

 (vii)(April 21, 1998) from Mr. David Leonhardt, Director, Public and Government Relations, Canadian Automobile Association (Ontario), requesting the opportunity to appear before the Committee, and advising that CAA Ontario is opposed to the burning of used lubricating oil whenever another viable option is available.

 The following persons appeared before the Works and Utilities Committee in connection with the foregoing matter:

 -Ms. Zivah Stocker, North York, Ontario, and filed a submission with respect thereto;

-Mr. John Hanson, Executive Director, Recycling Council of Ontario, and filed a submission with respect thereto;

-Mr. Ian C. Morton, Director, Environmental Health, Pollution Probe, and filed a submission with respect thereto;

-Mr. Usman A. Valiante, General Science Works Inc.;

-Mr. T. R. Clapp, Vice-President, Ontario Division, Canadian Petroleum Products Institute, and filed a submission with respect thereto;

-Mr. David Leonhardt, Director, Public and Government Relations, Canadian Automobile Association;

-Mr. Ron Lugowski, De-On Supply Incorporated;

Mr. Doug Barnett, Reznor/Garage Supply Ltd.;

-Mr. Lloyd Clare, Environmental Permit Corporation;

-Ms. Melissa Brookfield, Ontario Provincial Office, The Lung Association;

-Councillor Judy Sgro, North York Humber, and submitted a press kit from Pollution Probe, The Lung Association, Recycling Council of Ontario, Toronto Environmental Alliance and CAA Ontario, and a list provided by the Ministry of the Environment indicating locations of waste oil furnaces; and

-Councillor Joan King, Seneca Heights.

 (A copy of the attachments to the foregoing communication from Councillor Sgro has been forwarded to all Members of Council with the agenda for the Works and Utilities Committee meeting of March 25, 1998, and a copy thereof is on file in the office of the City Clerk.)