Comment
The proposed change as written states all 2025 cancelations take effect on March 31st / April 1st 2025 taking into consideration only 3months of production data.
The next opportunity to withdraw from the EPS program using a full year of data would be December 31st 2026.
Given that verification would still need to be completed for January – March 31st 2025, these are the peak heating months of the year. It is expected that for most manufacturers this period of the year would be the poorest performing quarter of the year for measuring Carbon emissions per unit manufactured. It is likely that some facilities require the remainder of the year to bring down the Carbon emissions per unit, ideally under the yearly TAEL target. I suggest that an option be ADDED to voluntarily exit the EPS program with a target end date of December 31st, 2025.
Good day,
Scott Kuehl
Business Development / Product Manager
200 McNab Street
Arnprior, Ontario, K7S 3P2
(613)875-4845
scott.kuehl@nylene.com
Submitted July 2, 2025 3:13 PM
Comment on
Expanding criteria for Voluntary Participants to exit the Emissions Performance Standards (EPS) program
ERO number
025-0394
Comment ID
150674
Commenting on behalf of
Comment status