I believe the program should…

I recommend that the program revisit its current guidelines and estimation factors. Specifically, it would be beneficial to differentiate between high-emitting and lower-emitting facilities, and to adjust emission factors to better reflect the efforts of voluntary low emitters. Reducing these factors could support lower emitters in achieving their targets and earning EPUs, rather than being penalized with EEUs.

This adjustment is especially important given the removal of the carbon tax from the program. Providing more favorable conditions for proactive participants could encourage continued engagement in the EPS program and reduce the incentive for companies to opt out.

Thank you