To Whom it May Concern,
I represent a hospital system in Etobicoke, and we are strongly in favour of removing third-party verification requirements for voluntary participants as defined in O. Reg. 390/18, as proposed in the EBR posting 013-4595 - Streamlining and updating of greenhouse gas reporting requirements.
As a voluntary participant under O. Reg 390/8, third-party verification drives cost and administrative burdens for our organization which could be diverted to patient care. Given that the cap and trade program is no longer in effect, there is no compliance or regulatory requirement driving the need for emissions verification. Other emissions reporting programs, specifically O. Reg. 507/18, requires no verification requirements.
We are also in favour of harmonizing Ontario reporting requirements with the federal Greenhouse Gas Reporting Program in order to further decrease the administrative burden associated with tracking separate quantification methods for the purpose of reporting emissions.
Thank you for your consideration.
Submitted March 1, 2019 10:17 AM