Q1. How can the EPS be designed to optimize GHG emission reductions while minimizing carbon leakage?
Impose tariffs on products entering from United States that would be subject under the EPS. Carbon leakage should be reduced now that all Canadian jurisdictions are subject to carbon pricing. However Ontario is particularly at risk due to its proximity to the US to have products entering the province that contribute to greenhouse gas emissions but are not subject to the carbon pricing.
Q2. What compliance options should industrial facilities have under the program (e.g. use of compliance units for payments for excess emissions that go into a fund that could be used to support greenhouse gas emissions projects in industry, voluntary emission reductions or removals or overachieving the EPS, other)?
We support payments being placed in to a specific fund to support emission reductions for industry. Offset carbon credits should also be a compliance option but projects should be within Canada for the sake of reliability and accountability. Funding for these offset projects would also assist in growing the green economy in the province and county.
Q3. If facilities receive compliance units for GHG emission reductions beyond the standard for the facility, should they be eligible to trade or bank them indefinitely?
Industries should be able to bank them indefinitely. Particularly since a single emissions reduction project may take years of planning, approvals and investment.
Q4. Which industrial facilities should be covered by the program (e.g. industrial facilities with GHG emissions greater than 10,000 or 25,000 or 50,000 tonnes CO2e per year)?
50,000 tonnes. Primarily to ensure funding is efficiently applied for emission reduction using the pareto principle where the largest quantities of emissions will be emitted by a small number of industries in Ontario. Only allowing industries that emit more than 50,000 tonnes would ensure that emissions reduction funding is provided to large organizations, with expertise, private funding backing and international recognition. These large organization will have a higher emission intensity so more reduction projects will reduce the overall emissions in the province. Larger funding would also encourage significant, long term and highly innovative projects.
Q5. Should Ontario harmonize with the federal reporting under the federal Production Order (which sets out reporting and verification requirements) and the federal OBPS (output based pricing system) (e.g., methods, threshold, verification)?
All efforts should be made to reduce redundancies and harmonize with the OBPS to reduce administrative burdens.
Q6. Should different stringency factors apply to fixed process and non-fixed process emissions?
Yes, different stringency factors should be applied to different types of emissions. Particularly since there are minimal options for feed stock change for fixed process emissions. Efforts should be to focus on reducing high priority emissions that easier and less expensive to mitigate such as those being emitted from combustion etc.. It is more costly and challenging to reduce process emissions, since it involves specific process changes, feedstock substitution and significant capital investment.
Submitted March 8, 2019 8:50 AM