Albeit at times hard to…

Albeit at times hard to differentiate fundamentally with the previously in place Cap-and-Trade system, this new proposal has merits.

Important things to focus on in my opinion:

1) Instead of fighting the constitutionality of GGPPA (could be an ironic argument and predictable outcome due to previous actions taken by the provincial government at municipal levels).

I'd recommend tweaking this program to come into line at a minimum with the GGPPA's requirements. Allowing Ontario to control it's own program, without the federal government implementing a backstop for provincial policy gaps is ideal.

2) Compliance payment funded reduction initiatives. This is an area that I'd like to see monitored closely, ensuring that the funds are spent efficiently for the intended purposes.

I could foresee a situation where a larger emitter pays for these compliance units, either they or another company in industry is given funds to invest in reducing their carbon emissions and ends up squandering the money elsewhere in their organization. It's important to keep this money's effectiveness accountable.

3) Methane is something that should probably be tackled under this program. Considering its global warming potential is 25 times that of CO2. Methane is not mentioned in the proposal.

4) 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)?

How much toxic, green-house causing emissions is okay? None. So definitely apply this to all facilities.

Hope these comments will be taken into consideration when finalizing this legislation and doing what's right for our environment, our industries, and our future.