1. It looks like the September 1 verification remains in place. Is it anticipated that facilities reporting to OBPS will need to verify under both the Federal and Provincial Regulations? If so, how is this reducing unnecessary costs and regulatory burden for reporters?
2. We note that it is proposed for the Director to have the ability to require a revised GHG report and verification if the Director feels that the Accredited Verification Body (AVB) that has verified the GHG report has a potential threat to the AVB’s impartiality. Would that be the case even when a mitigation plan has been submitted to the MECP and the Director has provided consent to a mitigation plan? If so, then there's a significant risk to the AVB, why would the potential threat be evaluated at the start of an engagement and rejected at that time if the risk is deemed to be unacceptable by the Director?
Submitted November 25, 2019 9:20 PM