Ontario’s Universities have…

Ontario’s Universities have a track record of early action and commitment to climate action. The sector is not able to pass on these increased costs to customers (students). Therefore, increasing their operational cost burden takes away from their ability to deliver their core services and to operate and implement GHG reduction projects independently. Ontario universities face competitiveness risks as they compete provincially, nationally, and globally to attract and retain students, researchers, and professors at the institution and in the province. Therefore, providing the sector opportunities to participate is crucial.

The Ontario Association of Physical Plant Administrators (OAPPA) requests that the MECP consider the following when developing a solution that will allow universities to continue to be financially stable and provide a benefit to their communities while contributing to provincial climate action goals.

1. Allow publicly funded organizations providing public services to remain internationally competitive and allocate funds to core educational services by allowing all universities the option to participate in the EPS program.

2. Consideration for the Historical Method (Method F: Historical Facility Emissions Limit Standard) as an applicable performance standard for the sector. This standard would accurately depict campus operations and incentivize emission reductions. This standard would assess universities based on their individual past emissions performance and recognize and reward the emission reductions achieved through the various projects and initiatives implemented on campus. To fully recognize and credit these emission reductions, OAPPA, therefore, requests for the MECP to consider increasing the limit for the issuance of Emissions Performance Units beyond the 5% of verified emissions for the university sector.

4. Allowing universities to choose between Method F: Historical Facility Emissions Limit Standard, Method B: Electricity Generation Sector Performance Standard, or Method D: Cogeneration Performance Standard. This flexibility is important for the sector as it provides universities the ability to choose the standard that provides the lowest costs and credit generating opportunities. This will further support the universities in remaining internationally competitive.

3. A portion of the revenue generated by the EPS to be allocated to Universities for energy efficiency and GHG reduction projects. The Universities have proactively identified a range of carbon reduction projects that could be supported.

OAPPA appreciates the opportunity to submit these comments for consideration and looks forward to furthering communication with the MECP on the participation of the sector in the EPS program.