Dear Sir/Madam: Re: Proposed…

Dear Sir/Madam:

Re: Proposed Amendments - Transition Ontario Industrial Facilities from the Federal OPBP to Ontario's EPS Program

Thank you for considering these comments, submitted to the Ministry of the Environment, Conservation and Parks consultation on behalf of Sundara Energy (Sundara), consultant working with a diverse group of industrial and agricultural clients across Canada. Sundara provides services to customers covering energy and facility efficiency projects, including carbon emissions reporting and program management.

Sundara is putting forward the following comments and recommendations for consideration with regards to the Industrial Emission Performance Standards regulatory amendment proposal - posted on December 16, 2020 ERO #019-2813:

 Propose that a facility emitting over 10,000 tonnes of Co2e not covered under a listed or proposed industry code in Schedule 2 be permitted to submit a business case considering outside factors for eligibility to participate in the Program. We have seen many businesses deemed essential services who wish to be considered part of the program where industry benchmarks will set the standards and be beneficial to their businesses. Under the current OPBS regulations, cases are considered on a case-by-case basis but a service industry facility is ineligible due to the industry code and they currently have no other options of mitigating risk and face plant closures. EPS regs perhaps could include facilities faced with "exceptions" if supported by strong evidence.

 Propose that any facility under 10,000 tonnes of CO2e should be eligible to voluntarily opt-in if it competes directly against a facility regulated under the EPS - evaluated based on similar leakage risk assessment methodology.

 EPS - Greenhouse Sector: In support of Energy Use Intensity Method approach - we encourage continued consultation to include this sector as benchmarks standard to hold accountability will drive innovation in this industry. The current CRA partial exemption is not an incentive to find sustainable alternatives to cut emissions. The Alberta TIER Program has recently opened up this sector as voluntary participants.

I personally want to thank the MECP team for your on-going collaboration and communication as these regulations are considered and finalized.
Look forward to participating on future consultations.

Sincerely,

Stephanie Freund
President

Sundara Energy Inc.
P.O. Box 20077
Burlington, Ontario L7P 0A4
t. 905.741.7505
f. 289.816.1457
Stephanie.freund@sundaraenergy.com
Sundaraenergy.com