I am a representative of an…

I am a representative of an Ontario-based producer of rock salt. Several of our staff and advisors have thoroughly reviewed the “Making polluters accountable: Industrial Emission Performance Standards” proposal, posted for public comment on February 12, 2019.

On behalf of the company, I am providing the following comments :

• Regarding section 2.1 and Appendix B to the proposal, we support the inclusion of salt production and mining in the list of sectors eligible for participation in the EPS program. This sector is both emissions intensive and trade exposed.

• Regarding section 2.3 of the proposal, we support Ontario establishing an emissions threshold of 50,000 tonnes/year of CO2e for mandatory participation in the EPS program. We also support Ontario establishing an emissions threshold of 10,000 tonnes/year of CO2e for voluntary participation.

Establishing thresholds that are consistent with those already in use at the federal level would make it far easier for companies such as ours to understand and continue to implement any applicable compliance obligations. Furthermore, keeping the availability of voluntary participation as wide as possible, provides greater flexibility for facilities to select the most appropriate approach to greenhouse gas management and carbon pricing.

• Ontario should establish an exemption to the EPS program for any facility that is registered and participating in the federal OBPS. Such an exemption would eliminate the risk of regulatory duplication, reduce compliance costs, and provide flexibility for facilities to select the most appropriate approach.

We sincerely hope you take the above comments into consideration in finalizing the EPS program.