Dear Sir/Madam: Re: …

Dear Sir/Madam:

Re: Industrial Emission Performance Standards (EPS) - Proposal: Comments for Discussion and Consideration

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 proposal - posted on February 12, 2019 ERO #013-4551:

 Propose EPS Program registration and compliance tracking be managed through the Ontario
GHG Single Windows platform for both Mandatory and Voluntary facilities.

 Enable information/data transfer between the Emissions Reporting and EPS Program portals in SWIM.

 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.

 The requirement for opt-in facilities to have a minimum emissions level of 10,000 tonnes of CO2e poses the risk of incenting facilities falling below this threshold to increase their emissions in the short term. A facility can increase its emissions either by increasing its production, or in a much less desirable scenario, increasing its emissions intensity.

 Compliance options - Offset development should be expanded to adopt all provincial and international protocols and establish processes for developing new options.

 EPS - Greenhouse Sector: In support of Energy Use Intensity Method approach - more feasible than product based for this sector.

 Recommend that clear guidelines and process be communicated for OBPS facilities transferring over to the EPS Program.

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