With regards to the…

With regards to the standards for new facilities.
I do not agree with the 10,000 te CO2e threshold. I recognize that the government is targeting 'large polluters'. But as a person working with SMEs (and scaling them up to be large), I strongly believe SMEs should pull their weight as well. The threshold should be lowered to 5,000 te or even 3,000 te. The increase in admin from additional company submissions will be offset by the other admin changes the government is proposing, e.g., increase in variance to 5%.

I also do not agree with the 3 year period before compliance takes affect. I would suggest a phased in approach. For example, year 1 requires reporting (which often has errors and omissions), year 2 is some partial level of compliance, and year 3 is full compliance.

Thank you for your consideration.