Please be advised of the…

Please be advised of the following comments:
- Section 10.3: Please allow for a Sector to be defined as a NAICS code or sub-division of a 5 digit NAICS Code. Example: NAICS Code 332810 consists of Coating, Engraving, Cold and Heat Treating and Allied activities. A sub-division would be simply "Heat Treating" There is no natural NAICS code in Canada that is exclusive to "Heat Treating". With respect to the Ont. Regulation 241/19, it is proposed that within Schedule 2 "Industrial Activities" that a new Section "40." be added to reflect "Sub-divided" NAICS Codes.
- Section 8.5: It is proposed that the Director have authority to approve the addition of a New Sector without issuance of a new regulation. If this is not possible, then through the current proposed amendments, allow for conditional approval by the Director of a New Facility and any associated Facilities subject to issuance of an updated regulation. Furthermore, include a provision for adjustment to carbon tax paid by a New Sector associated Facility retroactive to the date such New Sector associated Facility were conditionally approved by the Director. The adjustment amount would reconcile the difference between carbon tax actually paid, and carbon tax owed under EPS. The adjustment period would be the period between the Director approval of a New Sector associated Facility and the effective date of the updated regulation.
- Section 4.1 and 10.3: In addition to the existing references to "Professional Engineer" please include a reference to "Certified Engineering Technologist C.E.T.)
- Section 5.1: Replacement of the Energy-Based Methods" should be effective for the 2022 compliance period.
- The EPS Program should not consider a more stringent performance standard for the electricity sector for the 2023 to 2030 period. Initiatives by the Provincial Government through a Directive to the IESO to develop a strategy for eliminating Natural Gas Generation will be far more effective in reducing emissions without adding incremental costs to the price of electricity for consumers.