Enbridge Gas (Enbridge)…

Enbridge Gas (Enbridge) welcomes the opportunity to comment and provide feedback on the Emissions Performance Standards (EPS) program regulatory amendments for the 2023-2030 period. Climate change requires serious solutions, and Enbridge wants to be a part of those solutions. Across our business, we have committed to achieving net-zero greenhouse gas (GHG) emissions by 2050, with an interim target to reduce the emissions intensity of our operations by 35% by 2030.

Below is a list of recommendations for EPS program regulatory amendments for the 2023-2030 period

• A declining stringency factor and an escalating carbon price are duplicative and too onerous
• The proposed changes to the electricity generation and cogeneration performance standard may be challenging while maintaining energy reliability
• Ensure that the regulations and quantification guidelines recognize the GHG reductions of combusting low carbon fuels, such as renewable natural gas (RNG) and hydrogen, whether used on their own or blended into the natural gas pipeline
• Recognize book and claim reporting of RNG and hydrogen, and that there are zero GHG emissions from combusting hydrogen
• Review the EPS policy every two to three years throughout the 2023-2030 period
• Engage the industry throughout each EPS policy review process as it can provide practical expertise and knowledge to help inform policy updates
• Recognize carbon capture and utilization (CCU) under the EPS as a viable means of reducing GHG emissions at a covered facility
• Link the EPS with other provincial and territorial programs and recognize credits generated under eligible systems for compliance under the EPS
• Leverage the lessons learned from existing Canadian registries, including the Federal Credit and Tracking System (CATS) when developing the EPS compliance unit registry
• Include offsets as a compliance option under the EPS either by adopting offsets into the EPS from existing systems and market programs or developing an Ontario offset program by leveraging the lessons learned from other Canadian carbon pricing programs and the federal OBPS
• Consider creating a carbon capture protocol with the development or adoption of an offset program
• Recycle proceeds back to industrial facilities regulated under the EPS and provide transparency around how the EPS proceeds are spent