We understand the importance…

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013-3738

Comment ID

10000

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We understand the importance of participating in environmental reports, however we feel they must be fully relevant to the business size and purchases accordingly. Being a small motorsports business, not only was the ON Greenhouse Gas Report not relevant to our purchase of race fuel, most persons we spoke at the Cap and Trade program could not answer our questions how to proceed with the report, since much of it did not pertain to our company. The reporting became complicated and time consuming. Most importantly, the cost for a mandatory verifier to visit our place of business to look at one invoice and confirm the emissions were calculated correctly at a fee of $4,000 - $8,000 is unrealistic. Our purchase of 4000 litres of race fuel cost $10,500 US, yet the verification fee for the ON Greenhouse Report was quoted at $4,000-$8,000! Also, the report requires manual calculations by the reporter which we feel should be set up to complete the calculations automatically to avoid human error. With our technology today this should be easily done. Also, as for all government reports they should be subject to audit. These two changes could omit the required verifier and their fee… for at least the small businesses with few purchase orders/invoices. Another fact that should be considered pertaining to small businesses reporting… we understand there is a margin allowance for error permitted based on what a company actually reports and the difference in the calculation the verifier calculates. It is possible the emissions calculation for our 4000 litres of race fuel is less than the margin allowance for many larger companies reporting.
We really need the verification requirement for the 2017 report for small businesses waived. Also, we truly hope reasonable adjustments are being made accordingly to accommodate the small businesses that import fuel for coming years.
Thank you for your time.