Ivaco Rolling Mills supports…

Ivaco Rolling Mills supports the Ontario government’s decision to cancel the cap and trade program. We are a regulated facility and capped participant under the Climate Change Mitigation and Low-carbon Economy Act, 2016. We participated in the auction process as a regulatory compliance requirement and we acted in good faith by doing so. We incurred significant costs to purchase allowances and our auction strategy was to purchase sufficient allowances, each auction, for coverage of our compliance requirements. We herein submit our comments on the proposal to cancel this Act.

The proposal does not provide equitable treatment to the regulated community in Ontario. As a capped participant, participation in the auction process and purchasing of allowances was considered necessary and mandatory to fulfill our compliance requirements at the end of the compliance period. We upgraded our facility in 2012-2014 with state of the art technology and we do not expect to be able to significantly improve our emission intensity in the near future. We were therefore required to purchase allowances to meet our compliance requirements.

The costs incurred for the purchase of emission allowances in the auctions should be reimbursed to us, as a capped participant. We wish to reinvest these funds into our facility which may include projects for the reduction of carbon emissions, where feasible. If the funds are not returned, they would be an unfair tax which is not applied to our competitors in Canada and the United States. Our business is already at a disadvantage due to the steel tariff imposed by the United States in July 2018. This further increases uncertainty for investing in improvements at our site.

Please reconsider the approach proposed in Bill 4 to support investment in Ontario and create jobs opportunities.

regards,
Ivaco Rolling Mills - A Heico Company