Dear Sir/Madam: Re: …

Dear Sir/Madam:

Re: Streamlining and Updating of Greenhouse Gas Reporting Requirements - Regulatory Proposal: Comments for Discussion and Consideration

Thank you for considering these comments, submitted to the Ministry of the Environment, Conservation and Parks consultation on behalf of Sundara Energy (Sundara), consultant working with a diverse group of industrial and agricultural clients across Canada. Sundara provides services to customers covering energy and facility efficiency projects, including carbon emissions reporting and program management.

Sundara is putting forward the following comments and recommendations for consideration with regards to the Updating of Greenhouse Gas Reporting Requirements regulatory proposal - posted on February 6, 2019 ERO #013-4595:

1. Support of the regulatory removal of the Third-Party Verification requirement for the opt-in
Voluntary Participants under the cancelled Cap and Trade Program O. Reg. 390/18. These costs
are an unnecessary burden on facilities who by submitting their annual emissions through the
Single Windows reporting platform captures the necessary data required to support the
proposed EPS Program development.

2. Support the alignment of the Federal (GHGRP) and Ontario reporting requirements and
streamlining duplication.

3. Propose a revision of the definition of "Facility" - to consider including off-site buildings under
same ownership.

4. Emissions quantification and reporting requirements for facilities emitting less than 10k CO2e

Propose that all facilities should be required to quantify and record their emissions establishing
their baseline - a starting factor when considering efficiency projects and
strategic investment decisions. Knowledge is the basis for smarter decision making.

I personally want to thank the MECP team for your on-going collaboration and communication as these regulations are considered and finalized.
Look forward to participating on future consultations.

Sincerely,

Stephanie Freund
President

Sundara Energy Inc.
P.O. Box 20077
Burlington, Ontario L7P 0A4
t. 905.741.7505
f. 289.816.1457
Stephanie.freund@sundaraenergy.com
Sundaraenergy.com