Dear Melissa, The…

Dear Melissa,
The Atmospheric Fund (TAF) appreciates the opportunity to provide feedback on the proposed
regulatory amendments to the Emissions Performance Standards (EPS) program. TAF is a regional
climate agency based in the Greater Toronto Hamilton Area (GTHA) supporting a net zero future.
In relation to electricity generation using fossil fuels, we support the proposal to strengthen this
performance standard from 370 tCO2e/GWh to 310 tCO2e/GWh. Regular reductions in the fossil
fuel electricity generation standard are essential to the province aligning with the compliance
obligations and stringency requirements of the federal OBPS.
However, we recommend that a stringency factor be applied to this performance standard, with
regularly scheduled updates to regularly increase the stringency and lower the tCO2e. This will
ensure that Ontario is on track to phase out all conventional fossil fuel electricity generation, in line with
the expected Canada-wide Clean Electricity Standard (CES), and will provide more certainty for energy
planning and procurement in Ontario.
Additionally, we echo the recommendation of the OEB’s Market Surveillance Panel that “the IESO
should immediately cease reimbursements to gas generators of carbon cost payments.” The
current practice dilutes the price signal sent by the performance standard and undermines efforts to
reduce emissions by weakening the incentive to invest in more clean energy infrastructure.
Currently, published data collected through Ontario’s Greenhouse Gas Reporting Program (GHGRP) is
limited to total emissions, by greenhouse gas and converted to carbon dioxide equivalent, for each
facility. This dataset does not disaggregate these emissions by quantification method (QM), emission
type (process or combustion), or fuel type. This makes accounting for these emissions in municipal and
regional inventories challenging, especially given potential issues around double counting from natural
gas combustion which are present in both utility data and the GHGRP dataset. Additionally, and more
importantly, without specific details on the source of those emissions, we are unable to identify and
accurately quantify potential pathways to economy-wide decarbonization.
We recognize the sensitivities and challenges associated with publishing disaggregate data at the
facility level. We ask that the MOECP publish a secondary data set, consisting of total emissions
by emission type (process or combustion) and fuel type (e.g. natural gas, gasoline, etc.), for
each sector. This approach would guard against potential sensitivities associated with facility-level
data while providing municipalities and other practitioners the ability to more accurately account and
plan for climate change mitigation efforts.
We strongly urge Ontario to include our recommendations when amending the EPS program.
Sincerely,
Bryan Purcell
VP of Policy & Programs
The Atmospheric Fund