Air Products appreciates the…

Air Products appreciates the opportunity to provide input to the Ministry of the Environment, Conservation and Parks (MECP) in response to the proposed EPS amendment bulletin (ERO number 019-7649). We are supportive of Ontario’s climate ambitions and programs like the EPS are important to achieving those goals. Because of the importance hydrogen will play in the energy transition, we want to ensure regulations recognize its emission advantages and promote its use wherever possible.

Air Products has the following recommendations and comments in response to the proposed amendments.

Clarifying Applicability of Emission Limits for Cogeneration Facilities
Air Products stresses the importance of any amendments to the methodologies to determine the emission limit for industrial cogeneration facilities (i.e. co-production of thermal energy coincident with hydrogen production) operating within or directly serving petroleum refiners ensuring consistent treatment, and that the same eligibility requirements should apply to both a refinery and an independent hydrogen producer.

Expanding eligibility for Renewable Natural Gas (RNG)
Air Products strongly supports proposed revisions to the GHG Reporting program to deduct CO2 emissions from the consumption of renewable natural gas (RNG) in instances where the RNG is contracted consistent with the criteria set out in the current proposal. It should be clarified that the RNG supplier (with whom the supply has been contracted) may be either a direct RNG producer or an RNG aggregator, so long as the direct producer meets the proposed criteria.

Air Products also strongly recommends that MECP clarify that the deduction of such biogenic CO2 will be allowed both in instances where the RNG consumption is through “combustion”, as well as where the RNG consumption is as a “feedstock”. Both combustion as fuel and consumption as feedstock result in biogenic CO2 emissions that provide the same emission reduction benefit compared with using fossil natural gas as a feedstock or fuel. Restricting the benefit of using RNG as a feedstock alternative to fossil natural gas removes an important emission reduction opportunity for industrial facilities such as hydrogen production facilities. This may have a negative impact on both the development of new RNG supplies in Ontario, and the use of RNG in low carbon intensity hydrogen production.

Further, Air Products encourages MECP to allow RNG sourced from US suppliers to be equally eligible for this reporting deduction, so long as the US RNG source can demonstrate it is tied into a natural gas distribution system connected to Ontario.

Clarifying GHG Emissions to be reported in verification reports
Air Products is interested to learn more about the proposed changes to GHG emissions that are to be reported in verification reports. However, more information is required to be able to provide informed feedback on this matter. Air Products would appreciate clarification from MECP on what the specific changes being proposed are, and when this information will be available to review.

Adjustments to facility compliance obligations
Air Products is interested to understand further what the compliance obligation adjustments in case of extended periods of modification/maintenance encompass. Air Products recommends MECP consider extending such provisions to shorter periods of time that result in the same impact, such as during turnarounds, and not be limited to periods greater than one year as specified in the proposal.

Air Products would appreciate the opportunity to discuss these recommendations with MECP and to provide further information on our recommendations. Please feel free to contact me by phone (780-862-7266) or email haroonh@airproducts.com.