We are of the view that the…

We are of the view that the reporting requirement petroleum product suppliers should be removed retroactive to July 3/18 being the date that the Cap & Trade Program was terminated.

Companies that were subject to the reporting requirements for ON Cap & Trade had reported and verified (where applicable) their volumes sold and the associated emissions up to July 3/18. Requiring the same companies to report all volumes etc. for all of 2018 and to get them verified is unnecessary and burdensome. If the reporting requirement were to remain in place for all of 2018 this would cause a filer to have to pay for two verifications for the same jurisdiction in the same calendar year. (No companies would have budgeted for two verifications.)

Further, as submitted in the proposal, the removal of this requirement "...will have no impact on how the government tracks emissions from these sources." As such, there does not appear to be any value in having companies report their volumes and associated emissions subsequent to Jul 3/18.

Thank you