Kuntz Electroplating Inc. …

Kuntz Electroplating Inc. (KEI) supports Ontario Ministry of Environment, Conservation and Parks’ (MECP) proposal entitled Streamlining and updating of greenhouse gas reporting requirement, which would amend Ontario’s greenhouse gas emissions reporting program to remove the collection of unnecessary data.

KEI opted- in to the Ontario Cap & Trade program, which triggered an annual verification requirement of its greenhouse gas (GHG) emissions. Despite the cancellation of the Cap & Trade program, KEI is required to continue to verify its GHG reports as a result of the ‘continuing duty to verify’ in O.Reg 390/18: Greenhouse Gas Emissions: Quantification Reporting and Verification.

According to the O.Reg 390/18 subsection 9(4) if a facility’s emissions are between 10kt and 25kt CO2e for three consecutive years subsequent to the first year where reporting is required, it can exit the verification obligation. As a result, KEI is obligated to verify emissions for two more reporting years in order to comply with the regulations, even though the Cap & Trade program no longer exists in Ontario and KEI’s emissions are below the 25kt verification threshold. The resources and costs for the third party verifications result in unnecessary costs and administrative burdens for KEI.

Therefore, KEI supports the removal of the third party verification of emissions requirement for the voluntary participants as defined in O.Reg 390/18.