Enbridge Inc. is North…

Enbridge Inc. is North America's premier energy infrastructure company with strategic business platforms that include an extensive network of crude oil, liquids and natural gas pipelines, regulated natural gas distribution utilities and renewable power generation. The Company safely delivers an average of 2.9 million barrels of crude oil each day through its Mainline and Express Pipeline; and we transport 25% of the crude oil produced in North America. The Company's regulated utility, Enbridge Gas serves approximately 3.7 million retail customers in Ontario, Quebec, and New Brunswick. Enbridge also has interests in more than 1,700 MW of net renewable generating capacity in North America and Europe.

We are pleased to provide our initial comments on streamlining and updating of greenhouse gas reporting requirements. Enbridge supports the government’s intent to streamline reporting requirements and to reduce unnecessary costs and regulatory burden.

Based on initial analysis, Enbridge is generally supportive of aligning provincial greenhouse gas qualification methods with federal methods including adapting the including the adoption of the IPCC AR4 Global Warming Potentials. However, there is potential for complication given companies may have referenced Ontario’s regulation in the Output Based Pricing System (OBPS) regulation, which is still in the proposal stage. Additionally, be aware that under the federal GHGRP, Ontario companies were permitted to use provincial regulatory calculation methodologies where the federal program was not as prescriptive. Therefore many of our quantification systems are configured in accordance with Ontario’s Guideline for Quantification, Reporting and Verification of Greenhouse Gas Emissions (2018). Any changes to the guideline to align with the federal GHGRP could create additional work and cost for companies as well as introduce confusion due to the less prescriptive nature of the federal regulation, especially for natural gas distributors. While Ontario’s reporting and verification guidance is more robust and clearly defined it is important that there is communication between Environment and Climate Change Canada and the Ontario Ministry of the Environment, Conservation and Parks to determine which aspects to retain.

To further reduce unnecessary regulatory burden and the costs associated with verification, Enbridge supports the proposal to remove greenhouse gas reporting and verification requirements for natural gas distribution. This requirement was introduced to support cap and trade, and since this program has been cancelled, it is no longer necessary. Additionally, natural gas distributors already face increased reporting and verification requirements under the federal carbon pricing program. Enbridge requests clarity on the proposal to remove verification for reporters that may have compliance obligations under the Ontario Emissions Performance Standard program. For instance, what criteria would qualify a company to be exempt from verification? Enbridge intends to submit comments to the proposed performance standard including any additional concerns or considerations where appropriate.

Canadian companies must compete globally against locations with lower cost and more streamlined regulatory processes. Enbridge, which operates in multiple jurisdictions, is required to respond to increasingly complex and layered carbon and climate regulations. Governments must avoid inadvertently introducing competitive risks to companies or otherwise take steps to mitigate these risks with the input of industry.

It is anticipated that Enbridge may have further comments once the details of the proposed changes to quantification methods are proposed later this fall for consultation. If you have any questions or require additional information please do not hesitate to contact Brad Lattanzi, Government Affairs Strategist (brad.lattanzi@enbridge.com).