Our comments on the…

Our comments on the Emissions Performance Standard ('EPS') regulatory proposal are attached in a separate pdf document with greater context. The comments can be summarized as follows:

1. We encourage MECP to consider more ambitious stringency factors that provide a prospect for a healthy market for emissions reductions. This is needed to adequately incentivize Ontario industry to invest in energy and resource efficiency as well as GHG reductions from enhancing forest management, waste management and agricultural practices.

2. We ask that the EPS refrain from applying limits to the use of compliance units and voluntary reductions/removals. The EPS should maximize the incentive for regulated entities to invest in their own energy efficiency and offset projects with significant co-benefits. This will lead to more efficient outcomes than making payments for compliance.

3. We urge MECP to prioritize development of an offset framework that can function on day 1 of the EPS coming into effect. This would maximize the job creation and economic opportunity benefits of the EPS policy. The offset framework (protocols, approval processes) could borrow from and align with Alberta, Saskatchewan, Manitoba and the federal OBPS.

In so doing, it would create opportunities for Ontario forestry, agriculture, refrigeration and waste management sectors under a made-in-Ontario system pending the entry into force of the EPS and deliver the co-benefits and low-cost mitigation on day 1 of the EPS.

Thank you for your consideration.