Thank you for the…

Thank you for the opportunity to comment on The Proposed Regulatory Amendments for Emissions Performance Standards (EPS) Program 2023-2030.

The EPS Program fails to acknowledge the severity of the climate crisis and sets unreasonable low targets for climate mitigation. Policies enacted in the present will substantially impact the climate far into the future. Furthermore, these poor targets may exacerbate positive feedback loops in the Earth’s system and are not strong enough to prevent irreversible tipping points. Society cannot deal with the climate outcomes that we are projected to encounter with unchanged emissions standards.

Section 1.2 of the Proposed Regulatory Amendments for EPS Program 2023-2030 outlines the carbon pollution price strategy, which is no more ambitious than the minimum requirements imposed by the federal Output-based Pricing System. However, the current price is not a significant enough pricing scheme to meaningfully reduce industrial emissions. Furthermore, the annual changes are far too slow of change for the system to have a considerable impact.

The program differs from the federal system in its aim to reduce pressures that arise from competitiveness. Reducing the impacts of competitiveness from production directly goes against the purpose of the carbon pricing system, which is to reduce industrial greenhouse gas emissions. We need to be comfortable with the concept that industries that are no longer competitive due to the increase in carbon pricing will no longer be able to continue to operate.

The stringency measures applied to high-risk and medium-risk sectors, as described in section 7.0, should be higher than the proposed program. All facilities in each sector should be forced to comply with the minimum regulations, and low stringency factors allow facilities to avoid reaching compliance standards.

Furthermore, the compliance obligation is poorly structured and does not incentivize people to report emissions properly. Therefore, stricter measures for facilities that do not comply with the EPS Program are crucial, and better reporting guidelines are necessary to assess polluters properly.

Another unsatisfactory component of the EPS Program is the esoteric language and poor explanation of the program’s components. The Ministry of Environment opened a consultation to the public to hear perspectives from the people of Ontario. However, the EPS Program document is not comprehensible to most Ontarians, despite climate change being a top concern for many residents. Moving forward with environmental regulation amendments, a better consultation process and greater accessibility must be considered.

Ontario’s EPS Program is among Canada’s weakest provincial carbon pricing systems. Stronger targets must be made to adequately address the climate crisis and meet the national climate targets.