Posted by Chris Paré, P.Geo. on Oct 7, 2015 in Blog |

If you follow our blogs, then you may recall that on April 24th we discussed the pending Greenhouse Gas (GHG) Cap and Trade Program for Ontario.  We mentioned then that we would keep you updated as we learn more about the nuts and bolts of this program.  And what we know currently is based on a recent release from the Ministry of Environment and Climate Change (MOECC).

On September 14, 2015, the MOECC issued a notice seeking comments on proposed amendments to the GHG Emissions Reporting Regulation (O.Reg. 452/09) and the Guideline for Greenhouse Gas Emissions Reporting.

Regulation of GHGs in Ontario

Recall that the purpose of O. Reg 452/09 is to report GHG Emissions that are “…intended to support the development and future implementation of a cap and trade program for greenhouse gases.”  As the regulation is currently structured, it only covers certain facilities with GHG emissions in excess of 25,000 TPY (tonnes per year).

However, part of the proposed amendment is to reduce the threshold for reporting from 25,000 TPY of CO₂e to 10,000 TPY of CO₂e (NOTE: CO₂e = Mass of GHG x Global Warming Potential of GHG).

According to the Guidance Document (Regulatory Proposal: Proposed Amendments to Greenhouse Gas Emissions Reporting Regulation [O.Reg. 452/09] and Incorporated Guideline: 2015”), “The proposed changes would significantly increase the amount of emissions reported and the number of facilities reporting under the Regulation.”

As it relates to the specifics of the proposed amendments, the changes include the following:

• Lowering the reporting threshold to 10,000 tonnes CO₂e from the current threshold of 25,000 tonnes of CO₂e per year, while maintaining the requirement to have emissions greater than 25,000 tonnes per year third-party verified.
• Divide the emission sources into those that are reporting only and those that require third-party verification.
• Add petroleum product suppliers and natural gas distributors to the reporting regulation, starting in 2016, to support the implementation of a cap and trade program.
• Add other sources to the reporting regulation including the following:  equipment used for natural gas transmission, distribution and storage, electricity imports, electricity transmission and distribution, magnesium production, and mobile equipment at facilities.

In addition, according to the announcement, “Technical changes to the calculation methods are also proposed to align with Quebec and California on missing data, analysis methods, and reporting of production data (to support cap and trade).  These changes include several changes proposed under EBR Registry Number 012-2618.”

Impact on Ontario Manufacturing Companies

So what does this mean to the regulated community in Ontario?  We still cannot say for certain, but as stated in April, there will be increasing pressure on companies in Ontario to inventory, and ultimately reduce, their GHGs.

Further, as stated by the MOECC, “The Ministry will consider the use of monetary penalties for non-compliance with reporting requirements of greenhouse gas emissions as part of any proposal for a cap and trade program.”

The politics of GHGs aside, this may not be welcomed news as Ontario manufacturers face increased global competitive pressures and recent data that seems to suggest a recession is now underway.

As we learn more information, we’ll continue to share it with you on this site.  In the meantime, please feel free to contact me (cpare@dragun.com) at 519-979-7300, ext. 114, with any questions you may have as it relates to environmental compliance, assessment, or remediation.