The Ministry of the Environment and Climate Change filed amendments to the Greenhouse Gas Emissions Reporting Regulation (O.Reg. 452/09) in December 2015 that will come into force on January 1, 2016 (see attached regulation). The amended Guideline is published as part of this decision (see link). The amendments include:
- Lowering the reporting threshold to 10,000 tonnes CO2e from the current threshold of 25,000 tonnes per year, while maintaining the requirement to have emissions greater than 25,000 tonnes per year third party verified.
- Dividing the emission sources into those that only need to reportand those that require third party verification.
- Clarification on verification to allow for the use of qualified positive, in addition to positive and adverse verification statements.
- Adding petroleum product suppliers and natural gas distributors to the reporting regulation starting in 2016, to support the implementation of a cap and trade program.
- Adding other sources to the reporting regulation including:
o Equipment used for natural gas transmission, distribution and storage,
o Electricity imports,
o Electricity transmission and distribution,
o Magnesium production, and
o Mobile equipment at facilities (optional reporting only).
Comment(s) Received on the Proposal:
Public Consultation on the proposal for this decision was provided for 45 Days, from September 14, 2015 to October 29, 2015.
As a result of public consultation on the proposal, the Ministry received a total of 32 comments: 17 comments were received in writing and 15 were received online.
Additionally, a copy of all comments are available for public viewing by contacting the Contact person listed in this notice.
The proposed greenhouse gas emission reporting regulation amendments were posted on the Environmental Registry and Regulatory Registry for public comment. There were about 30 comments from stakeholders ranging from fuel suppliers, industry, energy companies, municipalities and the Quebec government. Most were supportive of the approach to broaden the scope of the reporting program; but, there are many technical concerns. Major comments are summarized below:
- Natural gas suppliers indicated a need for lead time (3 years) to implement any fugitive emissions monitoring program and asked that the these types of emissions be considered as reporting only (no verification);
- Petroleum product suppliers indicated a need to harmonize the requirements with Quebec and further clarity on the parties that are facing compliance requirements;
- Several electricity importers asked for a reporting threshold that is higher than zero, and more flexibility on what can be considered as specified power (from a dedicated generation facility in another jurisdiction);
- Several companies asked for reduced administrative burden and exemption from having to report mobile emissions;
- Several companies asked for a definition of a facility that would allow them to report all their operations across the province as a single facility;
- Recognition that biofuels (e.g., for cars) have different characteristics and should not be considered as having no emissions.
As a result of the consultation, the Ministry has made the following additional changes to the proposed amendments to the guideline under EBR Registry Number 012-4549:
- Classify natural gas transmissions and distribution fugitive emissions as reporting only; and
- Make reporting of mobile emissions optional.