In support of the development and future implementation of its cap-and-trade system, Ontario’s Ministry of the Environment and Climate Change (MOECC) is proposing amendments to the Greenhouse Gas Emissions Reporting Regulation (O. Reg. 452/09) (the GHG Reporting Regulation). Under the current GHG Reporting Regulation, regulated facilities emitting 25,000 tonnes or more of carbon dioxide equivalent (CO2e) per year are required to report and verify their emissions. Once implemented, the proposed amendments will significantly increase the amount of emissions reported and the number of facilities reporting under the GHG Reporting Regulation.
The proposed amendments include the following:
• 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 are reporting only and those that require third party verification;
• adding petroleum product suppliers and natural gas distributors to the GHG Reporting Regulation starting in 2016; and
• adding other sources to the reporting regulation including:
– equipment used for natural gas transmission, distribution and storage,
– electricity imports,
– electricity transmission and distribution,
– magnesium production, and
– mobile equipment at facilities.
Similar to California, there will be no emissions thresholds for electricity importers, the purpose of which is to prevent them from sub-dividing into smaller entities to avoid compliance obligations.
The reporting threshold for liquid petroleum fuel distributors and suppliers will be set at 200 litres of fuel to ensure consistency with Québec requirements. The verification threshold will remain at 25,000 tonnes of CO2e, but any liquid fuel distributor and suppliers that exceed the 200 litre threshold will be required to verify their emissions reports. All electricity importers will be required to verify their emissions reports.
The amended GHG Reporting Regulation will also categorize certain emission sources as being subject to reporting requirements only, meaning that these emission will need to be reported, but would not be subject to verification or potential compliance requirements under the cap-and-trade program. These proposed categories include:
• fugitive geothermal units and hydrofluorocarbons (HFC) emissions from cooling units at electricity generators;
• coal storage emissions;
• biomass combustion emissions; and
• on-site emissions from mobile equipment.
The proposed amendments have been posted for a 45 day public review and the comment period will end on October 29, 2015. Comments may be submitted to the MOECC’s designated contact person or online.