About The Submission:
We appreciate the ongoing effort to engage with stakeholders regarding the regulations and equivalency agreement and ECCC’s modelling efforts. However, there are still critical assumptions in the modelling that don’t align with how the regulations will be implemented and enforced, based on available evidence. These issues are outlined below, with recommended actions at the end. We are nevertheless concerned that in a number of ways, ECCC’s modelling has both overestimated the mitigation that would result from the B.C. methane regulations, and underestimated the mitigation that would result from the ECCC regulations.
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