On February 28, 2018, TEI filed comments on the proposed Greenhouse Gas Pollution Pricing Act (Act) and Draft Fuel Charge Regulation (Regulation) (collectively, Proposed Legislation) released by the Department of Finance and Ministry of Environment and Climate Change on January 15, 2018. In 2016, the Canadian government published a Federal benchmark mandating the application of carbon pricing to a broad set of emission sources throughout Canada, while providing provinces and territories flexibility to implement their own carbon pollution pricing systems. The benchmark committed to implement a Federal backstop upon any province or territory that did not have a qualifying carbon pricing system in place by 2018. The Proposed Legislation sets forth the proposed Federal backstop.
TEI’s comment letter urged the Government to provide industry with appropriate lead time to plan, test, and implement complex changes to their legacy information technology systems; addressed concerns about provinces/territories that may be outside of the scope of the Act at its implementation but which may become listed provinces at later date; expressed concerns about complying with two levels of government regulation on the same fuel; addressed concerns related to the application of the legislation to joint ventures; addressed concerns about reporting and taxation of natural gas trading activities; encouraged the Government not to penalize taxpayers based on the age of facilities; and addressed potential inequities among provinces.
TEI's comments were prepared under the TEI’s Canadian Commodity Tax Committee, whose chair is David Card. Pilar Mata, Tax Counsel for the Institute, coordinated the preparation of TEI's comments.