UPDATE - CPA requires your feedback by August 12 on new Technical Guide for E2 Regulations
Environment and Climate Change Canada (ECCC) delivered a new version of the Technical Guide for Environmental Emergency Regulatory Requirements on July 15, 2020. The deadline to provide changes to the guide is before August 12, 2020. The CPA has already prepared industry-guided feedback and requests your review of this feedback, along with any additional comments or concerns that you have identified on the wording of the guide.
Note that the review portion is only on the wording of the guide, and not on the regulation itself. To that end, the CPA previously met with ECCC to discuss industry concerns with the regulatory requirements. However, while our suggestions were heard, ECCC has to date indicated they are not willing to effect change, which causes significant regulatory burden to the propane industry. These concerns were relayed to the minister in response to ECCC’s refusal to entertain our industry’s concerns. Our expectation is that the minister will address these concerns separately from the above document.
Please ensure that any comments you have about the technical guide being reviewed are related to concerns with language that may affect the interpretation of the current regulation, and not requested changes to the regulation itself. You can forward your concerns to tammyhirsch@propane.ca while Rob Loenhart is away for inclusion in the response to ECCC.