Minister Yurek, We…

Minister Yurek,

We appreciate the opportunity to comment on the Amendments to Transition Ontario’s Industrial Facilities from the Federal OBPS to the Ontario EPS program. I represent one of the leading developers of carbon offsets for compliance markets in Canada and the US, we have extensive practical knowledge of the implications of policy options for compliance alternatives on the operation of emission trading markets. The 13 years of experience in the Alberta carbon market, which is of similar design to the Ontario EPS, provides strong evidence that offsets are a critical component of a carbon market due to their ability to mitigate compliance costs and engage key sectors of the economy such as agriculture, waste management, and forestry.

We encourage the MECP to recognize voluntary reductions or removals (‘carbon offsets’) as a compliance option within the EPS. In doing so, we urge the Minister to rely on the federal offset system to generate eligible compliance offsets for the Ontario EPS, likely saving years of further delays and improving market functioning.

We are working with entities in non-EPS regulated sectors across Ontario who have significant low-cost mitigation opportunities with considerable co-benefits that depend on a functioning offset system and vibrant offset market in Ontario in the short-term. These offset opportunities include forest carbon sequestration on woodlots and Indigenous lands, regenerative agriculture practices on farms, GHG-intensive chemical recycling, and organic waste landfill diversion.

In addition to low cost mitigation that keeps Ontario industry competitive, these opportunities offer significant opportunity for rural economic development, First Nations reconciliation, and protection of natural ecosystems. Capitalizing on this myriad of benefits requires a demand for offsets from the Ontario EPS and it requires swift adoption of offset rules and protocols. The offset opportunity for Ontario farmers, foresters, First Nations, and municipalities has come and gone twice in the past and this has damaged the credibility of this critical tool for climate mitigation. Remaining hopes from these stakeholders lie with the federal offset system currently under development and we cannot afford to yet again deny offset use in the Ontario EPS or start from scratch with a provincial offset system.

We thank you for your consideration.