The Ministry's consultative…

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The Ministry's consultative approach to developing a voluntary carbon offset protocol is encouraging.

Ontario Pork looks forward to working closely with MOECC and OMAFRA in exploring how the livestock sector in Ontario can be part of the solution in addressing climate change and how our sector can contribute to permanent and cost-effective greenhouse gas reductions in this province, for instance through manure management practices that minimize losses of manure nitrogen to the atmosphere, and have the potential to reduce phosphorous run-off into surface waters, e.g. Lake Erie.

In response to the specific questions poses in this consultation the following comments are offered for consideration:

Question #3. Are there specific barriers to participation in the carbon market that the Ministry should consider when developing the proposed the Ontario voluntary carbon offsets program?

There will inevitably be potential obstacles to participation, e.g. reporting/recording requirements by potential participants, governance issues related to how cost and benefits of protocol implementation are shared by project developers, aggregators and individual participants (e.g. farmers), and the adequacy of the carbon offset credit price.

However, we are confident that most of these obstacles can be addressed through two measures:
1) A clear process is established under the program that allows for frequent working-level discussions between technical staff/persons within the parties developing new protocol ideas (e.g. Ontario Pork or Ontario Federation of Agriculture), potential developers and aggregators, and the agencies who have to approve and oversee the protocols (e.g. MOECC, OMAFRA). Frequent back and forth at a technical level allows for kinks to be worked out in advance that could become obstacles and damage potential interest if a poor protocol is launched. It also improves the chance that protocols will align with MOECC's environmental goals such as climate change and water quality protection.

2) A mechanism to roll out a new protocol as a size-limited pilot through which the final kinks (e.g. submission of data) could be worked out. This approach would embrace the reality that some protocols will not be perfect from the start and will require fine tuning as the on-the-ground realities of implementing the protocol become clear. The pork sector has experience with this approach - the national pork quality assurance program (CQA) is being overhauled and the new program was rolled out on a pilot basis in 2017, allowing program developers to refine details that were found to be impractical and/or ineffective, before rolling the program out in full.

Question #4. What is the best way for the Ministry to facilitate community participation in the proposed Ontario voluntary carbon offsets program?

Creating a clear process under the program that allows for frequent working-level discussions between technical staff/persons within the parties developing new protocol ideas, e.g. a community and the agencies approving/overseeing the protocols would facilitate community participation.

Question #5. What environmental co-benefits (e.g., flood management) should be prioritized in the proposed Ontario voluntary carbon offsets program?

a) Water quality - reducing phosphorous-runoff into surface waters, e.g. Lake Erie
b) Water quality - reducing nitrate run-off into surface and ground waters
c) Air quality - reducing fine particulate matter (PM2.5)
d) Soil health - increasing soil organic matter and soil microbiology on Ontario farmland

Question #6. What project types should be a priority for the Ontario voluntary carbon offsets program?

Project types should be prioritized based on their merit, in particular their ability to contribute to the policy goals e.g. addressing climate change, improving the health of the Great Lakes, and improving air quality.

Emphasis should be put on clarifying to interested parties what the requirements and processes are for developing a protocol, submitting it for approval, and launching it. If this process is clear, and interested parties have access to technical guidance from technical staff at the appropriate agencies, it should encourage the development of protocols, giving the government a greater selection of potential protocol candidates to consider and prioritize based on their promise to achieve policy objectives.

Question #7. What actions can the Ministry take to support viable end markets for Ontario voluntary
carbon offset credits?

A commitment by the provincial government and its agencies to play a significant and reliable role in the end market is critical for the success of the voluntary program. Successful offset protocols may be considered after a certain evaluation period for "upgrading" to meet higher standards, e.g. for international voluntary offset credit programs and/or compliance grade offsets.

[Original Comment ID: 211974]