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Thank you for the opportunity to provide comments on “Developing a Voluntary Carbon Offsets Program for Ontario (EBR Registry Number: 013-1634), these comments are submitted on behalf of South Nation Conservation (SNC), an Eastern Ontario Conservation Authority covering 4,384 km2, with 16 municipalities and 3 upper tier United Counties.

SNC’s Programs include natural resources management (water, forestry, fisheries and wetlands), landowner stewardship, education & outreach, and sustainable development (technical reviews, Source Water Protection Risk Management implementation, Ontario Building Code Part 8 (sewage systems) program delivery, implementation of Regulation 170/06 for work in and around waterways/wetlands).

SNC has interest in the Province’s carbon offset programs and is active in the consultation process, participating on several of the Protocol Stakeholder Teams.

With 20-years experience delivering water quality offsets, the SNC Total Phosphorus Management Program has been recognized nationally and internationally for its success in trading between point and non-point dischargers. Based on our experience developing this pilot program from the ground-up, it is important to build programs locally to ensure buy-in and support. Carbon trading is a new concept for many landowners and with approximately 80% of land in Eastern Ontario under private ownership, they are an important stakeholder in the carbon market.

SNC’s recommendation is to use well-established, local agencies, like conservation authorities, to facilitate community participation in the proposed Ontario voluntary carbon offsets program. SNC has excellent partnerships with Municipalities, First Nations, woodlot associations, agricultural organizations, and landowners; this is key to successful carbon offsetting programs. We also have staff expertise and experience required to help landowners develop their projects and navigate the complex carbon market.

One barrier we foresee in developing carbon offset projects is the availability of funding to initiate projects to the point that they produce carbon offsets that are validated for trading. The costs of administration and capital expenditures could limit participation for many project developers. The opportunity for collaboration of several partners is key, this also limits risks of individual entities not meeting their carbon offset targets by allowing for pooled credits under a project.

Proposed carbon offset projects should be eligible to access external funding programs (if they meet grant criteria) to help develop and implement the project. This will make it economically feasible for projects to be maintained in the future and meet verification/re-verification requirements.

SNC supports the environmental co-benefits approach for designing the voluntary carbon offsets program, this aligns with our integrated watershed management approach and ensures multiple benefits for our communities. The onus of demonstrating multiple benefits from proposed projects should rest with the project developer and priority be given to projects that demonstrate the highest level of co-benefits as opposed to a single “high” priority benefit.

SNC would be pleased to work with the Province to pilot a carbon offset program in our jurisdiction, we believe our experience with water quality trading is an asset that has valuable “lessons learned” that are transferable to carbon trading.

If you have any questions regarding this submission, please do not hesitate to contact Ronda Boutz, Team Lead, Special Projects, at 1-613-984-2948 ext. 251 or


Angela Coleman,
General Manager/Secretary-Treasurer

[Original Comment ID: 211990]