We find the Provincial…

We find the Provincial proposal for a Clean Energy Registry to be misguided, ineffectual, risky and costly. We disagree strongly with the creation of the Registry as proposed for the following reasons:
1. Without further clarification the registry appears to be primarily offering carbon credits based on the performance of projects that are already in place in the Ontario grid and therefore do not meet the Additionality standard for CEC. Any credits currently provided by the existing Ontario grid have obviously been retired.
2. The financing provided by the sale of carbon credits will not necessarily be used to finance carbon reduction projects which would not otherwise be implemented. Instead, their use will be at the biased whim of political exigencies with a strong bias to assisting electricity ratepayers.
3. The registry will be set up and managed by the IESO which controls the same non-emitting projects providing the carbon credit value. The Registry will therefore not be under the operation of an independent and unbiased body. The conflict of interest of the IESO and a Registry is obvious and deeply affects the authenticity of establishing carbon credits.
4. Establishing a carbon credit market for Ontario is not only a provincial matter. GHG emissions emitted in the province have global implications. It is therefore critical that standards and institutions established for carbon mitigation marketing meet not only Canadian federal standards but procedures and standards established globally. For Ontario not to meet federal and international standards opens the province to international condemnation and liability to those engaging in the purchase of unqualified carbon credits.