The Ontario Federation of…

ERO number

019-7649

Comment ID

95746

Commenting on behalf of

Ontario Federation of Agriculture

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Comment approved More about comment statuses

Comment

The Ontario Federation of Agriculture (OFA) proudly represents more than 38,000 farm businesses across the province, supporting our members and the agriculture industry on issues, legislation and regulations governed by all levels of government. We are the leading agricultural advocate for Ontario farmers, their businesses, and their communities.

We appreciate Ontario efforts to improve rural access to reliable, affordable, and sustainable energy options by enabling Ontario produced and supplied RNG to offset the obligations of covered facilities.

Renewable natural gas (RNG) is an important fuel source to ensure we are able to rely on our natural gas infrastructure to access energy through the next decades, and necessary to continue to lead Canada in the production and distribution of hundreds of agricultural commodities and food products, both locally and internationally.

The proposed amendment to allow the deduction of verified RNG GHG emissions from an EPS-covered facility’s emissions from RNG purchased under contract and delivered to through the gas pipeline network aligns with existing natural gas transaction processes. The amendment will help develop the RNG market necessary to meet our greenhouse gas reduction commitments.

Once this amendment is realized, eligible RNG produced and injected into Ontario’s pipeline network meant to meet covered facility’s EPS obligations should be expanded to allow RNG from other jurisdictions injected into Ontario supply.

Ontario forest and agricultural biomass used as anaerobic digestion (AD) feedstocks for RNG production are substantial. OFA recommends that all RNG derived through AD be considered as 100 percent biomass.