November 6, 2017…

November 6, 2017

PJ Partington
Ministry of the Environment and Climate Change
Ferguson Block 10th Floor, 77 Wellesley Street West
Toronto, Ontario
M7A 2T5

RE: EBR Registry Number 013-1457, Amendments to the Cap and Trade Program and Reporting Regulations & Service Regulation & Administrative Penalties Regulation

Dear Mr. Partington,

Thank you for the opportunity to comment on EBR Registry Number 013-1457, Amendments to the Cap and Trade Program and Reporting Regulations & Service Regulation & Administrative Penalties Regulation. The Ontario Forest Industries Association (OFIA) believes that Ontario’s forest sector can play an important and positive role in Ontario’s Climate Change Strategy and we would like to provide the following comments on the September 22nd Ministry of Environment and Climate Change (MOECC) proposal.
The forest products sector in Ontario currently represents $15.5 billion of revenue and provides 172,000 direct and indirect jobs. The sector is the cornerstone of Ontario’s low carbon economy manufacturing a wide variety of low carbon products, energy, as well as sustainably managing Ontario’s crown and private forests.
The sector is also an industrial leader in greenhouse gas emission reductions with the current operating facilities reducing greenhouse gas emissions by over 65% since 1990 – far exceeding the Province of Ontario’s 2020 and 2030 targets. These significant reductions are a result of early adoption of fuel switching from fossil fuels to renewables (primarily biomass), energy conservation projects as well as facility level capacity reductions.

In the 2017-2020 Ontario Cap and Trade program, MOECC has recognized these mitigating efforts through an adjusted declining cap based on biomass content. Not only does this adjusted cap recognize early actors, but it also provides the necessary incentive to continue making improvements and further facilitate the transition of the Province of Ontario to a low carbon economy. We seize that opportunity to reiterate the importance of this incentive measure and expect that this adjustment of the declining cap based on biomass content will remain in the Post 2020 Ontario Cap & Trade program.

As our industry is in the midst of its transformation, it will be critical that Post 2020 Ontario Cap & Trade program supports this transformation which could potentially lead to global substantial GHG emissions reductions through product and forest carbon sequestration or the intensive use of our current and future products to replace fossil fuel derived products. Biofuels and biomaterials are promising avenues to fight climate change on a broader base as these products will reduce GHG emissions in both transportation and production across the province of Ontario. The addition of such products to our facilities will trigger the need for adjustments in the Post 2020 free allowance methodology.

Finally, under the Quantification, Reporting and Verification of Greenhouse Gas Emissions Regulation (O. Reg. 143/16), we are concerned by the proposed requirement to submit the verification report along with the verification statement. By doing so, sensitive information such as facility’s production data could potentially become public. Prior to agree with the submission of the complete verification report, we are raising this major competitive issue. We are asking MOECC to ensure that appropriate measures and controls will be put in place to ensure the confidentiality of sensitive information.

We are confident that linkages now established between Ontario, Quebec and California will create a larger market, reduce costs and provide Ontario with more opportunity to receive offsets.

Rest assured that Ontario’s forest products sector supports Ontario’s desire to move towards a low carbon economy and OFIA looks forward to continuing to work with the Government of Ontario and the Ministry of the Environment and Climate Change on the implementation of their Climate Change Action Plan and the post 2020 Cap and Trade Program.

Sincerely,

Lauren McBride
Environment and Energy Advisor
Ontario Forest Industries Association

Cc:
Heather Pearson, MOECC
Jeff Hurdman, MOECC

[Original Comment ID: 211290]