Dear Ms. Anderson,…

Dear Ms. Anderson,

Ontario Sheep Farmers (OSF) welcomes the opportunity to provide comments on Developing a voluntary carbon offsets program for Ontario. OSF represents nearly 3,000 sheep farmers in the province of Ontario. With a focus on profitability and sustainability, the organization works in the areas of advocacy, industry capacity, research and market development. Its goal is to provide consumers with premium lamb and sheep products.

OSF is pleased to see that environmental co-benefits – tree planting to help with soil erosion and flood management, and providing plant species for bees to pollinate - are being proposed a key element of the proposed program design. Many agriculture operations have already incorporated many of these co benefit activities into their farm business operations with little to no programming support to do this. OSF would like to see programming that rewards these early adopters and innovators for developing and implemented these good practices at their farm businesses rather than penalizes them.

OSF would like more information and clarity provided on how the price of the carbon credits is going to be established. The price of the credits also needs to be significant enough to provide an incentive for farmers to participate in the program. Further, more information on how the carbon credits are going to be marketed for purchase should be provided.

The size of the farm operation should not be a barrier to participate in a carbon offsets program in Ontario. To reduce this barrier, the opportunity to aggregate smaller offset projects could increase participation from the agriculture sector in the program.

Communication and extension on any voluntary carbon offsets program will be needed, with a specific strategy and plan developed for the agriculture sector. Consideration needs to be given to the time of year that these extension activities take place, and that they do not conflict with farm business activities (i.e. planting, harvest).

Many Best Management Practices (BMPs) have been, and continue to be, developed for agriculture production that are based on science and practical application to a farming enterprise. OSF would like BMPs to be the standard for the development of requirements for creating carbon offsets projects. Further, OSF would encourage the Ministry of Environment and Climate Change to include agriculture industry representatives as participants on the technical workings groups that it is planning to establish.

Finally, OSF would like to see administrative costs and burdens of the program to be as minimal as possible. As mentioned, farmers are already involved in and have implemented activities in the farm businesses that help offset carbon emissions. If the program places too much of a burden, farmers will be less inclined to participate.

OSF thanks the MOECC for providing the opportunity to provide comments on Developing a voluntary carbon offsets program for Ontario. We would be pleased to further discuss our comments and concerns with you at your earliest convenience.
Sincerely,

Robert Scott
Chair, Ontario Sheep Farmers

[Original Comment ID: 211972]