Ms. Vidya Anderson, Project…

Ms. Vidya Anderson, Project Manager, Environment & Climate Change
Environmental Program Planning &Implementation Branch
135 St. Clair Ave; West 11th Floor,Toronto, Ontario, M4V 1P5

Comments: EBR # 013-1634 – Ministry of Environment and Climate Change, Developing a Voluntary Carbon Offsets Program for Ontario

The Preservation of Agricultural Lands Society (PALS) , whose members have been working for over 42 years to permanently protect the irreplaceable Niagara fruit lands, is pleased that the Premier’s mandate letter and the 2017 Budget have directed that there be a ‘Voluntary Carbon Offsets Program’, and further, that there will be an agricultural component which may be used by the “government” to play its part in the provincial , national and global efforts to mitigate climate change. 1.EBR Notice page 1 and Page 11 Discussion document ‘Developing a Carbon Offset Program for Ontario’

In this regard, while there is some discussion of how natural areas store carbon and a very brief mention of farmland preservation and farm communities, the latter two should be a far greater part of the upcoming dialogue. And Niagara, being unique ‘specialty crop lands’ , miniscule in acreage compared with the hundreds of thousands of prime class1-4 farmlands in Ontario, and despite the Greenbelt still under considerable urban–use pressure, should be a first “priority” 2. Ibid Page 14 question 6.

PALS submits that the Province has an invaluable opportunity , through the Ministry of Environment and Climate Change, to prioritize the protection of fruit tree crop lands as well as stabilize and enhance the industry, through a voluntary carbon offset program, whereby farmers are paid to place restrictive covenants on their fruit land to prevent development “in perpetuity” . We note that many US States pay for easements to protect valuable farmlands, and in 1994 Michigan initiated an easement program which by 2012 had essentially stopped urban sprawl and revitalized Michigan’s Traverse County red tart cherry industry. And, in 2016, California, which has lands suitable for sensitive tree crops such as apricots and almonds, invested $37.5million in easement purchases on restrictively-zoned farmlands as part of its Climate Change program, on the basis that not only would these farmlands be a good carbon sink, but protecting them over the long term would avoid the huge carbon emissions from urban sprawl . 3. https://www.farmland.org/initiatives/californias-sustainable-agricultur…

While it is unclear in the discussion paper who should pay for these “voluntary carbon offset” programs, it is PALS position that, since the offsets are intended “for use by the government” among others 4. EBR Notice page 1 , and the Province has already invested in Green Energy Plan climate- mitigation home retrofit programs, that it should similarly invest in an easement plan. In this case, such a far -sighted program would not only help fulfill the Province’s mandate to reduce carbon emissions through soil and tree carbon sequestration and avoided urban sprawl, but also bolster Greenbelt protections.

Tender fruit land protection and industry investment would also help fulfill the very important Voluntary Carbon Offset’s goals of “ additional environmental, social and community benefits” 5.Ibid page 11 Table 1, which as we noted in a 2016/17 Pre- Budget brief, will not only save the rare and threatened Niagara fruit land that grows healthy fruit close to urban markets, but also ensure Greenbelt protections continue to work over the long term, create and maintain much needed value-added farm jobs, bolster Niagara’s tourism sector , and most important, given Niagara’s very limited fruit land base and current real estate and other sector pressures, help fruit farmers stay in business. 6. PALS Spring 2017 Newsletter QUOTABLES Page 4 http://members.becon.org/~pals/PALS%20Spring%20Newsletter%202017.pdf

We note that four of our five PALS’ Easement Team members, mentioned in the above-linked article, were part of the 1992-1995 development of a 1995 Ministry of Agriculture, Food and Rural Affairs ‘NIAGARA TENDER FRUIT LAND Easement Program (Cancelled by an incoming conservative government before its initial roll-out could protect 4,000 acres of tender fruit land “in perpetuity”). And, we are not alone in supporting that program’s plan for the investment in “permanent” easements/ restrictive covenants to protect this rare and threatened land base and industry. Others include the Ontario Farmland Trust, the Regional Niagara Agricultural Policy and Action Plan Committee, the Provincial Council of Women of Ontario , the Honourable Jeff Leal, Minister of Agriculture, Food and Rural Affairs and Jim Bradley MPP St. Catharines .

Finally, regarding the discussion paper ‘s questions on the best way to enhance community participation, the PALS Easement Team offers its assistance in developing a tender fruit land voluntary carbon offsets program, which could well be a model of how these programs could best be facilitated , and we would be very pleased to discuss this further at the Ministry’s convenience.7. Page 14 Question 4.

c.c. The Honourable Chris Ballard, Minister of Environment and Climate Change
The Honourable Jeff Leal, Minister of Agriculture Food and Rural Affairs
Jim Bradley, Member of Provincial Parliament St. Catharines

[Original Comment ID: 211973]