Dear Ms. Anderson:…

Dear Ms. Anderson:

Re:EBR Registry Number 013-1634
Developing a Voluntary Carbon Offsets Program for Ontario “Discussion Paper”

The following comments are in response to the Minister’s invitation for public consultation on Ontario’s Environmental Bill of Rights Registry No. 013-1634 - Developing a Voluntary Carbon Offsets Program for Ontario. We would like to offer our most sincere thanks for the opportunity to contribute to this consultation process.

As an early adopter of best management practices in environmental waste diversion and responsible waste management strategies, the City of Guelph was one of the leaders in investing in composting and methane gas recovery and destruction initiatives at its closed landfill. These substantial investments were not mandated by the Province and were implemented solely as a result of the City taking a leadership position with respect to environmental responsibility.

GENERAL COMMENTS

In general, we are supportive of the development of such a program. This program will support the long-term protection of natural heritage systems in Ontario and assist with further development of knowledge and standards around natural capital, ecological goods and services and sequestration of carbon by natural features.

The City of Guelph is one of a few municipalities that currently participate in offset generation, verification and sale of carbon credits within the voluntary market. The City currently has two projects that for the past 7 years have been involved in the sale of greenhouse gas offset offsets. The Eastview landfill site (closed in 2003) generates carbon credits through the capture and destruction of methane. The City’s state-of-the-art Organics Waste Processing Facility, built and commissioned in 2000, generates carbon offsets by avoiding methane emissions produced by anaerobic decomposition of this waste material in a landfill.

1.The City’s preference is for waste management projects such as those described above to be eligible for compliance grade carbon offsets under the cap and trade program. The current draft of the landfill protocol excludes our landfill project from eligibility; the protocol for organics processing has not yet been released. Should these projects not be eligible, we would strongly encourage the Ministry to include these types of projects in this voluntary carbon offsets program in Ontario.
2.Municipalities are by nature risk averse, and need particular considerations to assist with risk mitigation. Renewable natural gas production processes are highly influenced by factors over which the municipality has little control (for example, the gradual decline of landfill gas production over the life of the project). While it is attractive to have a purchaser of the carbon credits resulting from such operations, we have some concern about the risk of having contractual obligations based on forward-looking predictions of gas output rather than retrospective actual production values. We would therefore request that any regulation resulting from this consultation process would include provisions to allow after-the-fact sale of carbon credits, or some other measure to mitigate the risk that production volumes do not meet predictions and that the provider would be liable for any shortfall compared to the contractually obligated volume.
3.It is recommended that furthering the knowledge, practice and standards of natural capital inventory, ecological goods and services value calculations and quantification of carbon sequestration by natural features be included as priorities to the development of the program as there continues to be much uncertainty associated with them and these items are critical to implementing a functional offset program. For example, some municipalities may quantify the natural capital of a street tree as the cost to operate and maintain the asset, while others may factor in the ecological goods and services that a street tree provides. Additionally, the amount of carbon that natural features sequester differs based on the type of feature (wetland, woodland, meadow) and the age of that feature (young trees vs. old trees). As part of the voluntary offsets program, these knowledge gaps should be further researched and standards developed to assist in quantification. For example, there is potential for carbon sequestration arising from naturalization of storm water ponds. Such facilities often attract a variety of species, including bulrushes, cat tails, and other wetland flora. We would be interested in seeing this opportunity considered as an eligible project for voluntary carbon credits.
4.In terms of co-benefits that should be prioritized in the offset program, it is suggested that rather than prioritizing co-benefits, a suite of co-benefits be made eligible but not prioritized. Co-benefits must be examined in detail on a site-by-site basis, since natural features have specific ecological functions based on their form and the species that inhabit them. Prioritizing co-benefits could result in biasing functions, and result in negative impacts to other ecological functions that are also highly valuable. For example, if flood attenuation is prioritized over localized temperature regulation, there may be projects that propose to flood out deciduous forests which may result in a community shift toward swamp and eventually treed marsh, which provide different habitat for different species.
5.The project types that should be a priority for the program should include restoration of natural heritage systems. Obtaining funding to restore and manage natural areas that are protected as part of natural heritage systems has proven difficult across the Province. Promoting restoration as part of this program can contribute to generating funding to ensure that natural heritage systems are not only protected in terms of area, but also in terms of the health and integrity of the system.

CONCLUSION

The City asks that these comments and recommendations be taken into consideration when drafting the associated legislation for the voluntary carbon offsets program in Ontario.

Sincerely,

Alex Chapman
Manager, Climate Change Office
Facilities Management
City of Guelph
T 519-822-1260 x 3324
E alex.chapman@guelph.ca

[Original Comment ID: 212006]