RE: Developing a Voluntary…

RE: Developing a Voluntary Carbon Offsets Program for Ontario

Dear Vidya,

Red Sky Métis Independent Nation (RSMIN) has reviewed the “Developing a Voluntary Carbon Offsets Program for Ontario” discussion paper and would like to provide our perspective, as well as, questions about the program. RSMIN citizens see the value in the creation of a Voluntary Carbon Offsets Program and the necessity of mitigating the effects of climate change. The five objectives laid out in the “Getting There” section of the discussion paper define what the program intends to achieve, and while these objectives cover many important components RSMIN would like to see an additional objective added.

RSMIN is proposing that a “Research and Advancement” objective be created to oversee and encourage new types of offset projects that will continue to mitigate the effects of climate change. This objective would support research into projects such as low carbon or no carbon fuel sources, high efficiency equipment for the mining and forestry sectors, new sources of sustainable foods and new methods for growing food with reduced GHG emissions. Having an objective dedicated to research and technological advancement would open the door to new types offset projects that can aid Ontario in reaching and sustaining its goal of a carbon neutral economy. While the “Resilient Communities” objective states that building, natural capital will drive innovation, RSMIN strongly believes that true innovation and progress will only come if there is a dedicated objective to do so.

When discussing the topics laid out in the discussion paper RSMIN noticed that a lot of our conversation centered around “How much carbon or greenhouse gases (GHG) will be sequestered by a project?” or “What does one metric tonne of carbon look like on the landscape?”. After speaking with staff at the MOECC, RSMIN understands that each offset project will be unique, which means that there is no way to standardize how much different types of projects will avoid or sequester carbon. With that being said, RSMIN wants the government to provide examples of fully completed projects that show how much carbon they sequestered or avoided. These example projects should be accessible to Indigenous communities and the public so that groups can get a full understanding of the types of offsets projects, the amount of carbon the projects could potentially remove and the amount of work that is required to achieve them. Constructing an offset project will require a large upfront investment to determine a project’s feasibility and the GHG sequestering (or avoiding) potential. Having these examples will help groups to make smart decisions when starting an offset project, even if the example can’t tell them the exact amount of GHG they will be able to avoid or sequester. Furthermore, RSMIN would like the Ontario government to regulate and monitor all companies who calculate the GHG sequestration and avoidance of offset projects. Regulating these companies will ensure that all statistical models used for calculations are consistent and scientifically proven to provide the most accurate results. This would also mean that as new technology and information becomes available the government could assure that companies are using the best tools for their calculations.

RSMIN citizens still practice traditional land use activities, such as hunting, fishing, trapping and the gathering of medicinal plants. These traditional activities provide citizens with a deep connection to the land, wildlife and even the flora. As the climate continues to change many of these traditional activities have been put in danger, because of invasive species and moving species ranges. Given the importance of these traditional practices, RSMIN strongly believes that offset projects should focus on whole ecosystems rather than just focusing on trees. Sequestration offset projects should include the conversation of large sections of untouched lands (e.g. wetland systems) or the restoration of an entire ecosystem (e.g. replant shrubs, clean banks etc.), instead of just planting monocultures of conifers. The MOECC should visit with Indigenous communities and learn about the land from the people who live on it. Many of the potential offset projects will have to take place in Northern Ontario, therefore every effort should be made engage Indigenous communities and work them when developing offset projects.

RSMIN citizens have several questions about the proposed program that can be include:
1)Will farms qualify as a GHG offset?
2)Can individuals create and manage a carbon offset to sell as part of the proposed Voluntary Offset Program?
3)Are trees (conifers) the only plants that qualify for use in “plant based” carbon sequestration offsets?
4)How will the amount of GHG sequestered or avoided be calculated for each project?
5)How much money will each offset-credit be worth?
6)What are the “time tables” on these proposed offset projects? Example: How long will trees have to remain standing to be considered an offset?
7)How will the taxes generated by these offset projects be used? Will they be used to pay for more offsets? Or for climate change research?
8)Will there be constraints on how groups or individuals can spend the money they receive for their offset projects?
9)Are there going to be capital gains tax on money received for offsets? If so how will it be applied? All at once or over the duration of the project?
10)Who will oversee the monitoring of offset projects purchased by the government of Ontario?
11)Will the government of Ontario regulate or create a training program for businesses looking to calculate and design carbon offset programs?
12)Do all sequestration programs have to be newly planted plot or can they be standing forest that is will be properly managed?
13)Will conserving untouched wetlands or other ecosystems be considered as sequestration projects?

Sincerely,

Kayla Searle
Environmental Coordinator
Red Sky Métis Independent Nation

[Original Comment ID: 212014]