1. Are there additional…

1. Are there additional priorities related to the development of the proposed voluntary
carbon offsets program that have not been considered in this document?

-If the MOECC wishes to have separate offset protocols and programs under a voluntary scheme, it needs to ensure that the voluntary program does limit the suite of protocols available for development and use under the compliance program so as to not diminish opportunities for sizeable projects under compliance.
-To that end, it is important to have the compliance protocols developed and in the public domain before introducing voluntary protocols.
-Given that the goal is to introduce environmental co-benefits, it may be worth crediting not only for carbon but also the additional co-benefits that could arise from a project – whether that be species conservation, habitats, water systems, etc. The simplest way to differentiate programs may be the approach the MOECC takes in crediting actions/results under this program.

2. In addition to the five program objectives listed in this discussion paper (see “Getting
there”), are there other objectives that you think the Ministry should consider?

-Given carbon neutrality is just one of the objectives in this program, it would makes sense to build protocols that clearly focus on the 5 stated objectives, and give ‘credit’ for meeting these objectives. Carbon does not have to be the only currency in this program, given its voluntary nature. Incenting participants to develop projects that create multiple co-benefits for the environment and communities should be the goal here, not simply carbon. This will allow for a more diverse and impactful program that delivers additional value to Ontario beyond the carbon reductions through the compliance program.
-Furthermore, a pragmatically developed program could also attract funding from a much wider array of participants, given the vast number of conservation groups, communities, companies etc that could be further incented to undertake worthwhile programs if there was a platform allowing them to receive credit for doing so.

3. Are there specific barriers to participation in the carbon market that the Ministry should
consider when developing the proposed the Ontario voluntary carbon offsets program?

-First and foremost is a vibrant market with adequate supply and demand. One needs to look no further than the current voluntary market to understand the dynamics of an oversupplied market with insufficient demand. Ontario’s program may well add to the supply glut already in existence. If Ontario is keen to differentiate, then it may well be served to consider a more dynamic platform (as stated above), than one which is driven solely by carbon.
-Current estimates, based on voluntary market knowledge of offset demand within Ontario suggests protocols need not address large scale projects…unless there is the intention of creating a pseudo compliance demand by having municipalities and even provincial government undertake some commitment to participate and meet objectives under this program (like BC’s carbon neutral government). It must be noted, that even with this demand in the compliance market in BC, the voluntary market is very stagnant, as ‘general’ voluntary demand is not robust, so very few new projects are created on an annual basis and very few tonnes are sold annually compared to the compliance market.

-Developers will only participate if there is a market that allows them to put risk capital at play, with the likelihood that it can return a reasonable ROI. Typical carbon offset projects may cost hundreds of thousands of dollars to undertake…so there will be a need for real, robust market to consistently sell offsets into. Otherwise, the risk to develop projects is too great and Ontario will need to rely on philanthropic investments into such programs, which then of course has potential to both limit supply and affect additionality etc (depending on the structure of the program).
-Incenting smaller communities and groups to undertake programs is a valid objective, however, like most carbon programs, the more complicated a project becomes, the more expensive it becomes…so again, the MOECC needs to be keenly aware that their focus on carbon as a primary outcome will limit participation and limit aggregation plays and large land based opportunities.
-If the MOECC remains keen on putting carbon first in their program, then the baseline for protocols should at least be protocols that already exist and have a fungible international market, to allow developers to monetize the credits into a larger market, not just Ontario. The MOECC needs to appreciate that building new protocols and claiming them to be the highest quality will not translate into international demand…as well known protocols already exist. So there needs to be consideration as to the market these offsets will sell into, as the more fungible they are, the more risk mitigation there is for the developer.

4. What is the best way for the Ministry to facilitate community participation in the
proposed Ontario voluntary carbon offsets program?

-Make the program as pragmatic as possible. Having carbon as just one of the possible outcomes allows both the MOECC and the communities to address a wider variety of opportunities and outcomes. Create protocols that incent a variety of outcomes that could receive credits…as stated above. This is voluntary, so cast a wide net and let communities bring you ideas.

5. What environmental co-benefits (e.g., flood management) should be prioritized in the
proposed Ontario voluntary carbon offsets program?

-This list can be as varied as you wish it to be. Speak to the conservation groups, the communities, the people that are already doing impactful projects, but relying on philanthropy to do so. You can give credit for many outcomes…what do the regions within Ontario want to accomplish? Build protocols to achieve those outcomes.

6. What project types should be a priority for the Ontario voluntary carbon offsets
program?

-First we would suggest that project types should be different from those suggested under compliance – they should be more charismatic in their approach to outcomes (as stated above);
-They need to address regional concerns and opportunities;
-They could credit for ex post and ex ante carbon, as well as co-benefits or other outcomes;
-They could possibly be testing grounds for future compliance offsets (if you want carbon specific outcomes).
-Sequestration, specifically restoration and afforestation can be considered, but again, allow for ex ante crediting (or credit for co-benefits therein).
-Sequestration, Avoided emissions and improved management of forest is best left to compliance given scale and where the current compliance market operates.

7. What actions can the Ministry take to support viable end markets for Ontario voluntary
carbon offset credits?

-The MOECC has to build a robust market first and foremost. The underlying theme in your papers is not just carbon, but multiple co-benefits, so build a program that credits for multiple co-benefits. Doing so will create two distinct markets in Ontario - compliance and voluntary, with little overlap/confusion.
-Use accepted and trusted platform to manage and regulate the market…whether those are protocols or registries or auditing firms etc.

8. Are there existing standards or methodologies that you feel the Ministry should
consider when developing requirements for the creation of carbon offsets projects?

-This has been done already by those that have come before you…carve your own path. Make this a co-benefit program that incents folks to do great things and receive recognition for it…not just carbon.
-In order to differentiate the two markets, we recommend that the voluntary program places higher priority on the co-benefits aspects while the compliant market focuses on the carbon reductions and removals required to address climate change.
-Ontario has the opportunity to create a unique and important program to benefit its communities and residents. However, if the voluntary program attempts to replicate the compliant market but for the voluntary space it will not be able to develop the demand required to develop necessary long term projects. Therefore it’s recommended that you focus on the co-benefits and impacts on communities, habitat etc. That's unique.

[Original Comment ID: 212004]