Dear Ms. Anderson,…

Dear Ms. Anderson,

Thank you very much for the opportunity to comment on EBR #013-1634 – Developing a Voluntary Carbon Offsets program for Ontario. OPG supports the province’s approach to recognizing “beyond carbon benefits” of projects. This can provide economic incentives to invest in green projects, enable organizations to go towards a “carbon-neutral” goal at decreased cost, and simultaneously help to build natural capital that provide ecosystem services.

OPG manages its sites in a manner that strives to maintain, or enhance where it makes business sense, significant natural areas and associated species of concern. OPG also works with its community partners to support regional ecosystems and biodiversity through science based-habitat stewardship; it is strategically focused on funding efforts that contribute to the protection and restoration of a natural heritage system of habitat cores, and corridors across Ontario. With this in mind, OPG offers the comments below.

Stakeholder Consultation in Protocol Development
The development of voluntary carbon offsets protocols needs to commit to adequate input from all stakeholders sessions, similar to the process for compliance protocols. This will ensure transparency of the process, and practicality of the protocols.

Recognition of and alignment with other government programs and priorities
A voluntary offsets program should align with and recognize the ecosystem values managed under other provincial / federal priorities and strategies that have ecosystem co-benefits. Some of these may include the Biodiversity Strategy, Pollinator Health Action Plan, Invasive Species Strategic Plan, species and habitat conservation in general (i.e. wetlands, Great Lakes, etc), and the Environmental Farm Plan. For example, Ontario is developing a Wetland Strategy which discusses the potential for wetland banking. It is recommended that the voluntary offsets program consider habitat banking as an ecosystem co-benefit (i.e. fisheries, species at risk, etc.).

Project types priorities should include wetlands, forests and grasslands
It is positive that the discussion paper recognizes wetland restoration and conservation, and forests. However, grasslands were not discussed in the document. It is recommended that grasslands be included since they are effective carbon sequesters, and provide an essential ecosystem service. Unlike the current draft compliance protocol approach for grasslands, grassland projects should not be limited to “avoided conversion” only but should also include new grassland habitats.

Aggregation and Statistical Sampling
Aggregation must be allowed for as it helps bring to market projects that would typically be too small and uneconomic on their own. Maximizing the number of eligible projects helps to develop a larger volume of offsets at lower cost. OPG recommends statistical sampling of sites instead because it is an effective approach that can minimize transactional costs for small producers while ensuring the offsets maintain their environmental integrity.

Regards,

Tammy Wong

[Original Comment ID: 212017]