Ontario Crown Forest: …

Ontario Crown Forest: Opportunities to Enhance Carbon Storage

EBR Registration # 012-8685

Having reviewed the above referenced Discussion Paper, attended a public consultation meeting, and participated in the follow-up webinar, I would like to submit the following comments:

In addition to this MNRF consultation on the design options for enhancing carbon storage on Crown land, the provinces of Ontario and Quebec have partnered on a process to adapt existing international carbon offset protocols for use in the cap-and-trade system under the Western Climate Initiative (WCI). The lead contractor in this process is the Climate Action Reserve (CAR) who held a webinar on January 11, 2017 to launch the process. In that webinar CAR outlined that they will be undertaking a twelve month process to review a series of existing international protocols, and to modify them for use under specific provincial conditions. It will therefore be important that these modifications include parameters that are suitable for use in our northern temperate and boreal forest ecosystems. The goal should be to ensure that carbon project developers and/or the Crown can undertake and register high quality carbon offset projects under the WCI in a cost effective manner.

The MNRF Discussion Paper outlined that two policy approaches are being considered: (i) a government led forest carbon management approach, and (ii) a market-driven approach that would enable offset projects on managed Crown forest.

I believe either approach would work, depending on policy objectives, but in both cases I would suggest that the protocols include a process for designing broad, forest-scale mitigation strategies. The rationale is that our northern forests are generally slower growing than the forests most often used in international forest carbon offset projects. Our slower growing forests are, on the one hand a drawback, because they sequester carbon at a slower rate, but on the other hand they are a benefit because they store carbon for a longer period of time. Therefore, it will be important to modify existing forest management protocols that were originally designed for faster growing southern forests, to account for our northern growth and carbon storage rates.

One of the main design factors should be to allow for large forest-scale projects that could aggregate a number of similar project types across the province. This would reduce the high MVR (measure, verify & register) costs associated with each project. For example, the UNFCCC Clean Development Mechanism has outlined an average MVR cost per project of over US $150,000. If each individual project had to incur these high MVR costs, it would make most forest management projects uneconomical in our slower growing boreal forests.

A solution would be to incorporate protocol guidelines that would allow for “Grouped Projects” as in the Verified Carbon Standard, or “Program of Activity (PoA) projects” under the Clean Development Mechanism. These types of projects allow for a single registration that covers a range of similar projects over a wide geographic area. For instance, a forest management practice such as fertilizing, thinning, faster growing trees, enhancement planting, etc. could be proposed and registered for application across the province. Once the project methodology is registered, the specific forest management activity could be undertaken yearly, at different sites, and then one MVR event would take place every 5 years to aggregate the entire group of projects that occurred during the previous 5 years.

This process would allow for a broad project application across the province, with one project design document, and one MVR event that would average the sequestration rates for the aggregated projects. By combining the project design and the MVR cost over a large number of individual projects, you would be able to lower the project development cost significantly and deliver cost effective emission offsets to help Ontario meet its GHG emission targets.

Mark Kean, Mikro-Tek Inc.

[Original Comment ID: 207817]