Dear Ms. Corrigal,…

Dear Ms. Corrigal,

Re: Ontario’s Crown Forests: Opportunities to Enhance Carbon Storage? A Discussion Paper

On behalf of Forests Ontario, we applaud the Ministry of Natural Resources and Forestry’s (MNRF) commitment to understanding the role of crown forests, and the policies to be developed to inform the creation of Ontario and Quebec’s Cap & Trade Program. Forests Ontario is glad to offer comments on the discussion paper which will act as a communications tool for the general public.

1.In regards to the Ontario’s Crown Forests: Opportunities to Enhance Carbon Storage? A Discussion Paper (EBR 012-8685) there are a number of items that Forests Ontario would like to comment upon:

a.On page four of the document in the text box, it discusses the reduction of emissions as it relates to the pulp and paper industry. Care should be taken as much of this reduction can be attributed to the decline in the pulp and paper industry in Canada in 2000, which can be attributed to the value of the Canadian dollar at the time and the increased use of the internet and electronic billing.

b.On page seven within the text box it states the number of jobs that forest products sector supports. Forests Ontario encourages the province of Ontario to also include the number of jobs that the forest industry supports as well as other values the forest industry provides our economy. Forests Ontario’s #ItTakesAForest campaign communicates the sustainability of Ontario’s Forest Industry which is often misunderstood by Ontario’s urban dwellers. Forests Ontario would be glad to provide additional information to be included as well as a link for people to learn more about the sustainability of our forest industry ittakesaforest.ca

c.On page eight, paragraph two- This information provided would have a greater impact if supported by a reference. This is a message that Forests Ontario would be glad to propagate as long as there was a scientific reference for this statement.

d.In addition to comment b (above), on page eight paragraph three- Forests Ontario supports this messaging through our #ItTakesAForest campaign as well as with our partnership with Ontario Wood. It should be clear that these are programs that can provide further information and resources for the public on how they can take part either by understanding or by purchasing products grown in Ontario.

e.On page 11, as it pertains to the forest carbon policy project, Forests Ontario’s #ItTakesAForest campaign provides an ideal platform to provide updates as it relates to a developing a crown forest policy project that supports Ontario’s Climate Change Strategy and goals. Ultimately, by being transparent through the development of this project and the Cap and Trade Program, the forest industry will receive a greater positive response as the general public will be informed during the develop rather than after development.

f.On page 13 under Forest Carbon Management (a government-led approach), paragraph 6 it is stated that forest carbon management strategies could reduce opportunities for forest carbon offset projects. It is important to note that offset creation is a method by which people can generate offset projects (according to the various protocols) which will enter into market as a means for companies to offset their emissions overages (those that exceed their cap). This, for those who have been involved in the Cap & Trade discussions, could be a temporary vector until the company is able to reduce emissions through investment in infrastructure or other. This is also the case for the forest industry, however there may still be companies that do not invest in emissions reductions projects and therefore may require offsets. This statement made in this document is too general and may be misleading as organizations and companies working towards the development of offset protocols and projects.

2.Further comments on the Your Views on Policy Approaches on page 16:

1.Ontario’s crown forests are of utmost importance as it relates to Ontario’s emissions reductions. That is, those emissions reductions that exceed the baseline established. Additionally it is imperative that the provincial government clearly communicates who will maintain ownership over those carbon credits and the distribution of funding therein. It will be important in the coming weeks to determine the value of carbon that exceeds the baseline to observe the level of impact that carbon value will have on local stakeholders including Indigenous organizations and stakeholders, communities and industry members.

Discussions will be challenging without this understanding and may be misleading for those who believe they will be positively impacted by the Cap & Trade program.

2.Currently missing is the establishment of a baseline and the development of a forest management protocol. Establishing a baseline will inform the decision to enter into market while the development of Ontario protocols will inform who can be involved and how the industry may have to adapt to such protocols. Additionally, as it relates to carbon management of offset creation, is there not an option to combine these two methods if a stakeholder is unable to meet one or another.

3.

a.Forests Ontario’s interests are related to private land offset creation as well as the impact of a crown forest carbon management approach as Forests Ontario’s mandate is to increase awareness of the high standards of Ontario’s forest management regime. Additionally, if the forest industry is able to make a substantial contribution to Ontario’s emission reductions, this is a story that the public should be made aware of and the positive profile of the industry can be highlighted. Forests Ontario maintains its mandate to be the voice of Ontario’s Forests and will continue to incorporate messaging as it relates to climate change and the developing carbon market. b.

c.Challenges Ontario should explore further are the impacts that carbon storage will have to wood supply, marketability of products, the long term storage of carbon in wood products within Ontario and the additional job creation that this might provide for communities in the Area of the Undertaking. Additionally, methods for monitoring at this large scale should be considered as this could be financially significant. Another item to account for is the impacts that crown forest carbon offsets may have on the generation of public offset creation in southern Ontario, this should be explored further.

d.Developing a policy for managed crown forests needs to take priority prior to the development of protocols however care should be made when making this decision. Both options must be considered in detail including the implications that the policy would have those listed in two. (b).

e.Involvement of government in verification, submission, ownership etc. will impact the marketability of the product if a product is going to be marketed.

f.This is dependent upon what policy the MNRF decides to move forward with. At this time, this is challenging to determine without consultation and without experience.

g.Managing crown forests for carbon sequestration would increase the generation of offsets in other parts of the province including those in southern Ontario. If the decision was towards offset generation, MNRF would be restricted solely to crown forests for the generation of offsets as they are not comparable to those that could be created in southern Ontario

h.The government should maintain transparency and has a number of public platforms like Ontario Wood, #ItTakesAForest campaign, Forests Ontario and Ontario Forest Industry Association to communicate the development of the policy and protocol. Transparency during the development of the policy will be effective, not just after decisions have been made.

i.Absolutely, there could be major impacts on pulp and lumber production, on wildlife habitat and the protection of species at risk, all of these aspects need to be considered prior to the policy decision and can be avoided during this assessment period

6.If crown forests move towards a policy for offset creation, it could in fact (depending upon the analysis of the carbon sequestration above baseline) be the largest offset generator in the province.

Forests Ontario has a mandate to be the voice of Ontario’s forests, dedicated to make Ontario’s forests greener. Our forest establishment programs, extensive public education programs and our skills in public awareness and outreach bring our vision for healthy forests to a new generation of Ontario stewards. Forests Ontario feels very strongly that Ontario should improve its understanding the ability of crown forests to sequester carbon which will be beneficial not only for provincial, municipal and corporate bodies but also lead to an increased understanding for Ontario’s private landowners.

Forests Ontario has the experience and diverse network of partners to communicate many of these decisions and the impact they have on Ontario’s forests. We also have the ability to address any challenges related to the practicality of applying this Offset regulations and have expertise in communications. We look forward to the outcomes of the decision.

Sincerely,

Kerry McLaven, M.F.C. HBSc

Forest Program Manager, Forests Ontario

[Original Comment ID: 207882]