Kirsten Corrigal…

Kirsten Corrigal

Ministry of Natural Resources and Forestry

70 Foster Drive

Suite 400

Sault Ste Marie Ontario

P6A6V5

RE: EBR Registry Number 012-8685, Ontario’s Crown Forests: Opportunities to Enhance Carbon Storage? A Discussion Paper

Dear Ms. Corrigal:

Thank you for the opportunity to comment on EBR Registry Number 012-8685, Ontario’s Crown Forests: Opportunities to Enhance Carbon Storage? A Discussion Paper.

The Ontario Forest Industries Association (OFIA) believes that Ontario’s forest sector can play an important and positive role in Ontario’s Climate Change Strategy. Within the Discussion Paper, OFIA was pleased to see an introduction to Ontario’s rigorous sustainable forest management standards, the strong track record of the forest sector in reducing emissions, and the critical importance of a healthy wood products market when accounting for and reducing emissions.

However, given the existing world-class standard of Ontario’s forest management program, it is critical that the Crown forest is recognized as already being a major contributor to greenhouse gas (GHG) emission reductions and carbon sequestration. While the Western Climate Initiative (WCI) requires reductions and removals that are beyond business as usual, there should be some recognition of the existing framework and the good work that has been done through the Crown Forest Sustainability Act (CFSA).

Although the scope of this project is limited to improving the Ministry of Natural Resources and Forestry’s (MNRF) understanding of the role of managed Crown forests in mitigating climate change, it has encouraged a dialogue that spans multiple policies and Ministries. Ongoing questions include:

 How will MNRF’s reconcile potentially conflicting Acts and regulations such as the Endangered Species Act and the Wildland Fire Management Strategy with the forest carbon policy?  What is the current state of legal ownership of carbon emissions and offsets on managed Crown forests?  How will the province reconcile emissions generated through unmanaged parks and protected areas?  Will carbon be viewed as another competing value on the landscape?

The OFIA has also noted that the MNRF’s timeline for the development of the new Policy extends into 2020 which is the end of the first Cap and Trade compliance period. As a result, there will be no opportunities for the province or the regulated community to take advantage of this significant GHG reduction and mitigation option during the first phase of the Cap and Trade program.

There is difficulty in deciding between two policy options (government-led approach versus the market-driven approach) so early in the process and without a clear understanding of how offset development protocols will interface with existing forest management direction. However, we would caution the creation of blanket carbon targets within the existing forest management planning framework given existing complexities and challenges of balancing multiple environmental, social, and economic values on the landscape. As stated in the discussion paper, one of the policy goals of the development process is to manage Crown forests to optimize mitigation potential while balancing multiple forest objectives and values (e.g. biodiversity, fish and wildlife habitat, watersheds, cultural heritage, flow of economic benefits from the forest).

One of MNRF’s goals in this project is to provide an “opportunity for meaningful engagement in the forest carbon policy development process by Indigenous communities and organizations, stakeholders and the public.” We believe that the best solutions are usually achieved when knowledgeable people from all parties work together and develop shared outcomes and solutions.

We see the Discussion Paper as a good first step in an ongoing process and we are looking forward to constructive communication and collaboration on this important file.

Sincerely,

Ian Dunn, M.F.C., R.P.F.

Director of Forest Policy

Ontario Forest Industries Association

[Original Comment ID: 207905]