The Canadian Environmental…

The Canadian Environmental Law Association (CELA) welcomes the development of a forest management policy that seeks to address both climate change mitigation and adaptation issues. The prompt reduction of greenhouse gasses (GHGs) in the atmosphere is important not just to ensure Ontario meets its GHG reduction targets legislated under the Climate Change Mitigation and Low-carbon Economy Act, but also to fulfill Canada’s global commitments.

Adding a consideration of carbon sequestration to the existing objectives and targets that must be considered as part of forest management plans would be an effective first step. The potential of Crown forests to mitigate GHG emissions must be evaluated on a full life cycle assessment basis. This includes all emissions, from fuels and infrastructure needed to access the forests, to the disposal of wood products at the end of their life. The mitigation potential of using wood chips and other residue materials as biomas must be compared to other practicable low-emissions alternatives, not to the most emission-intensive options.

The Discussion Paper does not provide enough details to evaluate the two policy options. For example, how will the policy objective of mitigating GHGs be balanced with other forestry objectives, including protecting wildlife habitat, species at risk, and timber harvesting goals? How will the environmental impacts of potential carbon offset projects be evaluated and addressed? Given that the forest management carbon offset protocol has yet to be developed, and it is unclear what range of forest management activities it will cover, we are unable to comment further, and reserve the right to do so when more information about both policy options is available.

[Original Comment ID: 207910]