OFVGA Response: Cap and Trade

Re: Ontario Cap and Trade Program: Offsets Credits Regulatory Proposal (EBR Registry Number: 012-9078)

The Ontario Fruit and Vegetable Growers’ Association (OFVGA) is the umbrella organization for the province’s fruit and vegetable farmers representing 27 different grower groups. OFVGA would like to express its thanks for the opportunity to provide comment on the Ontario Cap and Trade Program: Offsets Credits Regulatory Proposal consultation.

Local food security is important for a sustainable and healthy Ontario. In order to successfully achieve this, farmers and those involved in the edible horticulture sector should be acknowledged for their role in reducing greenhouse gas emissions and be given the opportunity to participate in the system through carbon offsets (i.e. carbon credits). OFVGA would like to present the following comments to support Ontario’s cap and trade program:

Access to carbon credits

OFVGA sees an opportunity in this posting, especially with the mention of early adoption dating back to January 1, 2007. We agree with this approach provided that a broad range of activities that our members (fruit and vegetable farmers) engage in are eligible to be sold as credits. These carbon offsets are needed immediately considering that the cap and trade costs begin January 1, 2017.

The list should include activities that sequester carbon and reduce carbon emissions such as no-till, grass buffers, high efficiently irrigation, plasticulture, and carbon dioxide fixation by greenhouse growers as a few examples. We support the aggregation of activities to ensure that carbon offsets can be easily and economically available to growers. Aggregation makes for an efficient and cost-effective beneficial program for all those involved. Similarly, while not relevant to this consultation, we believe that aggregation of food-producing facilities should also be allowed in the cap and trade program. Aggregation would allow for a level playing field across individual horticultural sectors, most notably greenhouse farming. The current framework places small to medium sized operations at a significant competitive disadvantage to larger facilities that can access free allowances through the cap and trade program. OFVGA believes the importance of food security and sovereignty should be supported through the recognition and support of greenhouse gas reduction activities by Ontario’s fruit and vegetable farmers.