Response to Regulations under Bill 172

Executive Summary

  • The OFVGA strongly takes the position that Ontario should be vigorously pursuing offsets from the agriculture and forestry sectors.
  • Orchard management offers a scientifically valid and credible source for offsets.
  • Use of conservation agricultural practices can result in net carbon sequestration and, should be considered for offsets.
  • Members of the OFVGA, through adoption of net carbon sequestration activities, should be credited through the ability to sell offsets.

The OFVGA has reviewed the Ontario regulation proposed for Bill 172:, The Climate Change Mitigation and Low-carbon Economy Act (2016), with the objective of understanding the direct and indirect impact on the edible horticultural sector. It is recognized that the major component of these regulations is designed around the calculation and allocation of allowances and credits (offsets), followed by their subsequent sale and trading.

Members of the OFVGA are strongly committed to providing safe and sustainable food to the consumer in a competitive manner.  It is in the best interests of both producers and consumers that healthy food be produced and delivered in the most efficient manner possible and in a way that makes the production of these products competitive in Ontario.  It is with this in mind that the OFVGA is providing feedback on the regulations associated with Bill 172.

The OFVGA is going on record with this submission to state that the edible horticultural industry and other components of the agricultural industry MUST be included in the determination of available and acceptable offsets for carbon sequestration and storage.  The OFVGA firmly states that many of its member’s production practices result in the long-term capture and storage of carbon.  Members of the OFVGA are subject to the costs associated with Cap and Trade through gasoline (4.3 cents per L), and natural gas and propane (3.3 cents / cubic meter) taxes.  They must also be given credit for the capture and sequestration that occurs on their farms that can then be used to offset the additional costs paid through the above products. Incentivizing growers to continue these practices is the reason OFVGA is insisting that offsets be applied to horticultural production.

Orchard Management
Orchards are in production for many years before they are profitable.  In Ontario, tender fruit (apricots, peaches, plums, and pears) and apples represent a sustainable, significant, and secure food supply to Ontario consumers.  Orchards metabolize CO2 through the carbon cycle, resulting in storage of carbon in the roots, tree, and fruit.  Sustainably-managed orchards have been proven to be substantial carbon sinks (see Xiloyannis et al., 2014).  Increasing soil organic carbon (SOC) through sustainable methods can not only benefit production, but also enhance soil quality and carbon capture. 

“In sustainable agro-forestry systems, management practices are able to increase carbon inputs into soil and possibly reduce GHGs emissions due to some revised field operations (e.g. irrigation, pest and disease, fertilization, soil and plant management). Carbon enrichment increases biological activities by changing (improving) soil structure as well as the soil moisture and nutrient contents which are beneficial to plant growth and production.”  (Xiloyannis et al., 2014)

It also enhances the soil hydrological properties (soil porosity, soil water infiltration rate, water retention and soil structure. New York work with apples indicates that use of mulches in orchards results in significantly higher carbon storage in the soil and in the tree biomass (Leinfelder et al., 2010).

Therefore, orchard production should be considered for offset potential.

Conservation Agriculture
In Canada and the United States, it has been stated that no-tillage cropping can sequester an average of 0.33 Mg Carbon/Hectare/Year (Franzluebbers and Follet, 2005).  Further, estimates of soil organic carbon sequestration under no-tillage without cover crops in the southern United States are 0.28 Mg Carbon/Hectare/Year, but when a cover crop is applied the estimate increases to 0.53 Mg Carbon/Hectare/Year (Franzluebbers, 2005).  Tillage is considered an abiotic disturbance.  Use of conservation agriculture no-tillage regimes reduces carbon emissions and increases carbon sequestration (Lal, 2004) resulting in less soil erosion and run off (a further environmental benefit – Seta et al. 1993).  Carbon sequestration rates are also higher when farmers use crop rotations and no-tillage systems (Gonzales-Sanchez et al. 2012).  Soil organic carbon can be sequestered with adoption of conservation agriculture practices such as:

  • Enhanced soil fertility and soil quality
  • Mitigation of greenhouse gas emissions
  • Soil surface change is most notable
  • Long-term changes are most scientifically defensible

In the scientific literature, there are suggestions that for horticulture, limited research suggests promising uses of cover crops for promoting increased soil C storage in vegetable and vineyard systems (Morgan et al., 2010).  These arguments could also include orchards, pasture, grasslands and buffets and grass waterways, bee habitat and many other related use patterns.

Any horticultural system that adheres to the above practices should be considered for offset potential.

Carbon Pricing
The OFVGA recognizes the current pricing outlined for carbon. The price of allowances sold at auction would be subject to a floor price of nearly C$14/tonne in 2017, with a concomitant increase by 5 per cent plus CPI in each subsequent year.  The settlement price for credits at the February 2016 joint California-Québec auction was just over C$17.50/tonne.  Members of the OFVGA should be allowed to sell offsets back to the system to assist in the negative impacts of pricing and competitiveness on the Ontario-based horticultural sector imposed by the Cap and Trade initiative, while also continuing to incentivize growers to continue on-farm practices that benefit our environment and encourage the development of new best management practices that go above and beyond the norm.

The OFVGA appreciates the opportunity to comment on the regulations associated with this proposed bill. The OFVGA and its members insist that horticulture’s position in providing a scientifically-based carbon offset program be considered, including orchard and vineyard management, and conservation agriculture.  Further, members of the OFVGA should be encouraged to sell these offsets back to the Cap and Trade system.

To download a copy of the response, please click here.

About the Ontario Fruit and Vegetable Growers’ Association
The OFVGA was established in 1859, which makes it one of Ontario and Canada’s oldest farm commodity organizations.  As the voice of Ontario’s fruit, vegetable, and greenhouse farmers, the OFVGA is a nationally recognized not-for-profit association that advocates on behalf of Ontario fruit and vegetable farmers and the edible horticulture industry, representing its members provincially, nationally, and internationally. 

The sector supports 30,000 farm-based, non-family jobs in Ontario, as well as a further 8,700 jobs specific to horticulture and specialty crops. Over 125 different fruit and vegetable crops are grown in Ontario with an estimated annual farm gate value of $1.74 billion (2014).

Franzluebbers, A.J. 2005  Soil organic carbon sequestration and agricultural greenhouse gas emissions in the southeastern US. Soil Tillage Res. 83:120-147.

Franzluebbers, A.J. and Follett (2005) Greenhouse gas contributions and mitigation potential in agricultural regions of North America. Soil Tillage Res. 83:1-8

Gonzalez-Sanchez, E.J., Ordonez-Fernandez, R, Carbonell-Bojollo, R., Veroz-Gonzalez, O, and Gilribes, J.A. 2012.  Meta-analysis on atmospheric carbon capture in Spain through the use of conservation agriculture. Soil & Tillage Research 122 : 52–60

Lal, R. 2004. Carbon emission from farm operations. Environment International, Volume 30 (7): 981-990

M.M. Leinfelder, M.M., Merwin, I.A. and Brown, M.G. 2010. Soil Health Indicators, Apple Tree Growth, And Carbon Sequestration Differ Among Orchard Groundcover Management Systems. ISHS Acta Horticulturae 938:43

Morgan, J.F, Follett, R.F., Hartwell-Allen Jr., L., Del Grosso, S., Derner, J.D., Dijkstra, F., Fransluebbers, A., Fry, R., Paustian, K., and Schoenberger, M. M.  2010.  Carbon sequestration in agricultural lands of the United States.  J. Soil Water Cons.  65:6-13.

Xiloyannis, C., Montanaro, G., Mininni, A.N. and Dichio, B. 2014.  Carbon capture and soil biological activity in fruit tree orchards.  Green Carbon Conference.  European Conservation Agriculture Federation. Brussels.


Dr. John Kelly
Executive Vice President, OFVGA
105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
519 763 6160 x115

Mark Wales
Section Chair, OFVGA
105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
519 773 6706

Dr. Justine Taylor
Energy and Environment Co-ordinator

Ontario Greenhouse Vegetable Growers
32 Seneca Road
Leamington, Ontario. N8H 5H7
519 326 2604 x205

Brian Gilroy
Section Chair, OFVGA

105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
519 270 3032

George Gilvesy
Board Chair, 
Ontario Greenhouse Vegetable Growers
32 Seneca Road
Leamington, Ontario. N8H 5H7
519 326 2604

Jan Vanderhout
Vice-Chair, OFVGA

105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
905 628 2503

Norm Charbonneau
Director, OFVGA
105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
519 832 5283