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Comments on Ontario's Climate Change Action Plan

In June 2016, Ontario’s Minister of the Environment and Climate Change released Ontario's Climate Change Action Plan. This five-year plan outlines how the Government and its partners will fight climate change and is focused actions to reduce greenhouse gases (mitigation) and help move Ontario towards a low-carbon economy.

One of the actions in the Plan focuses on the role of land to reduce emissions. For example, trees and plants absorb carbon dioxide, a key greenhouse gas, and stores it in plant material, thereby reducing the amount of carbon in the atmosphere. Ontario wants to ensure that it manages the land sustainably and to enhance the removal and storage of carbon. Ultimately, the Province wants “sell” the carbon the land can sequester as carbon offsets within the cap and trade market it is developing with partner programs in Quebec, Manitoba, and California.

A key element of being able to consider carbon in this way is to understand how Ontario’s managed and unmanaged (or natural) lands actually emit and store carbon. In the Plan, Ontario commits to:

·        Developing a Land Use Carbon Inventory, to allow Ontario to assess the potential of agriculture, forestry, wetlands and grasslands to emit, remove and store carbon.

·        Developing a Forest Carbon Policy Framework, to clarify the role ofmanaged Crown forests in storing carbon.

In November 2016, the Ministry of Natural Resources and Forestry (MNRF) released a discussion paper outlining how they might approach a Forest Carbon Policy Framework; MNRF manages approximately 271,000 km2 of Crown forests in the Area of Undertaking. The paper describes the state of MNRF’s current knowledge and level of scientific understanding about the role of carbon within Ontario’s managed Crown forests and then applies this to consider the climate change mitigation opportunities within Ontario’s current approach to forest management. Ontario will develop policy on forest carbon management and/or carbon offset projects for the forestry sector while exploring the potential benefits with Indigenous peoples.

WCS Canada scientists could not support either approach at this stage. Our main concern remains the lack of detail about the science underpinning these approaches. There is uncertainty among scientists about whether climate change can be mitigated by increasing carbon through forest management practices in the boreal. Finally, the narrow focus on forests managed for timber ignores the positive and negative contributions of unmanaged forests and systems, particularly the carbon-rich ecosystems such as wetlands and peatlands in the Far North. We offered five recommendations including:

1.      Develop a discussion paper that integrates known carbon science across all forested lands in Ontario (unmanaged and managed) and be more transparent about assumptions and uncertainties around various carbon modeling approaches.

2.      Prioritize the completion of the carbon land use inventory, including enabling an independent third party review of the approach and methods.

3.      Develop a comprehensive carbon policy that considers all sources of carbon in the province as an action item in the Climate Change Action Plan and support efforts for mitigation and adaptation.

4.      Strengthen the climate change components of the yet-to-be-released Far North Land Use and Wetland Conservation Strategies.

5.      Develop tools that can guide land use planning in the Far North at multiple scales and measure progress on the addressing climate change, including carbon processes and functions, as mandated by Objective 3 of the Far North Act, 2010.

Read our full comments here.

While the official comment period for the Discussion Paper is closed, you can still provide comments to MNRF at forestcarbon@ontario.ca

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