Submission to the Public Comment Period for the Federal Government’s Draft Greenhouse Gas Offset Credit System Regulations
This brief technical submission to Environment and Climate Change Canada (ECCC) should be read in conjunction with the NFU’s longer document, A Critical Analysis of Greenhouse Gas Offset Schemes and Draft Offset Credit System Regulations, which provides background, context, and citations.
In response to the draft Regulations for the Federal Government’s proposed Greenhouse Gas Offset Credit System (1) published March 6th, 2021, the NFU recommends:
1. For at least the next two decades, shelve offset credit systems and emissions trading (though not the carbon levy) and instead focus on actually reducing fossil fuel combustion and emissions. According to the Oxford Principles (2) and other expert analyses, offset systems should not be first-line measures. Instead, offsets should only be deployed after we achieve deep reductions in actual greenhouse gas (GHG) emissions. (See section 6 in A Critical Analysis of Greenhouse Gas Offset Schemes and Draft Offset Credit System Regulations.)
2. Do not use projects or credits to offset fossil fuel emissions—which should instead be rapidly reduced, and can be, using mature and affordable technologies. Rather, use protocols, projects, and credits solely to offset truly irreducible portions of emissions (see section 6).
3. Retain a strong commitment to the principle of additionality.
4. Retain rigorous, long-term requirements for monitoring and reporting.
5. Do not allow cross-border credit trading or out-of-country offset projects.
6. Acknowledge that soil carbon offsets are essentially unworkable, for these reasons:
a. Soil sequestration is not permanent, especially in a warming climate. In contrast, fossil carbon releases are essentially permanent and thus cannot be equated to, or offset by, temporary sequestration in actively cycling biological carbon pools (see section 3).
b. Soil sequestration potential is too limited to offset fossil fuel emissions (section 2).
c. Requirements for 100 to 200 years of monitoring and reporting are unrealistic; few farming practices, companies, monitoring programs, or laws last that long. Moreover, such requirements may create long-term unlimited liabilities for farmers, contractual entanglements, land title encumbrances, and other forms of lock-in and risk (section 3).
7. Provide programs and financial support to help farmers to reduce actual emissions from agriculture so we can make our rightful contribution to overall reductions. Farmers who grasp climate change realities want to reduce their own emissions, not offset excess or continuing emissions of others.
8. Work with farmers and Agriculture and Agri-Food Canada (AAFC) to develop publicly funded programs to support and incentivize soil enhancement and protection (section 8).
About the National Farmers Union.
Founded in 1969 by an Act of the Federal Parliament, the NFU represents thousands of farmers in every Canadian province and two territories. NFU member farms range from among the largest to the smallest, employ a wide range of production practices, and produce nearly every imaginable farm product. The NFU works to advance and implement policy solutions that lead to a more stable, prosperous, just, sustainable, and nutritious food system for all Canadians.
Respectfully submitted by the National Farmers Union, May 4th, 2021
1 Government of Canada, “Greenhouse Gas Offset Credit System Regulations (Canada),” in Canada Gazette, Part I, vol. 155, 2021, 966–1018, https://canadagazette.gc.ca/rp-pr/p1/2021/2021-03-06/pdf/g1-15510.pdf.
2 Myles Allen et al., “The Oxford Principles for Net Zero Aligned Carbon Offsetting” (Oxford: University of Oxford, 2020).