OFA provided comments to the Ministry of the Environment, Conservation and Parks regarding the proposed transition of Ontario’s industrial facilities from the federal Output-Based Pricing System to Ontario’s Emissions Performance Standards (EPS) program. As an alternative to the federal Output-Based Pricing System under the Greenhouse Gas Pollution Pricing Act, the provincial EPS program will have a greater ability to consider the unique characteristics of Ontario’s economy and environment; to consider trade exposure and threats to competitiveness; to assess carbon leakage potentials; and to provide flexibility in regulatory compliance. OFA believes that the creation of compliance units from voluntary carbon emissions reductions or removals to offset the emissions from regulated industrial facilities should be part of the provincial EPS. OFA has long supported the development of an Ontario-made carbon offset system and believe it is a win-win for farmers and for emissions reductions. OFA supported the intention of this proposal to align the scope of Ontario’s EPS program to match the federal OBPS and ensure a rapid and smooth transition. OFA stated its support for the position of the Ontario Greenhouse Vegetable Growers (OGVG) and their request for further discussion on the inclusion of greenhouse production under the Ontario EPS. OFA agreed that this must be done in a manner that is flexible enough to allow participants to choose the methodology that works best for their greenhouse operation.

OFA stated that a price on carbon places is a significant burden on farmers and the food sector, and it is not an effective policy tool to drive down emissions from the agricultural sector. OFA requested further discussion and clarity on how funds accrued from the Ontario EPS program will be returned to the agri-food sector to support further emissions reduction efforts. OFA remains concerned about the future impacts of carbon pricing, especially following the December 18, 2020 announcement by the federal government pledging to increase the price on carbon from the current $30/tonne of CO2 equivalent to $170/tonne by 2030.