OFA provides comments to the Ministry of Energy regarding the development of a Clean Energy Credit Registry under the Electricity Act. OFA recommends that the Clean Energy Credit (CEC) includes all clean, net-zero sources of energy on the list of eligible power generation types. As supporters of agricultural-feedstock production of biogas and conversion to renewable natural gas (RNG), and to be consistent with the proposed CEC treatment of landfill gas, RNG-fed power production should be eligible to generate CECs. Further, OFA recommends accommodating smaller increments than 1MW to ensure Ontario continues to build a broad range smaller scale generation. CEC markets should encourage investment in new non-emitting generation, especially in demand constrained areas throughout Ontario. To ensure continual grid decarbonization OFA supports including additionality measures to achieve emissions reductions that would not otherwise occur. Further, OFA supports a CEC framework and design that considers which parties are responsible for the cost to administer certification of CECs, to ensure CEC purchases are valid. OFA recommends that CEC design in consultation with the Federal Government to ensure compatibility with Canada’s proposed Clean Electricity Standard design, and compliance with any Federal net-zero electricity grid mandate or requirements for a provincial backstop. While the development of the voluntary clean energy credit (CEC) market and registry are in the early stages, considering the timelines imposed on the IESO, OFA supports ongoing consultation while the IESO prepares the framework, principles, and design of the CEC Registry.