About The Letter:

These comments to Environment and Climate Change Canada (ECCC), developed with Nature Canada and NRDC, on the proposed Greenhouse Gas Offset Credit System Regulations (Canada) focus on (i) general concerns about offsets; (ii) the proposed regulations’ definition of additionality; and (iii) the issuance of offset credits in respect of forest carbon flows. If ECCC believes that forest carbon flows should be covered by offsets rather than by regulated carbon pricing, then we believe it must publish a compelling rationale, including detailed supporting analysis, for why that should be so. In the absence of such a rationale, and as long as the revision of the OBPS Regulations is pending, we believe that it would be premature to proceed with the development of any offset protocols relating to forest carbon.
 


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