Give credit where credit is due
APAS’s stance on the province’s Greenhouse Gas Offset Program
"The careful management and stewardship of this land positions Saskatchewan producers as a strategic asset to address climate change."
The Agricultural Producers Association of Saskatchewan (APAS) strongly believes agriculture has a vital role in reducing and mitigating Canada's greenhouse gas (GHG) emissions. However, the agricultural sector needs to be recognized for its current practices that play a critical role in reducing Saskatchewan's and Canada's overall carbon footprint. As Saskatchewan's general farm organization, APAS serves as the voice of thousands of farmers and ranchers who manage over 40% of the cultivated farmland and 35% of total pastureland in Canada. The careful management and stewardship of this land positions Saskatchewan producers as a strategic asset to address climate change. Producer's fields are sequestering carbon through the plants they grow every year. Agricultural soil carbon sequestration is currently the largest source of offsets to carbon emissions, and governments record these offsets in their GHG inventories. Soil carbon sequestration also has the potential for future sequestration. Unfortunately, arbitrary and non-scientific administrative rules on penetration rates will let governments continue taking credit for agricultural emissions offsets in their inventories while agricultural producers will lose their ability to benefit from their carbon offset activities.
Penetration Factors in Agriculture
The proposed regulatory approach would make practices ineligible for offsets disallows once they reach an adoption rate of 40%. This is not science-based and represents a short-sighted and arbitrary administrative decision that would reduce the maximum environmental and economic benefits these practices could achieve.
Aggregators
APAS does not support the use of aggregators, which act as third-party marketers or verifiers, in agricultural offsets because they create minimal administrative value while taking an unreasonable share of proceeds from offset sales. Our members would prefer administration by an independent body with no financial stake in the process, and with no incentive to structure ongoing offset design to favour their interests.
Drafting and Review of Protocols
The creation of draft offset protocols and subsequent protocol reviews should be done at the sector level with stakeholder consultations that involve only those directly involved in the activities.
Proposed Method to Guard Against Reversal
Australia has decided not to discount sequestration to account for removals or reductions. Instead, they offer a portion of the credit value upfront to incentivize the adoption of a practice and then hold the credit balance until the practice is validated and maintained. Some flexibility is also required to account for changing conditions in each growing season that should be included in the offset criteria.
Maximizing Environmental Benefits from Agricultural Practices
Government programs to incentivize farm stewardship should be integrated. For example, carbon offset programs should complement efforts to reduce emissions from reforestation, or wetland retention.
“Agricultural soil carbon sequestration is currently the largest source of offsets to carbon emissions, and governments record these offsets in their GHG inventories.”
