CFA submitted its comments the proposed Federal Offset Protocols for reducing manure methane emissions.
In the comments CFA noted some concerns with the protocols, including:
- The criteria for “baseline conditions” exclude existing livestock operations that are already implementing good manure management practices. These criteria exclude and penalize early adopters of such technologies. The protocol should be adapted so that farmers already managing manure are immediately eligible.
- The legal additionality clause of the proposed protocol, which disqualifies GHG reductions from earning credits once they become legally required. Given the complex and variable nature of manure management regulations across provinces and municipalities, the CFA recommends a buffer period be added to allow continued crediting for existing projects, ensuring farmers can recoup their investments.
- The that prevents changes to a project’s geographic boundary after the first reporting period. The CFA recommends allowing some flexibility to accommodate situations like new farms joining an aggregated project or farm acquisitions, which would support broader technology adoption and reduce administrative burdens for future participants.
- There is a need for more clarity and better alignment among the different offset systems and carbon credit markets in Canada.
- The absence of an explicit economic lens in the protocol.