Calgary Chamber submission on the proposed Federal Offset Protocol: Reducing Enteric Methane Emissions from Beef Cattle

February 9, 2024

Environment and Climate Change Canada

On behalf of the Calgary Chamber of Commerce, we welcome the opportunity to provide a formal submission to Environment and Climate Change Canada (ECCC) regarding the draft Federal Offset Protocol: Reducing Enteric Methane Emissions from Beef Cattle. Specifically, we wish to address the exclusion of Alberta's producers from accessing federal protocols due to the existence of a provincial program.

Alberta’s agricultural sector has long recognized the importance of environment stewardship, positioning producers as pioneers of the innovative technologies and products needed to advance decarbonization. In Alberta, producers have been leveraging carbon protocols to continuously reduce emissions, including through protocols such as Reducing Greenhouse Gas Emissions from Fed Cattle and Agricultural Nitrous Oxide Emission Reductions.

Alberta’s abundance of arable land, deep-rooted primary production industry and unique talent pool, has positioned the agriculture and agri-food sector as one of the strongest in North America. In fact, Alberta makes up approximately 70 per cent of Canada’s cattle market.

ECCC's proposed protocols present a valuable opportunity for the cattle sector to mitigate methane emissions, thereby contributing to Canada's climate goals. However, the Province of Alberta's robust provincial program inadvertently excludes certain operators, leaving them unable to access the provincial Quantification Protocol for Reducing Greenhouse Gas Emissions from Fed Cattle. This exclusion arises from several factors:

• Projects under the provincial protocol may expire after 8 years, potentially leaving producers without a provincial option. 
• Not all producers possess carcass weight data, a requirement for the provincial protocols but not for the federal protocols. This discrepancy unfairly hinders eligible producers from accessing provincial benefits. 
• Backgrounding feedlots in Alberta are ineligible for the provincial protocol but could participate in the federal protocol if Alberta's producers were granted access. 

Should Alberta producers be unable to access provincial or federal carbon protocols:

• The cattle sector outside Alberta would gain a competitive advantage. 
• Emissions reductions achieved in Alberta would be excluded from government calculations. 
• Alberta would miss out on funds and resources available to other regions of the country through emissions reductions. 

To address this issue, we propose amending the Canadian Greenhouse Gas Offset Credit System Regulation to allow feedlots ineligible under any relevant provincial offset registry (due to registry-imposed time limits or differing specifications provincially) to participate under the federal protocol. This amendment would eliminate ambiguity for those under a provincial program they cannot utilize and ensure equitable access to federal protocols.

We urge the government to take necessary steps to ensure fair and inclusive access to carbon protocols for all beef cattle producers, including those in Alberta. By doing so, Canada can maximize its emissions reduction potential while fostering a competitive and sustainable cattle sector.

Thank you for considering our input on this important matter.

Yours sincerely,

Deborah Yedlin 

President & CEO 
Calgary Chamber of Commerce 

ABOUT THE CALGARY CHAMBER OF COMMERCE

The Calgary Chamber of Commerce exists to help businesses reach their potential. As the convenor and catalyst for a vibrant, inclusive and prosperous business community, the Chamber works to build strength and resilience among its members and position Calgary as a magnet for talent, diversification and opportunity. As an independent, non-profit, non-partisan organization founded in 1891, we build on our history to serve and advocate for businesses of all sizes, in all sectors across the city.

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