Cap-and-trade is a market-based way to cut greenhouse gases that uses economic incentives so that industrial polluters meet emissions reduction targets. Polluters get emission allowances equal to a government cap. If a plant's pollution exceeds the target or cap, it must purchase emission allowances from facilities that have reduced more than their share or else pay fines.

The Pembina Institute suggested: Manitoba move quickly to implement a cap-and-trade system by January 2012, set a cap that aligns with short- and medium-term emissions reduction targets, include all source of measurable emissions, and distribute allowances by auction, and eliminate or reduce any reliance on offsets.

Canadian Parks and Wilderness Society (CPAWS) Manitoba Chapter submitted comments that echo Pembina Institutes concerns, warning about the short-comings of relying on offsets, and arguing that revenue from a carbon pricing scheme should be used to fund GHG reductions, such as investing in carbon storage through ecosystem protection.

The Manitoba Government set up a webpage to collect comments on the proposed Cap and Trade system; however the comments are not being made publicly available on the Government webpage. There is also no public registry for the review.