Dear Ms. Jakobsen:…

Dear Ms. Jakobsen:

Thank you for the opportunity to comment on the Province’s recently posted Approach to Climate Change Adaptation. Few details are publicly available at this point and we look forward to receiving more complete plans when they are complete. The City of Hamilton’s Public Health Services department would like to offer the following comments and recommendations on the EBR posting:

1.Creating a new climate change adaptation organization to help build local adaptation capacity, enhance networks and take action

We support the creation of this organization and are very eager to begin to collaborate on the adaptation planning and implementation work the City of Hamilton is already conducting. Building provincial capacity on adaptation is critical and a vital support for municipalities to successfully build resilience.

Besides wondering how this will be structured, funded, and implemented, we are curious about how this will integrate with mitigation efforts.

While the Province’s cap-and-trade programme necessitates a hard boundary between adaptation and mitigation, in practice, for many municipalities and local organizations, projects and programs will target both mitigation and adaptation outcomes. How these will need to be structured to use provincial funding, and how use of funds will need to be reported on, will need to be laid out clearly and carefully. This should be part of any provincial adaptation organization and program.

As an example, and as you know, Hamilton, in conjunction with the Town of Burlington and Mohawk College, has recently launched the BACCO, a regional collaborative effort to tackle climate change in the Bay Area. The Province has contributed funding to this effort from the Green Fund, which necessitates that it be spend on mitigation efforts. BACCO however will be most effective if it can tackle both mitigation and adaptation and find projects and programs that address both. How this will work in practice with provincial funding, how adaptation efforts should work within this initiative, how funding should be reported on, are all questions we have. Working with and funding such regional initiatives for both mitigation and adaptation would be one way to develop and refine these requirements.

Recommendation A: Clearly lay out requirements for reporting on funds spent for mitigation and adaptation in line with cap-and-trade/Green Fund rules, particularly for projects and programs that target both mitigation and adaptation.

Recommendation B: Lay out separate lines of funding for regional collaborative initiatives targeting adaptation/mitigation and adaptation, such as BACCO.

Municipalities have long taken the lead on public adaptation efforts in Ontario, and will have lessons and experiences that can be used to benefit other municipalities and agencies as the Province scales this effort up. Besides not duplicating the work of existing climate change adaptation organizations (eg. OCCS, GTA CAC, TRCA), providing opportunities for municipalities to share and learn from each other regionally and provincially would be cost-effective and beneficial.

We also wonder how continuity of this organization will be assured following provincial elections. Continuity is essential to tackling climate change adaptation.

Regarding the specific adaptation actions and projects listed on the accompanying website, please consider reaching out to expert panels with more diversity in applied knowledge that can recommend specific recommendations on design and implementation practices. In particular for land use planning and infrastructure, existing planning documents don’t make low impact development and green infrastructure mandatory. They are structured in the form of recommendations and are typically framed around large new developments. Practices should be required for existing development upgrades and public infrastructure. Additionally, parks and open spaces are built form and public assets. Particularly as spaces that can provide opportunities for mitigation strategies and resiliency, they should be considered in policy making and used in all infrastructure language.

Recommendation C: Strengthen the language surrounding the use of land use planning guidelines, and incorporate parks as infrastructure that can help build resilience and adaptive capacity.

2.Work with climate change adaptation experts to undertake a province-wide risk assessment of climate impacts to better understand vulnerabilities and prioritize our actions

We support a province-wide risk assessment but also highly recommend a service where this data is downscaled and interpreted for Ontario municipalities, presented in formats that is understandable and can be operationalized by municipal staff across a range of municipal service areas. We suspect that this initial province-wide risk assessment is intended to be fairly high-level, which may limit its usefulness and applicability at the local level.

We also support including vulnerable populations in this risk assessment. The City of Hamilton’s Public Health Services has already begun reaching out to vulnerable communities within our City to gain their input and insight into adaptation priorities, and we can speak to the necessity and value of this approach. Local Health Units throughout the Province will likely be able to assist in identifying vulnerable populations and taking a health equity approach to climate change adaptation. This should also consider social and environmental priorities; for example, vulnerable populations and critical environmental services.

In order to identify and prioritize actions on climate change it is also important to understand the adaptive capacity of our communities and our systems. We suggest that the provincial climate change risk assessment should also include an assessment of adaptive capacity on top of the proposed assessment of current and future impacts and vulnerabilities in Ontario.

We also believe that this information will need to be packaged in such a way as to ensure its relevance and applicability to the agencies data is being shared with. Highly technical and specialized data may not be used to its best effect otherwise.

Recommendation D: Ensure province-wide risk information is down-scaled enough to be usable by municipalities and other local organizations. Include assessments targeted to impacts for vulnerable populations, using information provided by Local Health Units, including social and environmental priorities. Incorporate adaptive capacity into the risk assessment.

Additionally, we have some concerns on the selected HIRA approach. While discrete crises and emergencies are an important climate change threat and require resources and programs to address them, “creeping” or long-term emergencies and crises are just as important to any risk assessment used to inform adaptation plans. For example, gradual but extreme cost increases in the price of imported foods and the burden this places on low-income households; mental health burdens created by more frequent and unpredictable climate change impacts; impacts to local ecological communities and changes in species from shifting climate norms, and how this affects outdoor businesses and First Nations; adapting older or less-affluent neighbourhoods without air conditioning for hot summers that don’t meet heat emergency thresholds; and so on. None of these would be captured by a HIRA model but all would be important.

Recommendation E: Incorporate “creeping” and long-term climate change impacts into the risk assessment. Avoid focusing solely on short-term crises such as extreme weather events.

3.Developing an enhanced all-of-government approach to climate change adaptation

A whole-of-government approach is absolutely essential and we support this. We are curious to know how this will be structured and how responsibility and accountability will be distributed between Ministries, so we can design and implement our adaptation projects and programs accordingly. Information sharing and program coordination will also be critical at the provincial, federal and local (municipalities, Conservation Authorities, academics, etc.) levels. We also suggest the approach include a transferability framework for municipal implementation of actions.

Recommendation F: Include a transferability framework for municipal and local organizations.

4.Sharing information on the effects of climate change to help Ontario residents better understand the current and future effects of a rapidly changing climate

Public education is worthwhile, but attention needs to be paid to academic research demonstrating that increasing knowledge about climate change impacts often backfires and reduces concern and motivation to act. Educational efforts will need to walk a careful line.

The awareness and education for the community should include how climate change can impact them and how it can be helped or mitigated with examples of what to do and what not to do, what is helpful and what is not helpful in terms of material, uses, and overall expectations (i.e. reduction of irrigation practices).

Financial education and discussions around financial risk with organizations (municipal, large and medium sized industry, accounting and banking institutions) of a changing climate is also important to help reduce risks to the economy and services. We suggest financial risk be considered and incorporated by the Province in education by looking at the Guidelines for the disclosure of climate-related financial risk as developed by the Financial Stability Board; and potential changes to the Public Sector Accounting Guidelines regarding inclusion of green infrastructure as assets under accounting rules.

Recommendation G: Ensure public information is effective, targeted, and includes concrete actions and recommendations.

Recommendation H: Incorporate financial risk into assessments and communications.

We look forward to the next stage of this process and future information regarding concrete and detailed plans for climate change adaptation in the Province of Ontario.

Regards,

Andrea McDowell Project Manager, Air Quality and Climate Change Public Health Services, City of Hamilton

[Original Comment ID: 212086]