Clean Air Council Submission…

Clean Air Council Submission to EBR Posting 013-1520

The Clean Air Council (CAC) is a network of 28 municipalities and health units from across the Greater Toronto, Hamilton and Southwestern Ontario Area who collaboratively work on the development and implementation of clean air and climate change mitigation and adaptation actions. The CAC is proud to have the Province of Ontario as a CAC member. While the CAC commends meaningful consultation, and stresses the importance of engaging municipalities around Ontario’s forthcoming Approach to Climate Change Adaptation, we feel that unlike past consultation exercises (Climate Change Action Plan and Climate Ready for example), limited information and considerable ambiguity exists around the Approach at present.

While the CAC is pleased to provide eleven recommendations across the four thematic areas identified in the Approach, we would welcome the opportunity to provide more detailed feedback through a more thorough consultation process. As such, we invite the Ministry of the Environment and Climate Change to join a workshop we will convene at a future date where we can learn more about the Approach and provide more substantial commentary to the Ministry.

RE: Creation of a new climate change organization

CAC members strongly support the creation of a new climate change organization and feel that a not-for-profit provincial agency tasked with building adaptive capacity across all segments of society is required. While a one-window source for leading-edge climate projection data and adaptation information is certainly needed, it is our understanding that a similar one-window source is being considered federally through the Canadian Centre for Climate Services (CCCS).

CAC members strongly agree that climate information is not always easy to find, understand or use. Even well-resourced municipalities and public health units struggle to interpret this information internally, often relying on external organizations and private consultants to aide in data interpretation and operationalization at a considerable cost.

While we understand that the organization will work with decision-makers in communities, private businesses, and government to facilitate adaptation learning and capacity building, what CAC members would like to see is a service where this data is downscaled and interpreted for Ontario municipalities and public health units, presented in formats that are understandable and can be operationalized by municipal staff across a range of municipal service areas. We would also be happy to receive a statement of principles through which the organization will operate, and to better understand how the organization will address the dearth of funding available for municipalities and public health units to implement the adaptation measures they are planning.

As the Ministry is no doubt aware, Conservation Ontario, and Ontario’s 36 Conservation Authorities possess a wealth of experience and data pertaining to climate change adaptation in Ontario’s watersheds. We strongly recommend working with Conservation Authorities and other partners to avoid duplication, harnessing their existing expertise and information. The ability for municipalities to dedicate staff to be trained on use of climate data, risk assessment processes and adaptation planning is contingent on available staff resources. For most Ontario municipalities and public health units, there are no available staff to be trained in these areas. We do not recommend training for staff and instead recommend that the Organization place a priority focus on providing services related to risk assessments and climate data interpretation. Training can complement that service where only staff resources exist to put that training into action.

Recommendation #1: CAC members would like to recommend that Ontario work with CCCS and other agencies to ensure complementary service offerings and to avoid duplication or competing offerings of similar services.

Recommendation #2: CAC members recommend the provision of data interpretation reporting and services as opposed to the provision of data alone.

Recommendation #3: CAC members recommend that the organization prioritize conducting climate risk assessments for municipalities and public health units as opposed to training a municipal staff on how to conduct risk assessments.

Recommendation #4: CAC members recommend that the new climate adaptation organization should have a mandate to develop mechanisms for a sustainably funded set of regional adaptation collaboratives across connected jurisdictions in Ontario. These regional collaboratives should consider municipalities and public health units as founding members, where tertiary members could be other government, infrastructure and business interests.

Recommendation #5: CAC members recommend that the organization review and report on the implementation of the Climate Ready Adaptation Strategy and Action Plan.

Recommendation #6: To avoid duplication, harnessing existing expertise and information, CAC members recommend that the organization work with Conservation Ontario, Ontario’s 36 Conservation Authorities and other organizations working on climate change adaptation in Ontario.

RE: Provincial climate change risk assessment

Regarding the notion of a province wide risk assessment of the effects of climate change, while it is essential to understand the current and potential effects of climate change, vulnerabilities to those effects, and the resultant risks, we question the validity of conducting such an assessment at a provincial scale. While such an assessment is essential for the Province of Ontario (as a government entity) to undertake for its assets and operations, conducting risk assessments at this scale has minimal relevance and limited potential operationalization for lower orders of government and non-government actors.

We observe the importance of recognizing sub-regional approaches to risk assessments within the province, based on geographical conurbations. Many regions internationally are pursuing regional approaches to mitigating and adapting to climate change. Regional governance structures have been shown to advance climate change action at the metropolitan or regional levels. Ontario’s urban agglomerations are unique in terms of regional governance and planning around climate change. No regional structures exist as a result of legislative mandates, historical developments, and institutional capacities. Key challenges to adaptation at the regional level include 1) engaging municipalities with fewer resources and/or a lower political commitment to climate change, and 2) lack of authority and/or mandate to effect change.

CAC members feel that due to the inherently interconnected nature of our connected urban areas, regional risk assessments should be considered in addition to province-wide assessments. Of particular importance, is how we define the term regional. Where previous federally run adaptation collaboratives applied a regional approach, ‘region’ in this sense entailed groupings of one or more provinces. We feel regional approaches should be limited to considerably smaller geographies, perhaps not dissimilar to how Statistics Canada defines Ontario’s 35 Economic Regions, for example. Regardless of regional delineation, it is essential that any risk assessment undertaken has the ability to be integrated into existing and future risk assessments being undertaken by Ontario municipalities.

Recommendation #7: CAC members recommend that any Provincial-scale risk assessments allow for integration with risk assessments undertaken by other orders of government, including those that are ad-hoc in nature, and those mandated under the Emergency Management and Civil Protection Act.

Recommendation #8: CAC members recommend the consideration of regional risk assessments within the overall risk assessment framework, especially for inter-jurisdictional infrastructure and risks.

RE: A whole-of-government approach

We strongly support the development of a more strategic and coordinated whole-of-government approach to managing climate change risks, incorporating climate change considerations into government ministries and agencies. This is an area where municipal, provincial and federal governments have struggled over the past decade. For too long, climate change adaptation has been a stand-alone environmental consideration as opposed to a mainstreamed financial and risk-management consideration.

Recommendation #9: CAC members support and whole-of-government approach to climate risk management and provincial policy integration. Given the essential role of municipal government in managing climate risk and policy integration , we ask that any such approach include a transferability framework for municipal implementation of this approach.

Recommendation #10: CAC members would like to ensure, that any whole-of-government approach includes a holistic review of related provincial legislation, policy frameworks and guidance to identify and mitigate potential conflicting directions for municipalities.

RE: Raising public awareness

CAC members concur that it is essential that Ontario residents gain a real understanding of how a changing climate will affect us. We feel that there are important partnerships required here in the creation and dissemination of appropriate messaging through appropriate media. We feel the role of insurance companies here has been inadequately tapped over the past decade. Our community members are already paying for climate change through their insurance premiums, but many are unaware of this. Liaising closely with insurers in disseminating how climate change is affecting us all could build important connections with our community members. We also feel there are a range of actors who are possibly better suited to developing and delivering this message, including, but not limited to: school boards, Ontario Science Centre, Science North, Ontario Arts Council and Royal Ontario Museum for example.

Recommendation #11: Understanding the complexity of this task, CAC members recommend the use of medium-appropriate synergistic partnerships in the creation and dissemination of all messaging.

[Original Comment ID: 212087]