Please accept the following…

Please accept the following as my official comments on Bill 4, Cap and Trade Cancellation Act, 2018, posted for consultation as ERO 013-3738. I am writing not only because because we are the first generation facing the consequences of climate change, and we will are the last generation that has any chance of fixing it – but because a competitive economy and robust plan to combat climate change are not mutually exclusive. Finding efficiencies within government does not have to result in the elimination of critical environmental policies and plans.

Thank you for committing to prepare a climate change plan that establishes targets to reduce greenhouse gas emissions in Ontario as outlined on p.2 of the Cap and Trade Cancellation Act, 2018. My comments relate first to the winding down of the cap and trade program, and second, to areas for consideration for the revised climate change plan.

1. Winding Down Cap and Trade:

For the hundreds of organizations that were taking action on climate to reduce our greenhouse gas emissions and contributing to the Ontario economy at the same time - I suggest where these actions were cost-effective and made economical sense, they be given priority for funding in the new climate change plan. Organizations such as Green Economy Canada have a proven method to work with businesses to boost economic productivity and profits while simultaneously reducing greenhouse gas emissions.

What are the business benefits of reducing greenhouse gas emissions?

There are a number of key business benefits that come with reducing implementing sustainability and climate change strategies, including:

- Fostering innovation by changing business models to take the current and future state of the planet into account. Setting targets to reduce GHG emissions can encourage employees to innovate and transform the way they think about doing business.
- Cost savings. In looking for emissions reductions opportunities, businesses can find efficiencies and streamline supply chain logistics. According to the CDP, more than $12.4 billion in cost-savings was reported from emissions reduction projects with their suppliers in 2016. (CDP, 2018)
- It can improve brand reputation. Setting robust emissions targets can help Ontario businesses enhance their reputation by increasing its visibility as a leader in sustainability. This can help a business earn trust with stakeholders who are increasingly demanding business transparency. This includes shareholders, customers, investors and employees.
- Not doing it can lead to business risk. The Global Risks report released by the World Economic Forum highlights the most pressing risks that we face – including societal, economic, technological, environmental and sociopolitical. 3 of the top 5 risks in this report were environmental risks, including natural disasters, failure of climate change mitigation and adaptation and extreme weather events. These are complex challenges, and if they are not addressed, it can create disruptions that can lead to systemic, cumulative and cascading effects for business. (World Economic Forum, 2018).

Giving priority funding to help these businesses reap the benefits of environmental action will not only reduce greenhouse gas emissions for the province, but it will allow these Ontario businesses to remain competitive and boost their bottom line.

2. Areas for Consideration in a Climate Change Plan: Moving forward, any climate change plan must include:

• targets that are science-based and provide meaningful, sustained greenhouse gas reductions;
• carbon pricing in some manner; and
• climate adaptation.

A recent report by the IPCC stated concerns that post alarming risks for ecosystems around the world and the businesses that depend on these ecosystems to succeed. However, it outlines a number of steps forward to keep levels of warming to 1.5 degrees C (summary article at source (8), and summary source (9)).

Targets that are based on scientific fact and involve our most carbon-intensive industries are required to provide meaningful and long-term change for Ontarians. There is limited effectiveness of targets that are unattainable - they must be challenging enough to drive change but be also reachable.

In addition to targets, carbon pricing is the most practical and cost-effective way to lower greenhouse gas emissions while encouraging low-carbon innovation (EcoFiscal Commission, 2018). Cap and trade is highly effective, with practically no impact on the economy (EcoFiscal Commission, 2018). Even if you do not support cap and trade, there are other carbon pricing mechanisms that should be considered.

Finally, any climate change plan must include climate adaptation efforts to prepare us for the impacts. We are seeing the rise of more extreme weather events here in Ontario, whether the 39 wildfires in northern Ontario that decimated tourism and cottages (The Spec, 2018); the recent flooding in Toronto that caused over $80 million in damages (Business Insider, 2018), or the heatwaves that caused emergency room visits to spike by seven times the average in our province (CP24, 2018). If no action is taken, this will threaten future generations’ ability to enjoy a safe climate.

These extreme weather impacts will only worsen for future generations in the years to come if we do not act on climate change now. Taking no or limited action threatens our very prosperity. As an Ontario citizen where climate change has an impact on my life, and influences the decisions I make today such as where I choose to work and whether or not I have children, I need to know my government has a plan that will protect my health and my future. The government must implement a plan as soon as possible that achieves, at minimum, the same results that the Cap and Trade program did. Indeed, you have the power to do even better than the Cap and Trade program, demonstrating that Ontario cares about business and the well-being of its citizens.

Links:

1) https://greeneconomy.ca/
2) https://ecofiscal.ca/carbon-pricing/fast-facts/
3) https://ecofiscal.ca/carbon-pricing/
4) https://www.cdp.net/en/research/global-reports/global-supply-chain-repo…
5) https://www.weforum.org/reports/the-global-risks-report-2018
6) https://www.thespec.com/news-story/8768707-twelve-of-39-northeast-ontar…
7) https://markets.businessinsider.com/news/stocks/toronto-flood-causes-ov…
8) https://www.cp24.com/news/heat-wave-may-be-responsible-for-3-deaths-in-…
9) http://report.ipcc.ch/sr15/pdf/sr15_spm_final.pdf