To whom it may concern, On…

To whom it may concern,
On behalf of Ducks Unlimited Canada (DUC), I am pleased to provide comments regarding ERO number 013-3738: Bill 4, Cap and Trade Cancellation Act, 2018.

Ducks Unlimited Canada conserves wetlands and other natural spaces for waterfowl, wildlife and people. For 80 years, DUC has been Canada’s leader in wetland conservation. Using sound science, DUC works to conserve, restore and manage wetlands through a range of programs that support government, landowners and other partners. In Ontario alone, DUC has conserved almost 1 million acres of wetland and associated habitat in collaboration with landowners, volunteers, and nearly 20,000 supporters.

We are pleased that the Ministry of Environment, Conservation and Parks is proposing in Bill 4 to prepare a new climate change plan to reduce greenhouse gas emissions and achieve greater climate resiliency. We feel that natural systems conservation should be a key part Ontario’s climate change plan.
There are many environmental, economic and social benefits to building climate resiliency via natural systems. Healthy landscapes play a central role in maintaining clean air and water—absorbing and slowly releasing excess water, filtering stormwater and agricultural run-off, cooling the ground and air, and reducing atmospheric carbon and pollutants. Natural systems are valuable resources of ecological goods and services that benefit people, communities and economies.
(Further suggestions on how this natural system approach would work are provided, later in this submission).

With respect to climate mitigation and reducing greenhouse gas emissions, we believe that immediate and substantive action by the Ontario government is required. The urgency of much-needed climate mitigation was emphasized (again) by the Intergovernmental Panel on Climate Change in their October 7-2018 report. Instead of achieving the internationally agreed to goal of limiting the average temperature increase to 1.5 degrees C, the panel said without rapid, unprecedented measures, the world is on track to see double that amount of warming. The panel goes on to say that that level of warming would result in catastrophic impacts on people due to extreme weather and rising seas, a greater rate of species extinction and reduced economic growth.

For that reason, we recommend the new climate plan for Ontario include 1) aggressive targets and timelines for greenhouse gas reductions, and 2) a sound and well-resourced action plan to achieve those targets. While Ontario has made real headway in reducing emissions (eg. via closure of coal-burning generating stations), much work remains to be done.

With respect to bolstering Ontario’s climate resiliency, maintaining and expanding our natural systems and features, including wetlands, forests, grasslands and waterways, will be essential. DUC proposes the following principles to support a natural systems approach to building climate resilience across Ontario.

1. Plan at the landscape scale
We see landscape-level, ecosystem-based planning as a cornerstone of a natural systems approach to climate resiliency. DUC believes that Ontario’s natural systems are best conserved as a whole in order to understand the “big picture” and produce the best outcomes and greatest return on investment for climate resilience.
2. Integrate built and natural infrastructure
DUC sees an immediate opportunity where natural infrastructure complements the role of built infrastructure right from the design and planning stages. Infrastructure investments can make a significant contribution to climate resiliency and will go much further with the inclusion of natural infrastructure to complement built infrastructure functions.
3. Follow a planning hierarchy
The conservation hierarchy—Protect, Mitigate, Restore—is a well-established approach to priority setting for conservation. Much of the province’s policy for natural systems uses this hierarchy to some extent, starting with protection for what we have in terms of healthy habitats and moving up the ladder to reduce damage to habitats and, finally, restoring those we have lost (where possible).
4. Base decisions on evidence
There is excellent research available on the links between natural systems and climate change mitigation and adaptation. This body of knowledge can inform decisions and assist in quantifying the co-benefits of natural systems and the efficacy of wetland functions such as water quality improvement, flood damage protection, and carbon sequestration.
5. Base plans on geographically specific climate projections
Infrastructure planning for the delivery of reliable, cost-effective services by municipalities and the private sector must be based on best-available climate data projections at the regional and local scale. In addition, ongoing mapping exercises by municipalities to identify high flood risk areas could also be used to identify the preferred locations for restoration and creation of additional natural features to reduce the risk of flooding and erosion.

In summary, we need expanded, healthy natural systems to help us mitigate and adapt to a changing climate and associated extreme weather events, which we have seen many instances of in Ontario, in recent months. Ontario also needs immediate, concerted action to continue to reduce greenhouse gas emissions to help mitigate climate change.

Thank you for consideration of these comments.