The Corporati and expansion…

The Corporati and expansion of corporate emissions reductions strategies is important and valuable to align with Strategic Directions, regulations and responsible environmental practices.

In response to reviewing the proposed Guideline on Community Emissions Reduction Planning, the County wishes to comment on the proposed guidelines to pursue a community-scale emissions reduction initiative, that which encompasses all generated emissions within the jurisdictional boundaries of the County. As an upper tier municipality, this level of emissions reduction planning is a particularly complex and resource-intensive path for the County and is not a favourable guideline in the near-term for the following key reasons:

-Resources: the gathering of baseline emissions would be a significant undertaking for the County of Simcoe and its 16 member municipalities. Furthermore, strategic partnerships would need to be established and strengthened to assist in gathering the required data to include all land uses, residential, commercial, industrial, institutional and transportation sectors. The County believes that such requirements would impose significant, burdensome resource and time demands on the County and member municipalities.

-Authority: if and once baseline emissions are gathered, a community-scale emissions plan requires a cohesive set of emissions reduction targets for the near- and long-term. Given that member municipalities and strategic partners would have independent authority to select unique targets, that said targets may differ, and that the County may have no authority to monitor or regulate these inputs, staff believe the creation of a cohesive community-scale emissions reduction plan with a shared emissions reduction target would be a difficult undertaking for the County of Simcoe.

In closing, the County understands the intent of the draft Guidelines to significantly reduce greenhouse gas emissions at the municipal level, and believe this to be a necessary and important path while planning for Ontario’s future growth. However, the scale, complexity and time constraints for our unique position as an upper tier municipality combines to make community-based emissions planning very difficult, if not next to impossible, at this time.

We will await further clarification on the draft Guideline and anticipate modifications that are less imposing on upper tier municipal resources and assign adequate authority to municipalities. If in the event that such guidelines become legislated, additional resources, financial support and proper time allowances would be a key requirement to undertake such an initiative.

[Original Comment ID: 213156]