I am a concerned Ontario…

I am a concerned Ontario resident, and I strongly oppose this Bill 4 which cancels Ontario’s Cap and Trade program. I want to make it very clear that I do not support Bill 4, nor do countless others, and Environment Minister Rod Philips does the province a disservice by repeatedly stating that he is fulfilling Ontarians’ wishes as justification for this action. He is not.

I also will highlight that evidence indicates that Ontarions will not be better off with the removal of cap and trade, as we do not live in a vacuum – scrapping a program which businesses and the public had come to accept doesn’t do families, our economy, and the environment any favors. I am a professional and recent graduate from two Ontario universities in the space of environmental engineering. I know from firsthand experience how the momentum around the need to take collective action on climate change has had on the next generation of thought-, science- and business-leaders of our province. Cap and trade and the government’s previous policies, action, and commitment to climate change action drove the innovation in the cleantech sector, and signaled to entrepreneurs and businesses the landscape in which to thrive in Ontario. Such a drastic reversal is completely regressive and this is too serious a topic to play politics on.

I reject the narrative of this current government that simply being elected gives them the authority to cancel policies and programs on such important matters with little to no public consultation. For future actions, I expect a thorough consultation period, with the use of a neutral third-party to support the process to ensure the complex topic and implications of action on climate change are explained in a transparent fashion to Ontarians and politics are left out of it. This government does the public and the planet a disservice by over-simplifying the mechanisms to lower emissions by suggesting there is an alternative to a carbon pricing mechanism (market based or otherwise) which will be more cost-effective. Carbon pricing mechanisms, while not the only tool necessary, are a proven market-based approach to lower emissions and incent innovation and creative alternatives, and are our best option in today’s world which is transitioning to a low-carbon economy.

I also do not support the related rhetoric by the provincial government to challenge the federal government on enforcing carbon pricing. Quite frankly, a topic such as climate change mitigation transcends provincial jurisdiction in my opinion and this backwards, short-sighted action by the provincial government only further highlights this. Leaving aside the dangerous path and precedent this Bill 4 introduces for a moment, the Ontario government has provided the public with no clear path forward. How can any reasonable person be expected to support the cancellation of a climate program without knowing what will replace it? All that is outlined is how the government will settle claims for those involved in the cap and trade program, not how the government will continue to decrease GHG emissions. This current process to which I am writing barely qualifies as due process under the Environmental Bill of Rights. Shame on this government for its regressive moves to dismantle the climate change policy in Ontario, particularly in light of the recent IPCC report highlighting the urgent and drastic work needed to mitigate impacts of climate change.

All to state, this action is regressive, on the wrong side of history and I strongly object to Bill 4. Do not proceed to enact this Act and restore Cap and Trade.

If changes are to be made to Ontario’s climate policies and regulations – I implore the government to base it on the latest scientific evidence and research to select a comprehensive set of actions and measures which will efficiently reduce greenhouse gas emissions to mitigate climate change, and plant to strategically fund adaptations to the impacts we are going to face.
Thankfully, Ontario has appointed an Environmental Commissioner which helps Ontarians understand complex environmental challenges and how our government’s policies and programs impact them, and to provide non-partisan, science-based information to the public and government to keep the Ontario government accountable.

The Environmental Commissioner of Ontario’s recently released 2018 greenhouse gas progress report provides a comprehensive overview including the impacts on climate change in Ontario, an evaluation of the climate change efforts in Ontario to date, including evidence of many positive impacts of the cap and trade program, and the negative impacts we can expect by dismantling this made-in-Ontario program. This can be referred to by the government when re-considering proceeding with Bill 4. It also helpfully provides information for building a strong program in Ontario to support climate change adaptation, which will help lower the costs to Ontarians who are currently footing the climate change bill directly or indirectly through property damages to private and public infrastructure from extreme, climate change related weather events. Finally, recommendations on how to build strong climate law in Ontario are outlined. A link to this report is referenced in my comments, and if I were the Ontario Minister of Environment, I would heavily rely on this valuable resource to inform the development of a new climate policy, building on, rather than scrapping all existing work and starting from scratch.

I will highlight a few key points and the key recommendations which I support, paraphrased and lifted verbatim in a few places from the ECO’s 2018 Greenhouse Gas Progress Report:

-The government has essential roles that no one else can play. Only with strong, clear provincial targets, rules and incentives can individuals, municipalities and the private sector do their best.
-Cap and trade was providing the motivation and billions in funding for meaningful emission reductions across the province to help address some of the primary sources of carbon pollution, transportation and buildings;
-Climate leadership was enhancing Ontario’s reputation and drawing in foreign investment, and cap and trade was on its way to producing many economic and environmental benefits for the people of Ontario.
-Unfortunately, cap and trade was both complex and poorly communicated; for some, its costs were more obvious than its benefits. Today, cap and trade, the low-carbon programs that it funded, and 752 renewable energy projects have all been swept away, with nothing in their place.
-Strong climate law is needed to bring climate pollution down in Ontario. This should include:
1. long-term, science-based greenhouse gas emissions targets, and five-year carbon ‘budgets’; targets should reduce emissions from 1990 levels by:
a. 37% by 2030 and
b. 80% by 2050
2. a legal obligation to stay within these targets and budgets and
3. regular progress reports the public can trust.
-A strong climate change law would give climate action in Ontario a backbone, but the government would need policies and programs that work to reduce carbon emissions as well.
There are three types of tools that can work:
• a polluter-pay system, that charges people and businesses when buying fossil fuels.
• raising money to pay for solutions, such as public transit or building retrofits.
• regulations, like fuel efficiency standards for cars and trucks, or energy efficiency standards for buildings.
-There is no perfect answer, but the best international model for long-term consistency is the United Kingdom’s Climate Change Act. The U.K. Parliament sets legally binding long-term emission limits, plus five-year carbon budgets 12 years in advance, based on non-partisan, expert advice and reporting. Ontario should do the same.
-Another key feature of an effective climate policy is good consultation with the public, as the Environmental Bill of Rights (EBR) requires.
-A detailed model of Ontario’s energy system, commissioned by the ECO, shows that Ontario can minimize the cost of reducing emissions by: 1) investing in new emissions reduction technologies, including carbon capture and storage, and ways to store carbon in natural systems, 2) significantly conserving energy and increasing Ontario’s clean electricity supply, and 3) preparing to minimize fossil fuel use in transportation, buildings and industry.
-Polluter pay principles are central to managing environmental costs of a pollutant. Carbon pricing falls under this. There are also other variations, such as congestion pricing or feebates.
-The second key element is funding to invest in low carbon solutions. Without the $1.9 billion/year from cap and trade, how can Ontario unlock funds for these solutions, especially if the federal carbon tax does not kick in? Stopping Ontario’s subsidies for fossil fuel use is one key options.
-Regulating climate polluters, and enforcement of those regulations, is the third key element. In many jurisdictions, regulations do most of the heavy lifting. Transportation, buildings and waste are key sectors for regulation because emissions from all three sectors have grown since 1990. The strongest regulations directly affect emissions, such as bans, pollution limits or technology or performance requirements. Supplementary regulations may motivate emission reductions, such as reporting and disclosure requirements, and may also facilitate voluntary action.

I support the ECO recommendations that the provincial government should immediately develop a climate framework with the following central features (with 2018 GHG Progress Report section references):

1. Commit: targets and law
a. A climate law that commits the provincial government to a credible, long-term program to achieve statutory emission reductions that: i. meets Ontario’s fair share of Canada’s emission reduction obligations and creates good jobs (sections 1.5 and 3.1), and ii. meets the requirements of the Pan-Canadian Framework to unlock federal funds (section 3.3).
b. Legally binding carbon budgets set well in advance, based on non-partisan, expert advice, coupled with rigorous progress reporting and independent evaluation (section 2.1).
c. Provincial leadership on adaptation and preservation of natural areas (Part 4).
2. Plan a pathway
a. A transparent, achievable, cost-effective pathway to each carbon budget. The model described in this report is a good start. Note: The lowest-cost pathways require much more clean electricity and storage than the current Long-Term Energy Plan will provide (section 3.1)
3. Take action
a. Effective policy tools to achieve the necessary emission reductions, using the lowest-cost pathway, public health and ecological integrity to choose priorities. Appendix A contains a convenient menu of the potential tools discussed in this report.
b. Act fast and take advantage of work already done, here and elsewhere. Ontario is not starting from scratch and does not need to reinvent the wheel. Build on the best of the previous programs. Emphasize efficiency first (e.g., in social housing, schools, hospitals) (section 1.3, Appendix B).
c. Minimize disruption from the cancellation of previous programs (section 1.4).
4. Check and improve
a. Monitor and report progress to the public, with third-party validation (section 2.2), and
b. Revise plan and actions as needed to stay on track for targets (section 2.2).

Once again, I strongly object to Bill 4 and the cancellation of Ontario’s Cap and Trade Program. I also object to how this process has played out, with minimal public consultation. If the current Ontario Government feels it necessary to make changes to Ontario’s climate change strategy, a reasonable, intelligent leader of the Ontario Government would acknowledge that carbon pricing is going to be part of the most cost-effective solution - and not waste anyone’s time or energy trying to fight this further, and would study the ECO’s 2018 Greenhouse Gas Progress Report and appendices for developing a way forward. Take this opportunity to be a strong leader in climate change action, build on the progress to date and be on the right side of history. Thank you.